Trinity provides broad support for tank owners to assist with environmental compliance as well as broader design and inspection support. We routinely assist tank owners with identifying applicable regulations, obtaining proper permits, addressing ongoing compliance obligations, and quantifying emissions associated with storage tanks. With the addition of TGB Partnership in 2017, we have added expertise in regulatory development, tank emission factors, tank emission calculation software, and floating roof design and inspection. Trinity's unmatched credentials regarding tank emissions and design can help you streamline compliance with complete peace of mind.
TGB Partnership Joins Trinity
In 2017, Trinity Consultants acquired TGB Partnership, a consulting and software firm that specializes in the control of air emissions, the development of standards and regulations, data analysis, and the design of aluminum structures. TGB was founded in 1993 by Robert L. (Rob) Ferry and J. Randolph (Randy) Kissell, structural engineers and renowned experts on atmospheric storage tanks and aluminum structures. Rob is a trusted consultant to several trade associations and private sector clients and has led the petroleum industry's development of recommendations to EPA regarding standards and emissions calculations for storage tanks. Randy is a long-standing consultant to the Aluminum Association, as well as numerous private sector clients, serving as technical expert and primary author for the Aluminum Association's Aluminum Design Manual. TGB's powerful TankESP Software is now available through Trinity, with single site or corporate-wide licenses available.
Environmental, Health, and Safety Compliance
Trinity works routinely with tank owners to determine applicable environmental regulations and demonstrate compliance, including the following:
- Environmental permitting support
- Clean Air Act (CAA) new construction and operating permits
- Minor New Source Review (NSR)
- Prevention of Significant Deterioration (PSD)
- Nonattainment NSR
- Major Source Maximum Achievable Control Technology (MACT)
- Title V
- Clean Water Act (CWA) Spill Prevention, Control, and Countermeasure [SPCC] permits
- Clean Air Act (CAA) new construction and operating permits
- Tank emissions calculations based on the latest emission factors
- NESHAP and NSPS compliance
- NESHAP Subparts G, R, CC, WW, EEEE, and BBBBBB
- NSPS Subpart K, Ka, Kb, OOOO, and OOOOa
- Dispersion modeling to estimate the impact of tank emissions for air quality permitting, compliance, capital planning, design, and safety
- Emissions reporting
- Annual Emission Inventory (EI)
- Toxic Release Inventories (TRI)
- Tier II Reporting (EPCRA, CERLCA)
- Risk Management Planning (RMP) / Process Safety Management (PSM)
- Compliance auditing
Tank Emissions Software Tools
Phasing Out of EPA's TANKS 4.09D
Since its release in October 2006, EPA's TANKS 4.09D software tool has been widely used by regulatory agencies, the regulated community, and consultants to estimate VOC and HAP emissions from fixed- and floating-roof storage tanks. Because this model was developed using software that is now outdated, EPA no longer supports the program and has issued certain disclaimers regarding the use of this program:
“…we can no longer provide assistance to users of TANKS 4.09D. The model will remain on the website to be used at your discretion and at your own risk…” - EPA
EPA has clarified that use of the TANKS program provides no enforcement protection for inaccuracies in tank emissions estimation data. Furthermore, there are a number of issues regarding the use of the TANKS program, and several limitations. Namely, TANKS 4.09D SHOULD NOT be used for the following:
- Heated tanks without insulation
- Tanks storing warm product
- Tanks with significant variations in throughput month by month
- Monthly/Ozone season emissions for all tanks
In addition, TANKS does not calculate the following:
- Tank landing emissions (included in AP-42 Section 7.1)
- Tank cleaning emissions
- Short-term emissions
- Flashing emissions
View a detailed description of many of the issues associated with TANKS 4.09D.
AP-42 Emission Factor Revisions
The selection of alternative tank emissions tools may be made even more important by expected revisions to Chapter 7.1 of EPA's AP-42 document (guidance for estimating emissions from storage tanks) that are currently in draft form and under review by EPA. For information on AP-42 changes under review that would impact tank emissions estimation, see Trinity's Environmental Quarterly Winter 2017 article, Estimating Tank Emissions - Changes May be Coming.
Tank Emission Calculation Tools
Depending on your organization's needs, Trinity has several options for automating tank emission calculations. These include:
TankESP - robust software product that addresses a variety of stored products and related emissions (site and corporate licensing available
- Trinity's tank tool - a cost-effective tool with some limitations on number of tanks (slower performance for > 100 tanks)
- Data Integration/Automation (DIA) with Tank Module - links with plant process historian to generate accurate “net throughput” and service information and automate tank emission calculations
- Custom solutions to meet your organization's needs
Tank Calculations Training
Trinity routinely provides training for environmental professionals on tank emissions calculations. Our courses include the Fundamentals of Tank Emissions Calculations and Tank Emission Calculation Workshop with TankESP Software , which are taught consecutively several times a year. Attendees to both courses save 25% on the course fees. We also provide custom training to meet the needs of individual organizations.
Floating Roof Design and Inspection
Our expertise in floating roof design allows Trinity to assist you in selecting and specifying the appropriate type of floating roof based on structural and emissions concerns. Furthermore, we can assist with developing your inspection program including review of inspection forms and templates and training of in-house personnel on how to properly perform inspections. Alternatively, we can perform the inspections for you.
For broad environmental assistance for your storage tanks, Trinity offers unmatched expertise and service quality. Contact us online or at (800) 229-6655.