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For more than 20 years, Trinity Consultants has assisted facilities in the aerospace industry with regulatory compliance and environmental management issues.
Trinity has a long history of assisting facilities with their regulatory compliance and environmental management systems.
Trinity helps chemical and pharmaceutical manufacturers to achieve regulatory and environmental compliance.
Trinity has assisted clients with nearly 500 power-related projects, offering an array of services.
Due to their nature, “general manufacturing” facilities are often faced with reviewing a wide range of regulations to determine applicability.
Trinity provides a variety of services to government entities, including environmental permitting and compliance management.
Trinity Consultants has long been committed to assisting lime and aggregates facilities with their regulatory compliance needs.
Trinity takes pride in understanding the regulatory issues affecting our clients’ facilities and their industry.
Oil and gas facilities must contend with a variety of regulatory compliance and environmental management demands.
Trinity helps petroleum refineries to achieve compliance with complex environmental regulatory requirements.
Trinity Consultants has long been committed to assisting cement facilities with their regulatory compliance and environmental management needs.
Trinity has extensive experience assisting the pulp and paper industry with its regulatory compliance and environmental management requirements.
Railroads are faced with rapidly evolving state, regional, and federal regulatory framework in the United States.
For more than 25 years, Trinity Consultants has assisted facilities in the semiconductor industry.
Trinity Consultants has performed nearly 800 environmental permitting and compliance projects for clients with terminal operations, providing cost-effective, timely solutions that enhance compliance while maintaining operational flexibility.
For nearly 30 years, Trinity Consultants has assisted facilities such as those in the highly regulated wood products industry.
Access to two data sets that are critical to AERMOD dispersion modeling set up that were available through the Multi-Resolution Land Cover Characteristics (MRLC) Consortium website ( https://www.mrlc.gov/viewerjs/) has recently been permanently »
The State of New Mexico and EPA have released a draft white paper titled "Oil and Natural Gas Produced Water Governance in the State of New Mexico". The 43-page document addresses the roles of different agencies in managing produced water from oil »
In 2018, Rob Large joined Trinity Consultants as Managing Consultant on the EHS Performance & Risk Management team. Rob has more than 28 years of environmental and occupational health and safety compliance experience and over 17 years of auditing »
The ISO 45001:2018 Occupational Health and Safety Management System (OHSMS) standard was published in March 2018, replacing the OHSAS 18001:2007 OHSMS standard. Publication of this new standard is part of a broader effort by the International »
Leak Detection and Repair (LDAR) involves finding facility components that are leaking and fixing them. The U.S. Environmental Protection Agency (EPA) has a long history of regulating industries (such as petroleum refining and chemical »
Trinity's Environmental Quarterly (EQ) magazine covers environmental regulatory developments as well as topics related to corporate environmental performance.
all issues from 2009
These papers, presentations, and articles were authored by the staff of Trinity Consultants for presentation at various conferences.
all papers & presentations
Since its founding in 1974, Trinity has expanded its geographic footprint and breadth of services. We attribute our continued growth to a focus on cornerstone values of top-notch technical performance and excellence in client service.
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The very first step in determining NSR applicability is to define what constitutes the “stationary source.” When determining which pollutant-emitting activities should be considered part of the same “major source” under the Title V operating permit program, and/or part of the same “stationary source” under the New Source Review (NSR) program, permitting authorities assess three factors-same industrial grouping, location on contiguous or adjacent property, and common control-on a case-by-case basis. In the original promulgation of these three factors in the NSR program regulations, EPA was mindful of a decision from the D.C. Circuit Court holding that the “source” for NSR permitting purposes should comport with the “common sense notion of a plant.” (45 Fed. Reg. 52676, 52694, Aug. 7, 1980, (citing Alabama Power Co. v. Costle, 636 F.2d 323, D.C. Cir. 1979). The determination of stationary source was further complicated by adding the “support facility” test in determining what constitutes the stationary source.
EPA and courts have added more clarity and guidance over the past 3 years. Most recently, EPA released detailed guidance on this subject in the 2018 Meadowbrook letter which addressed the “common control” factor in the definition of stationary source. The 2012 Summit Petroleum case focused on the “contiguous or adjacent property” element. The concept of “same industrial grouping” (SIC code) has been covered in various EPA letters/memos that address the “support activity” vagaries. Our presenters examine the three part criteria including how the Summit Petroleum case and 2018 Meadowbrook affect future determinations of stationary sources. Topics include:
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