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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 provides dispersion modeling, permitting, and compliance support for coastal operations in the Outer Continental Shelf, Deepwater Ports, and liquefied natural gas terminals.
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 prepares hundreds of air quality compliance reports for landfills and industrial facilities across the United States on an annual basis.
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.
On February 4, 2019, EPA proposed amendments to 40 CFR Part 63, Subpart NNNNN, National Emission Standards for Hazardous Air Pollutants (NESHAP) from the Hydrochloric Acid Production (referred to as HCl MACT). EPA anticipates that the proposed »
Jennifer Milner, State Recycling Coordinator for MDEQ's Recycling and Waste Reduction Branch, was recently announced as a winner in Waste360's fourth annual 40 Under 40 Awards Program which honors leaders who are shaping the future of the waste and »
In January 2019, Trinity Consultants (Trinity) acquired The Redstone Group (Redstone), a consulting services provider of international chemical control laws, and EHS auditing, compliance and permitting.Redstone has deep expertise and advises clients »
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.
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These papers, presentations, and articles were authored by the staff of Trinity Consultants for presentation at various conferences.
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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.
As we are approaching the end of January, several reports are coming due in the next few months. March 1 - Tier II Report and Hazardous Chemical »
The Oklahoma Air Quality Advisory Council Meeting schedule for the coming year has been announced. Following are the dates: January 16, 2019 - DEQ's Multipurpose Room in »
DEQ has announced the dates and locations for their annual emission inventory (Redbud) workshops: Wednesday, January 23, 2019, in Norman at the National Weather Center »
The final Air Quality Advisory Council (AQAC) meeting of 2018 had a full agenda. The first two rulemaking items, involving changes to VOC regulations in multiple areas of the Oklahoma »
The next Air Quality Advisory Council hearing is scheduled for October 10 in the DEQ headquarters' meeting room (first floor). Based on the Notice of Rulemaking, the agenda will include »
The Oklahoma DEQ recently released a proposed guidance document that provides general guidance for determining when it is appropriate to use a representative analysis for oil and gas »
The DEQ Air Quality Division is currently taking comments on the proposed certification that Oklahoma has adequate resources and authority to implement, maintain, and enforce the 2015 Ozone »
The Oklahoma DEQ recently released a proposed guidance document that provides general guidance for determining when it is appropriate to use a representative analysis for oil and gas facilities. The document also details criteria on how »
The DEQ Air Quality Division is currently taking comments on the proposed certification that Oklahoma has adequate resources and authority to implement, maintain, and enforce the 2015 Ozone National Ambient Air Quality Standards (NAAQS). This »
Written comments on the proposed updated regulations governing Oklahoma's delegation of authority for federal National Emission Standards for Hazardous Air Pollutant (NESHAP) regulations (also known as MACT rules) promulgated in 40 CFR Parts 61 and »
The 2017 Air Data Report has been posted. The report charts air quality monitoring data collected at 30 monitors for criteria pollutants across the state. The report shows Oklahoma is in attainment for all the NAAQS, along with analysis of each »
EPA continues to fundamentally change policies on how the PSD pre-construction air permitting program is to be implemented. It started with a December 7, 2017 memo focused on the procedural requirements for, and EPA's policy regarding scrutinizing, »
One of the key issues discussed during the EFO's Newsreel on June 21st was ODEQ's plan to replace the EI reporting system, Redbud, with the State and Local Emission Inventory System (SLEIS). SLEIS is currently in use in several other states, »
An Air Quality Advisory Council Meeting was held in Owasso on June 20, 2018, and the primary topic involved new and revised rules for aerospace coating operations in Tulsa County. The proposed rulemaking will be presented at the next meeting before »
DEQ recently released the draft SO2 Annual Report for public review and comment. The report summarizes annual SO2 emissions from five applicable sources in counties that were designated as attainment/unclassifiable for the 2010 primary SO2 NAAQS »
The DEQ EI Division Director has extended the 2017 emissions inventory due date to 11:59 p.m. on April 4, 2018. If Redbud should have any other disruptions, notice will be posted here. For assistance in completing your emissions inventory, contact »
If Emissions Inventory season is just around the corner. DEQ will begin e-mailing passwords for the upcoming 2018 filing season on Tuesday, January 2, 2018. Once passwords are received, it will be possible to begin entering EI data for 2017. The »
The ODEQ published its 2016 Air Data Report on September 19, 2017. The full report is available on the DEQ's website. In summary, all criteria pollutant monitoring results across the state in 2016 (one-year averages) were less than the values of the »
The Oklahoma Department of Environmental Quality (DEQ) has issued the "General Permit OKR10 for Stormwater Discharges from Construction Activities within the State Of Oklahoma". This permit will replace Construction General Permit (CGP) OKR10, which »
One year after the last publication, DEQ revised its Modeling Guidelines again in June 2017. Many of the revisions involve simple updates to referenced materials such as EPA websites. The more substantive changes were largely due to EPA's revised »
The current CGP expires on September 17, 2017. The DEQ is proposing a new CGP. A public comment meeting is to be held on August 23rd at DEQ headquarters.The draft CGP has been streamlined but many of the requirements remain unchanged. The DEQ is »
The Oklahoma Department of Environmental Quality (ODEQ) has issued the final Multi-Sector General Permit (OKR05) for Stormwater Discharges from Industrial activities. There are some changes in the new permit that affect all facilities covered by the »
On April 6, EPA finalized revisions to electronic reporting in MATS (Mercury and Air Toxics Standards), and corrected inadvertent errors. The final rule extends the interim period for power plants to submit hard copies of initial and subsequent »
The DEQ is proposing to create a new Permit by Rule (PBR) for gasoline dispensing facilities. The new PBR would cover the applicable requirements of NESHAP CCCCCC and, for sites that operate emergency engines, the applicable requirements of NSPS »
DEQ recently issued a draft guidance document to address condensate and crude oil loading losses from tank trucks calculated using AP-42, Section 5.2. The main purpose of the guidance is to address the percent reduction that can be applied to these »
In the April 13th Federal Register, the EPA published a request for input on regulations that may be appropriate for repeal, replacement, or modification. The request comes after a February 24th executive order signed by President Trump. Executive »
The USEPA recently promulgated the NPDES Electronic Reporting Rule to modernize Clean Water Act reporting for municipalities, industries, and other facilities by converting to an electronic data reporting system. In Oklahoma, the electronic »
The EPA proposes to revise its regulations to streamline and clarify processes related to submission and review of Title V petitions. The revisions provide guidance on the format for petition submittal, establishing minimum required content and »
On June 30, 2016 EPA completed its second round of area designations following the June 22, 2010 establishment of a new primary 1-hour SO2 NAAQS level of 75 parts per billion (ppb) which was implemented to protect the public against health effects »
SummaryOn May 27, 2016, EPA issued a preliminary "notice of data availability" (NODA) under the Cross-State Air Pollution Rule (CSAPR) for the first round of "new unit set-aside" (NUSA) emission allowance allocations for the 2016 compliance period. »
Proposed revisions to the Regional Haze Rule (40 CFR Parts 51 and 52) were published in the Federal Register on May 4, 2016. A full copy of the federal register can be found here. This rule directly impacts state, local, and tribal governments as »
Two proposed rules, NSPS Subpart OOOOa (Oil and Natural Gas Sector: Emission Standards for New and Modified Sources) and Source Determination for Certain Emissions Units in the Oil and Natural Gas Sector, were recently sent to the Office of »
Revisions to the Prevention of Significant Deterioration (PSD) and Title V Greenhouse Gas (GHG) Permitting Regulations and Establishment of a GHG Significant Emissions Rate, was recently sent to the Office of Management and Budget (OMB) for »
The Oklahoma Department of Environmental Quality (ODEQ) recently proposed a revised Minor Source General Permit for Oil and Gas Facilities (GP-OGF). The GP-OGF was developed to authorize construction and/or operation of oil and gas facilities with »
On April 6, 2016, the Environmental Protection Agency (EPA) published to the Federal Register the final rule to 40 CFR Part 60 Subpart Da ("Utility NSPS") and 40 CFR Part 63 Subpart UUUUU ("Utility MATS"). These revisions were proposed on February »
According to United States Coast Guard data from the last ten years, there are thousands of hazardous substance spills each year from industrial facilities that are not subject to any hazardous substance spill prevention rules. EPA has agreed to »
On March 3rd, just weeks after the Supreme Court of the United States stayed the Clean Power Plan, Chief Justice John G. Roberts Jr. made a different ruling on the Mercury and Air Toxics Standards – deciding not to stay the regulation despite the »
On February 9, 2016, the U.S. Supreme Court granted a stay of the final Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (Clean Power Plan) until the applicants' petitions for review in the »
The BLM is proposing new regulations for drilling, completions, and related operations at onshore Federal and Indian leases. The proposed rule would require operators to take various actions to reduce waste of gas, establish clear criteria for when »
In a letter dated February 11, 2016, EPA released Round 2 of its Intended Designations for the 2010 Primary 1-hour SO2 National Ambient Air Quality Standard, pursuant to a March 2, 2015, court-ordered schedule. Of primary concern is the proposed »
January 14, 2016 - EPA has extended the deadline for responding to a request for additional data and information on emissions of hazardous air pollutants (air toxics) that were not available in 2012 when EPA updated its major source air toxics »
On January 21, 2016, the D.C. Circuit Court of Appeals denied requests from industry and dozens of states to halt the rule while litigation proceeds. The court also announced key case dates: initial briefs are to be filed April 15 and final briefs »
On December 8, 2015, the Air Quality Department (AQD) implemented the new General Permit (GP) for Air Curtain Incinerators. The GP is to authorize the construction and/or operation of air curtain incinerator (ACI) facilities with actual emissions »
The oil and natural gas industry operating in Osage County has been finding it more and more difficult to operate since the Bureau of Indian Affairs (BIA) recently made it more difficult and time-consuming to get drilling permits. Now a new ruling »
On January 29, 2016, the Environmental Protection Agency (EPA) proposed an amendment to the greenhouse gas reporting rule (40 CFR Part 98 Subpart W) to align leak detection monitoring methods with the method in the proposed New Source Performance »
On January 5, 2016, EPA finalized its partial disapproval of a February 19, 2010 revision to the Oklahoma SIP that addressed the Clean Air Act regional haze requirement to establish reasonable progress goals for the Wichita Mountains Class I area. »
Despite some dissenting comments from the Oklahoma Sierra Club, the Air Quality Council voted unanimously to approve the revisions to OAC 252:100-9, Excess Emission Reporting Requirements, after a holdover for further discussion from the October »
On December 7, 2015, the United States Environmental Protection Agency (EPA) published in the Federal Register the final version of the amendments to the Aerospace Maximum Achievable Control Technology (MACT) found in 40 CFR Part 63, Subpart GG »
On July 13, 2015 new EPA regulations on the "Definition of Solid Waste" came in effective. DEQ is proposing amendments to its rules in OAC 252: Chapter 205 - Hazardous Waste Management. The amendments will incorporate by reference the new federal »
The Environmental Protection Agency (EPA) has proposed a rule that would update the requirements to 40 CFR Part 82 Refrigerant Management Requirements under the Clean Air Act. The current regulations require that persons servicing or disposing of »
In 2012, EPA revised NESHAP regulations for Oil and Natural Gas Production Facilities and Natural Gas Transmission and Storage Facilities. EPA is now requesting additional data that was not available at that time, specifically:HAP Emissions from »
On October 24, 2012, the Environmental Integrity Project (EIP), together with 16 other organizations, submitted a petition to the USEPA to add the Oil and Gas Extraction sector (SIC 13) to the list of sectors covered by section 313 of Emergency »
On January 1, 2016, the Environmental Protection Agency (EPA) is finalizing 2015 revisions and confidentiality determinations for petroleum and natural gas systems source category of the Greenhouse Gas Reporting Rule (GHGRR). Entities affected by »
In addition to the Excess Emissions Reporting Requirements discussed above, the Air Quality Advisory Council also discussed the following amendments:The first amendment discussed was the proposed new Permit by Rule (PBR) for emergency engine »
On May 22, 2015, EPA Administrator Gina McCarthy signed the final "SSM SIP Call" rule. The rule contains EPA's response to a 2011 Petition for Rulemaking regarding the treatment of startup, shutdown, and malfunction (SSM) excess emissions in state »
On October 1, 2015, the U.S. Environmental Protection Agency (EPA) announced the new National Ambient Air Quality Standards (NAAQS) for ground-level ozone. Originally proposed as one of the six criteria air pollutants under the Clean Air Act, »
On September 15, 2015 the Environmental Protection Agency (EPA) proposed its National Enforcement Initiatives (NEIs) for 2017-2019. The EPA is soliciting public comments and recommendations on the proposed NEIs by no later than October 14, 2015 »
In June 2014, the EPA issued proposed rules that will affect petroleum refineries currently subject to the Refinery MACTs (40 CFR Part 63, Subparts CC and UUU). The new rules contain additional requirements for storage tanks, flares, and coking »
As a follow-up to the proposed rules summarized in our last eNews, EPA recently announced that it will be holding public hearings for three of the recently proposed rules affecting the oil and gas industry. The proposed rules include updates to »
Often an acquisition in the Oil & Gas Industry may involve either a large number of previously operated well locations or the rights to explore on large undeveloped parcels of land. In order to protect oneself from unwarranted risk it is advisable »
In June and July 2015, OSHA published significant OSHA logo changes to its enforcement policies on the Process Safety Management (PSM) standard in the form of guidance documents. These changes reflect items listed in the PSM RFI (December 9, 2013) »
The U.S. Environmental Protection Agency (USEPA) published a final rule in the Federal Register on July 13, 2015 (80 FR 39961) finding that 24 states failed to submit State Implementation Plans (SIPs) to satisfy requirements of the Clean Air Act »
On August 18, 2015, EPA issued a suite of new proposed rules and guidance affecting the oil and gas industry, including:Minor revisions to NSPS Subpart OOOO designed to streamline certain monitoring and continuous compliance demonstration »
On June 23, 2015, EPA sent its proposed methane leak rule to the White House Office of Management and Budget for final review. The proposed regulations are aimed at minimizing methane leaks from the oil and natural gas sector as part of the »
On July 15, 2015 the Environmental Protection Agency (EPA or the Agency) published in the Federal Register the Final Rule to 40 CFR Parts 280 and 281 Revising Underground Storage Tank Regulations. EPA is making revisions to the existing requirements »
EFO sponsored their annual regulatory update seminar at the Oklahoma City Zoo on June 26th. Among the speakers were ODEQ Executive Director Scott Thompson, who remarked about his desire for ODEQ to practice open communication with regulated »
On May 22, 2015 EPA Administrator Gina McCarthy signed the final "SSM SIP Call" rule. The rule contains EPA's response to a 2011 Petition for Rulemaking regarding the treatment of startup, shutdown, and malfunction (SSM) excess emissions in state »
The ODEQ Air Quality Advisory Council met on Wednesday, June 10, 2015 in Owasso. The Council discussed the following rule changes:Subchapter 5 (Emission Inventory): proposed amendment that would lower the inventory reporting threshold for lead to »
Air Quality Division (AQD) of DEQ is in the process of updating the forms used to apply for renewal of a Title V (Part 70) operating permit. One of the expected changes will be deletion of the requirement to submit a copy of the previous year »
The Air Quality Division (AQD) of DEQ is in the final stages of preparing for the release of two air permit application options. For incinerators the legal notices of an opportunity for public review of the draft General Permit were published on May »
Three major elements of Oklahoma State government have taken actions to resist the Clean Power Plan (CPP). CPP has been proposed to limit carbon emissions from coal-fired electric generating plants. U.S. EPA is relying on Section 111(d) of the »
Most AERMOD dispersion modeling is conducted using meteorological data from a nearby airport. As long as the airport is reasonably representative of your source location, there is nothing wrong with that: airports are often a source of high »
At the April 1, 2015 Oklahoma Oil and Gas Association (OKOGA) meeting, U.S Environmental Protection Agency (EPA) Region 6 Director Ron Curry and newly appointed Principal Advisor to EPA Administrator, Teresa Marks, laid out Ms. Marks' first priority »
DEQ has announced that Rick Groshong has been promoted to be the head of the Compliance/Enforcement Sections of Air Quality Division. Mr. Groshong has been in this Section for about 18 years and is replacing Ms. Kendal Stegmann. He stated that »
On April 21, 2015 the U.S. EPA withdrew a direct final rule that had been published February 24, 2015. The rule that was published in February delegated authority of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for all »
On January 7, 2015, the EPA will require all states to comply with a federal "model rule," if a state does not submit a custom plan under the new climate change regulations. The regulations are based on the Clean Air Act, and each state may »
On January 14, 2015, the President released a new goal to cut methane emissions from the oil and gas sector by 40 - 45 percent from 2012 levels by 2025. Methane emissions accounted for nearly 10 percent of U.S. greenhouse gas emissions in 2012, of »
Nov. 26, 2014 - EPA is proposing to tighten air quality standards for ground-level ozone, or smog, within a range of 65 to 70 parts per billion (ppb), while taking comments on a level as low as 60 ppb. The Clean Air Act requires EPA to review the »
Nov. 4, 2014 - The EPA is proposing a rule (RIN 2060-AQ75) which will target emissions of hazardous air pollutants that come from petroleum refineries. The proposed rule, signed in May by EPA Administrator Gina McCarthy, would revise emissions »
The Environmental Protection Agency (EPA) published the final rule for the (Greenhouse Gases) GHG Mandatory Reporting Rule MRR 40 CFR Part 98 on October 24, 2014. In summary: "The Environmental Protection Agency (EPA) is amending the »
Fossil Fuel-Fired Electric Utility Steam Generating Units The Environmental Protection Agency (EPA) is taking final action on its reconsideration of the startup and shutdown provisions in the final rules titled, "National Emission Standards for »
Facilities that are major sources of HAPs, and that operate affected boilers and process heaters need to comply with 40 CFR 63 Subpart DDDDD by January 31, 2016, or 180 days after startup of the source, if after the regulatory compliance date. This »
Ms. Gerlach serves as a Consultant in Trinity's Oklahoma City office. She provides assistance with permitting, air dispersion modeling, emissions inventories, fugitive component studies, regulatory applicability and tasking studies, and »
Temporary workers are often at a higher risk for workplace injury and illness. This could be due, in part, to the unfamiliarity with the work site but can also be a result of inadequate health and safety training. The Occupational Safety and Health »
Trinity's senior consultants can bring your staff concise, practical, and accurate information on compelling environmental issues. Management briefings can be delivered in a timeframe and format that is useful for you, such as:• One-hour briefing of »
Subchapter 2, Incorporation by ReferenceSeveral federal subparts have been incorporated by reference, view the full list Review.Subchapter 5, Emission InventoryThis rule revises the current emission inventory reporting schedule for all minor source »
The EPA recently released a proposal that will change some of the emission factors for industrial flares The most notable change is for the nitrogen oxides (NOX) factor, which is approximately 43 times greater than the existing factor. This change »
EPA Announces Steps to Reduce Greenhouse GasesOn September 19, 2014 EPA Administrator Gina McCarthy met at the White House with private and public sector leaders to discuss actions to curb emissions of hydrofluorocarbons (HFCs), greenhouse gases »
On September 16, 2014 EPA announced that it will be extending the public comment period for its proposed rules on carbon dioxide emissions from power plants. The deadline for finalizing standards is June 2015. The Acting Assistant Administrator »
Each organization has a unique EHS culture. It is critical to understand and manage your organization’s EHS culture in order to maintain positive EHS performance. EHS performance is most often driven by employee actions and behaviors, which are »
Many facility operations incorporate the use of oil/water separators. According to Chapter 5 of the EPA's revised SPCC Guidance for Regional Inspectors, the intended use of an oil/water separator determines whether the separator is subject to the »
Later this year, the Environmental Protection Agency (EPA) will decide whether it should tighten the air-quality standard for ground-level ozone. In 2008, the EPA set ozone standards for air quality at 75 parts per billion (ppb). The EPA is now »
The Air Quality Division, in cooperation with the Oklahoma Secretary of Energy & Environment and the Oklahoma Corporation Commission, is working to involve the public, state electrical utilities, and other stakeholders during the development process »
On June 23, 2014, the U.S. Supreme Court issued its decision in Utility Air Regulatory Group v. EPA (No. 12-1146). The Court said that EPA may not treat greenhouse gases as an air pollutant for purposes of determining whether a source is a major »
Update: On August 19, 2014, in response to recommendations from state and tribal representatives, EPA sent letters outlining the areas that are intended for designation for the annual fine particle air quality standards set in 2012.On April 25, »
USEPA has been performing several Risk and Technology Reviews (RTRs) throughout multiple industries. The Clean Air Act (CAA) requires that RTRs, a combined effort to evaluate both risk and technology, be performed within eight (8) years after »
On July 31, 2014 EPA issued a Request for Information (RFI) on the Risk Management Program (RMP) standard in response to Executive Order 13650 (EO 13650). Section 6(e)(ii) of EO 13650, , issued August 1, 2013, in response to industrial incidents »
Trinity recently contributed to an article by EMIS provider Credit360 on best practices in deploying a successful EHS management system. The article, published in EHS Today, examines steps an organization can take to identify the best and »
On August 18, 2014, the Environmental Protection Agency denied environmentalists a petition that would name almost 60 areas of the country out of compliance with the federal ozone standard. The agency told the Sierra Club and Earthjustice that it »
The Environmental Protection Agency has again extended the public comment period for proposed refinery regulations. The new date is October 28, 2014 for all comments to be submitted to the EPA. The EPA would like ensure the public has sufficient »
SANGEA™ is a user-friendly software program owned by the American Petroleum Institute (API) and designed to assist petroleum and natural gas companies with estimating, managing and reporting greenhouse gas (GHG) emissions. In 2012, Trinity »
The Environmental Protection Agency (EPA) has announced a proposal for a new rule to improve control of toxic air emissions from petroleum refineries.The new rule would call on refineries to optimize emissions control with maximum achievable control »
The Environmental Protection Agency (EPA) is proposing to amend the standards for gas well affected facilities to provide greater clarity concerning what owners and operators must do during well completion operations, especially the provisions for »
The EPA has announced an extension of the comment period for a June 5, 2014, advance notice of proposed rulemaking (79 FR 32502) that would amend regulations under 40 CFR 49 to address the implementation of the Indian country minor new source review »
The Environmental Protection Agency is proposing general permits for use in Indian country pursuant to the Indian Country Minor New Source Review (NSR) rule for new or modified true minor sources in the following six source categories: Concrete »
On June 26, 2014, the EPA asked the D.C. Circuit to re-instate Cross State Air Pollution Rule (CSAPR) following the Supreme Court decision upholding EPA's approach to addressing interstate air pollution. Bottom Line - If granted, EPA's motion will »
As part of the President's Climate Action Plan - Strategy to Reduce Methane Emissions, the U.S. Environmental Protection Agency (EPA) is proposing updates to its air standards for new municipal solid waste (MSW) landfills. These updates would »
Leak detection and repair (LDAR) programs live and die by their details. As years pass after the implementation of an LDAR program, and the staff involved either retire or move on to other assignments, it is easy for those details to start to lose »
On June 2, 2014, at the direction of President Obama and after an unprecedented outreach effort, the U.S. Environmental Protection Agency is releasing the Clean Power Plan proposal, which for the first time cuts carbon pollution from existing power »
Attorney General Scott Pruitt commented June 2, 2014 on the EPA's proposed rule to limit greenhouse gas emissions from existing power plants. "While the EPA says the new greenhouse gas emissions rule for existing power plants gives states »
The PC MACT was originally finalized in June 1999 with a compliance date of June 2002 for existing sources. Since then, the rule has been amended several times, most recently in September 2010 and February 2013. The February 2013 amendments set a »
On May 30, 2014 the United States Court of Appeals for the District of Columbia Circuit vacated an Environmental Protection Agency (EPA) Clean Air Act (CAA) directive that implemented a decision of the United States Court of Appeals for the Sixth »
According to the Verdantix Green Quadrant report for EH&S software, common EH&S function plays a leading role in selecting and funding EH&S software. The specific capabilities and areas of functionality that EH&S leaders look for when evaluating »
More rulemaking could be on the way from the Environmental Protection Agency (EPA) for oil and gas facilities located in Indian Country. The agency has announced that they are seeking comments regarding the Advance Notice of Proposed Rulemaking »
On March 25, 2014 the U.S. Environmental Protection Agency (EPA) and U.S. Army Corps of Engineers (Army Corps) jointly released a proposed rule to clarify protection under the Clean Water Act for streams and wetlands that form the foundation of the »
On September 11, 2013, EPA proposed amending greenhouse gas (GHG) reporting and recordkeeping requirements under 40 CFR Part 98. Due to the public's concern of sensitive data being released, EPA deferred the reporting deadline for inputs to »
Mr. Lowther works at Trinity Consultants' operation in Tulsa, Oklahoma. He has over 24 years of experience in environmental compliance and consulting including regulatory compliance audits, construction and operating permitting, wastewater and »
Mr. Townley is a Senior Consultant in Trinity's Oklahoma City office. His experience includes assisting clients with air permit applications, environmental compliance analyses, emissions calculations, and air dispersion modeling. Mr. Townley has »
The Oklahoma Water Resources Board, working in partnership with the US Army Corps of Engineers under their Planning Assistance to States program, held a series of public meetings to share information and obtain feedback on water conservation »
On April 15, 2014, the U.S. Environmental Protection Agency (EPA) released five technical white papers covering what it considers to be potentially significant sources of emissions in the oil and gas industry. The white papers focus on technical »
Ms. Thompson serves as a consultant in Trinity's Oklahoma City office and specializes in air dispersion modeling, permitting, regulatory compliance reporting, and emissions inventorying, including GHG inventories. Ms. Thompson graduated with B.S. »
For the engine rules, especially RICE MACT (40 CFR 63 Subpart ZZZZ), it has been one deadline after another for the last several months - plan development, testing, notifications, and reports. Throughout this time Trinity has worked on behalf of »
DALLAS - On February 10, 2014 the U.S. Environmental Protection Agency (EPA) announced the approval of Oklahoma's state clean-air plan to control regional haze from the Public Service Company of Oklahoma (PSO) two coal-fired power plants at its »
Four Oklahoma Tribes will have the funds to better address air pollution thanks to $847,097 in assistance grants from the U.S. Environmental Protection Agency. These funds will help provide assistance to monitor air quality on Tribal lands. The »
Bryan Research & Engineering, Inc. will be conducting a free three day training course in Tulsa, OK on May 6, 7, and 8th. The ProMax Level 2 courses are designed to provide a deeper understanding of how to model specific types of processes in »
Remember that the data reporting deadline for 40 CFR Part 98 is March 31, 2014 and e-GGRT 2013 GHG Reporting is now open. The new Global Warming Potentials must be used for the 2014 reporting deadline (2013 reporting year). For 2013 GHG Reporters, »
EPA intends by October to propose new regulations to curb ozone pollution that crosses state lines in the East, according to a schedule posted on the agency's website. The rule would replace parts of the Cross-State Air Pollution Rule, which a »
The U.S. Environmental Protection Agency (EPA) has agreed to issue a final rule by Dec. 19 for managing ash from coal-fired power plants (Appalachian Voices vs. McCarthy, D.D.C, No. 1:12-cv-00523, consent decree filed 1/29/14). A consent decree »
On December 9, 2013 OSHA issued a Request for Information (RFI) on the Process Safety Management (PSM) standard and related standards. This RFI was driven by Executive Order 13650, issued August 1, 2013, which required an RFI within 90 days for »
DALLAS - (Feb. 6, 2014) The U.S. Environmental Protection Agency's Toxic Release Inventory (TRI) data is now available for the reporting year of 2012. This annual report provides citizens with critical information about their communities, including »
Mr. Cordell works at Trinity Consultants' office in Tulsa, Oklahoma. He has over 6 years of experience in environmental compliance and consulting including regulatory compliance audits, construction and operating permitting, compliance reporting and »
Signed in 2012, the Hazardous Waste Electronic Manifest Establishment Act authorized EPA to implement a national electronic manifest system for waste handlers to complete, sign, transmit, and store manifest information electronically. Trinity »
On January 8, 2014, the United States Environmental Protection Agency (USEPA) proposed New Source Performance Standards (NSPS) for emissions of greenhouse gases (GHG) from new fossil fuel fired electric generation unites (EGU) and withdrew the »
Important compliance deadlines under the Area Source Boiler National Emission Standards for Hazardous Air Pollutants (NESHAP), promulgated under 40 CFR 63, Subpart JJJJJJ, are rapidly approaching. For existing boilers subject to the provisions under »
On January 17, 2014, the U.S. Court of Appeals for the District of Columbia Circuit unanimously ruled that the U.S. Environmental Protection Agency's (EPA) June 2011 Indian Country New Source Review (NSR) rule exceeded the agency's Clean Air Act »
The Oklahoma Department of Environmental Quality (DEQ) Air Quality Division (AQD) has posted online a PowerPoint on Emission Inventories. The presentations provide general instruction and address general issues and new reporting guidance. The »
The Oklahoma Department of Environmental Quality (DEQ) Air Quality Division (AQD) will be accepting comments and hearing requests until noon on Wednesday, February 19, 2014 on the proposed certification that Oklahoma has adequate resources and »
The Supreme Court is currently reviewing the GHG Regulations in the Utility Air Regulatory Group v. Environmental Protection Agency (EPA) case No. 12-1146. After receiving six (6) petitions, they limited their scope to a single question in all »
If your facility has a stationary engine controlled by a catalyst, then it is likely that EPA's RICE MACT (40 CFR Part 63, Subpart ZZZZ) requires you to develop and follow a site-specific monitoring plan describing your monitoring of the catalyst. »
On July 12, 2013 the Third Circuit Court of Appeals upheld a Clean Air Act (CAA) Section 126(b) finding by EPA against a Pennsylvania power plant on the New Jersey border. EPA used air dispersion modeling analyses in setting 1-hour SO2 emission »
As part of our continuing efforts to improve the services provided to our clients, Trinity Consultants has acquired a GF320 FLIR camera for visual observation of fugitive equipment leaks for leak detection and repair (LDAR) and non-LDAR facilities. »
This new type of air permit became effective on September 10 when the implementing emergency rule was signed by the Governor. Advantages of the new permit include the following:Shorter, streamlined, application processLower application fees when »
On September 6, 2013, the U.S. Environmental Protection Agency(EPA) published in the Federal Register a proposal requiring certain changes to the Oklahoma DEQ Air Quality Rules. The proposal specifically concerns Subchapter 9 for Excess Emissions »
This new type of air permit became effective on September 10 when the implementing emergency rule was signed by the Governor. Advantages of the new permit include the following: Shorter, streamlined, application processLower application fees when »
Environmental Federation of Oklahoma (EFO) EFO is a voice for Oklahoma Industry on environmental issues. Their website contains information on the status of Legislative Actions, membership, and other topics. For more information, visit their website »
Lesser Known Risk in Asset Acquisition - Understanding Liabilities Beyond a Phase I Assessment Luncheon SeminarJune 12, 2013 | 11:00 am - 1:00 pm CDT |TulsaJune 13, 2013 | 11:00 am - 1:00 pm CDT |OKCTrinity Consultants understands the unique »
Annual Emission Inventories Due April 1st All Oklahoma facilities with any type of air permit are required to report actual air emissions to DEQ each year. The preferred procedure is to use DEQ's "Redbud" on-line system for this report. Each »
Oil & Gas Area EmissionsCenSARA (Central States Air Resources Agencies) is a non-profit organization formed to assist its member states (Arkansas, Iowa, Kansas, Louisiana, Missouri, Nebraska, Oklahoma and Texas) to gain a better understanding of »
Environmental Federation of Oklahoma (EFO)EFO is a voice for Oklahoma Industry on environmental issues. Their website contains information on the status of Legislative Actions, membership, and other topics. Note the annual EFO Legislative Reception »
All Oklahoma facilities with any type of air permit are required to report actual air emissions to DEQ each year. The preferred procedure is to use DEQ's "Redbud" on-line system for this report. Each company's Responsible Official (RO) should have »
One of the ways that EPA reports the environmental status of each state is through Enforcement & Compliance History Online (ECHO). ECHO allows anyone with access to the Internet to find permit, inspection, violation, enforcement action, and penalty »
EFO is a voice for Oklahoma Industry on environmental issues. EFO website contains information on the status of Legislative Actions, membership, and other topics. Note a 1-day workshop on Threatened & Endangered Species in Oklahoma to be given in »
EPA is taking two separate direct final actions to revise the definition of volatile organic compounds (VOCs) for purposes of preparing state implementation plans (SIPs) to attain the national ambient air quality standards (NAAQS) for ozone under »
On January 30, 2013, EPA published direct final rules for reciprocating internal combustion engines. There are significant changes with the key highlights as follows. Click here to link to the rule. Link to article with more information by »
On February 12, 2013, EPA proposed a rule that would ensure that States have plans in place to address air emissions during SSM. Link to the website and Fact sheet which lists the states believed by the EPA to be in compliance (including Oklahoma).
The extended time for farms to comply with Spill Prevention, Control, and Countermeasure (SPCC) Plan requirements is just about up! An October 2011 rulemaking by the U.S. Environmental Protection Agency set May 10, 2013 as the deadline for farms to »
EPA published a direct final rule changing the Best Available Monitoring Methods (BAMM) deadline requirements for those seeking BAMM extensions. The original rule required operators to submit BAMM extension requests no later than September 20th »
EPA released "120-Day" designation letters on Thursday, February 7th, to states with areas that will be classified as "nonattainment" for the 1-hour sulfur dioxide (SO2) standard. EPA has proposed to designate 30 areas of the country as »
The following environmental regulatory actions were published in the U.S. Federal Register during January 2013. Select the hyperlink to view the complete Federal Register notice. For assistance in determining how any of these issues may affect your »
On May 31, 2013, DEQ Air Quality Division sent a letter to EPA containing early action measures planned to reduce ozone pollution in the OKC Metro area. While the OKC MSA is currently designated as an attainment area, the 2012 monitored data »
The next meeting will be held at the DEQ offices in OKC on July 17. The main action items and announcements are as follows. Link to details and the DEQ agenda for future meetings by clicking here.Subchapter 5: The proposal will adjust the Annual »
EPA's latest amendments to NESHAP Subpart ZZZZ published January 30, 2013, created a new category for engines in remote locations which meet either of the following criteria:On a pipeline segment that meets both criteria below:A pipeline segment »
For Compression Ignited (diesel) engines, the date is May 3, 2013, and for Spark Ignited engines the date is October 19, 2013. Nearly all of these engines will at least have recordkeeping requirements. Under Oklahoma DEQ air rules, existing »
On April 2, 2013, EPA published a proposal to amend the global warming potentials (GWPs) of some greenhouse gases (GHGs) and to add GWPs for certain fluorinated GHGs in Table A-1 of 40 CFR Part 98 Subpart A, more commonly known as the GHG »
EFO is a voice for Oklahoma Industry on environmental issues. Their website contains information on the status of Legislative Actions, membership, and their topics. Clickherefor more information.
Some companies may be unaware that the Oklahoma Corporation Commission (OCC) Petroleum Storage Tank Division has requirements for certain liquid fuel tanks. These requirements include registration, recodkeeping, and reporting to OCC for tanks above »
EPA Office of Air Quality Planning & Standards (OAQPS) issued an internal memorandum to the Regional Directors on December 21, 2012 in response to the 6th Circuit Court of Appeals' ruling in the recent Summit Petroleum case. In the case, the Court »
The newly amended Chemical Manufacturing Area Source (CMAS) Rule, 40 CFR Part 63, Subpart VVVVVV, addresses several reconsideration requests, including the requirement for facilities with subject Chemical Manufacturing Process Units (CMPUs) to »
On December 21, 2012, in response to a request by the House of Representatives, EPA issued an interim report on the environmental impact of the fracking process on water resources, specifically: Water Acquisition, Chemical Mixing, Well Injection, »
On Dec. 14, 2012, EPA promulgated a revision to the annual National Ambient Air Quality Standards (NAAQS) for particulate matter (PM). This resulted in the following standards:Annual standard for PM2.5 decreased from 15 to 12 µg/m3 24-hour standard »
On November 30, 2012, EPA published final new rules in the Federal Register. These rules are an update of the "Utility MACT" final rules published on February 16, 2012. In this change EPA is announcing revisions of the following:Certain new source »
On December 20, 2012, EPA issued a suite of new final combustion rules: the Boiler MACT rules (for major and area sources), the CISWI standards, and the Portland Cement MACT. These rules have not yet been published in the Federal Register.Trinity is »
The Air & Waste Management Association lunchtime meeting schedule and scholarship, membership, and other information is available on their website.
As usual, DEQ's Air Quality Division will provide a workshop opportunity for permit holders to hear about changes and improvements to the reporting process, to review QC procedures and avoid common errors, to view training in Redbud (Oklahoma's »
Air Quality Division has announced that the next meeting has held at the DEQ office in OKC on January 16, 2013. Consideration and possible action was scheduled as follows. Link to details and DEQ agenda can be found here.Subchapter 7: The main item »
Effective March 1, 2012, the Air Quality Division's penalty guidance has been updated. It is used by enforcement personnel in the AQD to assist in determining if an administrative penalty is justified for an air quality violation and in determining »
DEQ has extended the due date for the annual air emissions inventory report from April 1, 2012 until April 16, 2012. This extension is caused by technical issues with the on-line Redbud reporting system.
On March 1st, the DEQ will implement the air permit application fee increases in OAC 252:100-7-3 and 252: 100-8-1.7 that were adopted as permanent rules in 2011. The Department delayed implementation of the new fees pending an evaluation of the »
The Air Quality Advisory Council met Wednesday, January 18, at the DEQ - OKC office. The following items were considered, passed, and recommended for approval by the February Environmental Quality Board.Subchapter 1 - incorporation of EPA's recent »
The Air Quality Advisory Council met Wednesday, October 5, at the DEQ - OKC office. The following items were considered:Subchapters 1 and 8 - update definitions of and regulations for carbon dioxide (CO2) emissions.Subchapter 8 changes were passed, »
The DEQ website contains a new Form 100-611 adopted July 6, 2011. All facilities subject to federal fugitive emission rules (including but not limited to NSPS Subparts VV, VVa, and KKK; NESHAP Subpart V; MACT Subparts H, HH, and MACT CC; or the CAR) »
The DEQ website contains revised instructions and forms to apply for the GP for "Area Source NESHAP Small NSPS Facilities." Many of Trinity's clients have found that General Permits offer several advantages over "individual" permit when possible.- »
On September 2, 2011, President Obama announced that EPA would not be changing the National Ambient Air Quality Standard (NAAQS) for Ozone. EPA had previously proposed that the standard should be reduced from the current level of 0.075 ppm to »
Reminder that the initial notifications of applicability under this new rule are due to EPA and/or your state agency by September 17. Trinity has a form that can be used for this notification.
On August 19, 2011, the U.S. Environmental Protection Agency (EPA) signed a final action to amend Subpart W. The revisions would correct technical and editorial errors and address issues identified as a result of working with trade associations and »
The Air Quality Advisory Council met Wednesday, July 20, at OSU-Tulsa. The next meeting of the Council is scheduled for Wednesday, October 5, at DEQ - OKC Offices. The following items were discussed at the July meeting but "carried over" to be »
The DEQ website contains a new version of DEQ Form 100-884. Dated July 30, 2010, that is required for most air permit applications.
Trinity recently confirmed the following guidance from the AQD Compliance / Enforcement Group on when and how such events should be reported. Keep in mind that DEQ still makes determinations for each facility on a case-by-case basis. Air Permits »
On July 6, 2011, the US Environmental Protection Agency (EPA) finalized the Cross-State Air Pollution Rule (CSAPR), requiring 27 states to reduce power plant emissions that contribute to ozone and/or fine particulateconcentrations in other states. »
On June 13, 2011, EPA finalized new rules for "Review of New Sources and Modifications in Indian Country" intending to ensure that Clean Air Act permitting requirements are applied consistently to facilities in Indian country. The rules establish »
On July 20, 2011, EPA published and made effective final rules that defer, for a period of three years, the application of Prevention of Significant Deterioration (PSD) and Title V permitting requirements to carbon dioxide (CO2) emissions from »
On July 19, 2011 the EPA signed a proposed rule to make several changes to 40 CFR Part 98, Subpart W, first of which is to extend the reporting deadline from March 31, 2012 to September 28, 2012. Note that reporting under subpart C is still required »
On July 28, 2011, EPA signed a suite of proposed rule changes affecting the oil and gas industry. Proposed are changes to the following existing Subparts: NSPS KKK, NSPS LLL, MACT HH, and MACT HHH. The proposed changes would also create a new NSPS »
Sierra Club has conducted dispersion modeling and claims that certain sources within Oklahoma are causing violations of the one-hour SO2 NAAQS. Within its recent comment letter in response to EPA’s partial approval and partial disapproval of »
The meeting of the Air Quality Advisory Council scheduled for Wednesday, April 20, in Tulsa has been canceled. The next meeting of the Council is scheduled for Wednesday, July 20, at OSU-Tulsa. The following items were discussed at the previous »
On December 23, 2010, the U.S. Environmental Protection Agency (EPA) stated its intention to regulate emissions of greenhouse gases (GHG) using New Source Performance Standards (NSPS) (40 CFR Part 60). This action is the result of consent decrees »
For those industries that were required to begin monitoring and collecting data in CY2010, the date for reporting that data has been extended from March 31 until September 30, 2011. EPA is now offering free web–based training sessions to provide »
The meeting of the Air Quality Advisory Council scheduled for Wednesday, April 20, in Tulsa has been canceled. The next meeting of the Air Quality Advisory Council is scheduled for Wednesday, July 20, at OSU-Tulsa. The following items were discussed »
A copy of the presentation material and handouts has been posted to the DEQ website.