Air Quality Compliance

Our approach to compliance evaluations starts with objectively assessing a facility’s compliance program. Trihydro has completed compliance evaluations at over 100 industrial and government facilities involving dozens of CAA regulations. Through past experience, our experts bring both the regulator and operator perspectives to projects and use this awareness to develop optimal compliance strategies. Trihydro is also an industry leader in program auditing and third-party evaluations. Often, our compliance evaluations result in compliance plans and manuals that include regulatory compliance determinations, emissions inventories, inspection lists and requirements, monitoring requirements, and tools to enable compliance with records retention and reporting. We can also set up compliance tracking systems to simplify quarterly, semiannual, and annual reporting requirements, and can audit programs to confirm compliance with regulatory obligations.

We offer comprehensive air quality compliance and auditing services, including:

• Title V and New Source Review (NSR) permit compliance
• State-level Emission Inventories
• Toxic Substances Control Act (TSCA) reporting
• Toxics Release Inventory (TRI) reporting
• Leak Detection and Repair (LDAR) auditing
• New Source Performance Standards (NSPS) Subpart QQQ compliance
• National Emission Standards for Hazardous Air Pollutants (NESHAP) compliance (Subparts V, Y, FF)
• Benzene Waste Operations NESHAP (BWON) compliance, sampling, monitoring, and reporting
• Total Annual Benzene (TAB) reporting
• Maximum Achievable Control Technology (MACT) compliance (Subparts CC, DD, FFFF, GGGGG, BBBBBB, etc.)

Trihydro can assist with applicability reviews, monitoring plans, field support/data collection, and emissions calculations/reporting. From applicability determinations to GHG calculations, we work as an extension of your staff to keep you in compliance with this growing regulatory challenge. We specialize in implementing Subpart W of the MRR and can support you with:

• Optical gas imaging (OGI) surveys
• Compressor vent measurements
• Transmission storage tank monitoring
• Natural gas pneumatic population counts

Our GHG professionals specialize in the development of GHG inventories and data management plans to develop credible, transparent, and compliant GHG inventories. We have completed inventories for numerous clients under both voluntary and mandatory reporting scenarios at both the facility and corporate levels. Our GHG inventories follow applicable mandatory reporting and industry standard protocols. Trihydro has also prepared its own internal GHG inventory, which was subsequently third-party verified and voluntarily reported to The Climate Registry.

In addition to developing GHG inventories and data management plans, Trihydro’s GHG experience includes developing and implementing corporate sustainability strategies that focus on the triple bottom-line (economic, social, and environmental) impacts of current and potential future climate change regulations. Our corporate sustainability strategies build upon GHG data management plans and the results of corporate/ facility-wide GHG inventories.

The EPA's Refinery Sector Rule, implemented in 2018, requires refineries to monitor benzene emissions at their fencelines. Additionally, the Hazardous Organic NESHAP (HON) rule mandates fenceline monitoring for specific facilities, including the synthetic organic chemical manufacturing industry (SOCMI) and Group I & II Polymers and Resins.

Trihydro recognizes the complexities associated with navigating these evolving fenceline monitoring regulations. Building upon our extensive experience since the implementation of the 2018 Refinery Sector Rule, Trihydro offers comprehensive fenceline monitoring programs to efficiently guide you through the complexities. Our air experts provide support for your specific fenceline monitoring needs, including:

• Pilot Study Implementation
• Sample Station Siting
• Compliance Manual Development
• Field Data Collection
• Data Management, Analysis, and Reporting through Fenceline Pro^TM
• Laboratory Coordination
• Root Cause Analysis and Corrective Action Implementation

The team possesses the expertise to identify and address situations where leaks may be visually obscured, such as those with inadequate thermal backgrounds, adverse weather conditions, or interference. Through extensive training and practical experience, our team can detect leaks even in challenging conditions with minimal thermal contrast, including subsurface leaks. Accurate detection and detailed leak descriptions in complex environments are crucial, and our team's expertise ensures this level of precision.

OGI is increasingly becoming the preferred technology for demonstrating compliance with air pollution regulations, including the Best System of Emissions Reduction (BSER) as outlined in NSPS OOOOb. This preference stems from OGI technology's ability to facilitate faster, more accurate leak detection, streamlining the monitoring process by eliminating the need for calibration and minimizing downtime. OGI also offers a superior approach compared to traditional methods. It enables component-level identification, ensuring no leaks go unnoticed, even in challenging locations. Furthermore, OGI allows for the inspection of unregulated components such as flares, vents, and pneumatic controllers.

By leveraging OGI technology, Trihydro's experts collaborate to develop comprehensive inspection and repair strategies that optimize costs, enhance safety, and ensure regulatory compliance.

• Greenhouse gas (GHG) Subpart W surveys
• New Source Performance Standards (NSPS) OOOOa, OOOOb, and OOOOc surveys
• BWON no detectable emissions (NDE) equipment surveys
• State regulatory surveys
• Voluntary emissions reduction surveys
• Preemptive facility startup surveys
• Health & safety-based surveys (toxics, H2S & LEL)
• Internal facility or equipment audit surveys
• Facility turnaround startup monitoring
• Custom surveys to meet requirements of Consent Orders or Decrees
• Flare or combustor destruction efficiency monitoring

Our LDAR team has the regulatory knowledge and technical expertise to help you implement a comprehensive LDAR program that fits your facility goals. Trihydro has provided LDAR compliance support to hundreds of facilities, including renewable fuel plants, refineries, natural gas plants, chemical facilities, and pharmaceutical plants. Trihydro is experienced at preparing auditing plans for “inspector-proof” LDAR programs required under New Source Review (NSR) Consent Decrees and federal and state regulatory programs. We are well-versed in New Source Performance Standards (NSPS) Subpart VV, VVa, GGG, and GGGa requirements, including various Maximum Achievable Control Technology Standards (MACT) and National Emission Standards for Hazardous Air Pollutant (NESHAP) regulations. Trihydro can provide records and database reviews, Method 21 compliance observations, and comparative and shadow monitoring. Third-party LDAR audits and reviews can be scheduled to meet specific regulatory needs and are tailored to meet facility program goals.

Our LDAR services include:

• Program implementation, tagging, and inventory
• Routine program monitoring and management
• Database management
• Recordkeeping and reporting
• 3rd party LDAR compliance auditing
• Site specific and general LDAR program training
• 3rd party LDAR database quality assurance and quality control support
• LDAR coordinator transition support