Understanding and Meeting Industry Regulation

At TRC, we’re committed to helping our clients update facility-wide policies and programs to meet industry-specific regulatory compliance standards. It is important to work with experts who understand the complex obligations and requirements of the Federal Energy Regulatory Commission (FERC) and North American Electric Reliability Corporation (NERC). We ensure our clients have the tools to keep their facilities and projects updated to compliance standards from audit preparation to systems compliance.

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Our Regulatory Compliance Services

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Federal Energy Regulatory Commission (FERC)

We help you understand and meet FERC regulatory obligations, so your projects get approved and stay on track.

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NERC

Solutions from standards requirement tracking to audit preparation and compliance program improvements.

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PHMSA Regulatory Consulting

Industry recognized pipeline regulatory and compliance expertise via our team of former pipeline transmission and distribution operators, PHMSA senior regulators …

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TRC’s PHMSA Reporting Services

The Pipeline and Hazardous Materials Safety Administration (PHMSA) mandates annual and incident-specific reporting from operators of pipelines, gas distribution systems, …

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Regulatory and Environmental Consulting

TRC is responsive to the complete range of EHS&S service requirements throughout the life cycle of your project.

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Cultural Resources Management

TRC works with a broad range of private and public sector clients to identify and address vital cultural resource concerns.

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Environmental Assessments

We collaborate with you to provide comprehensive environmental studies that achieve projects’ goals and comply with federal, state and local …

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Biological Assessment

Working with clients to solve environmental challenges, including preserving and restoring sensitive habitats and vegetation.

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Endangered Species

Collecting data on endangered species and critical habitat concerns for our energy, infrastructure and industrial market clients.

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Environmental Monitoring

TRC provides sound strategies and proven techniques to characterize and measure baseline conditions and ecological change in both aquatic and …

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Environmental Site Assessment

Reviewing current and historical information to evaluate the environmental risk of acquiring, leasing or divesting of property to support.

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Risk Assessment and Toxicology

Technical analysis of potential for risk to aid in site decision making and closure, and toxicology review of chemicals used …

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Compliance Training

We provide technical training to ensure that your staff is equipped to monitor and maintain compliance.

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Environmental Compliance

Stay compliant with all regulations, as well as evolving corporate EHS expectations.

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Environmental Assessments

We collaborate with you to provide comprehensive environmental studies that achieve project goals.

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Occupational Exposure Assessments

TRC’s industrial hygienists help clients manage workplace risks and contain costs associated with exposures.

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Regulatory Compliance

Stay compliant with all the constant changing in international, national and regional/local regulations.

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Sharing Our Perspectives

Our practitioners share their insights and perspectives on the trends and challenges shaping the market.

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Regulatory Updates

PM2.5 Annual NAAQS Revised

May 7, 2024

The U.S. EPA issued a final rule based on its reconsideration of its 2020 decision to retain the primary and secondary National Ambient Air Quality Standards (NAAQS) for particulate matter (PM) without revision.

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Regulatory Updates

NJDEP Issues Stormwater Management Updates and Amendments

April 12, 2024

The New Jersey Department of Environmental Protection (NJDEP) recently issued two new requirements pertaining to its New Jersey Pollutant Discharge Elimination System (NJPDES) program that affect municipality mapping requirements and the sizing of new stormwater management practices.

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Regulatory Updates

Changes to EPA’s Risk Management Program (RMP) Regulations Are Here

April 3, 2024

Changes to the Risk Management Program (RMP) regulations were signed into a final rule on February 27, 2024, by EPA Administrator Michael S. Regan.

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Regulatory Updates

Are You Prepared for 2024 TSCA Chemical Data Reporting?

October 9, 2023

Chemical Data Reporting (CDR), like the Olympics, occurs every four years, and then most facilities move on to more pressing environmental, health and safety (EHS) matters.

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Insights

Intro to NERC Regulatory Guidance on Inverter-Based Resources

August 29, 2023

As renewable energy proliferates across the US power system, the North American Electric Reliability Corporation (NERC) continues to actively address reliability risks resulting from the implementation of inverter-based resources (solar and wind generation technology) connected at both transmission and Distributed Energy Resources (DER) levels.

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Insights

Proposed Use of a Hazard Index for PFAS National Primary Drinking Water Regulation (NPDWR)

April 4, 2023

The Proposed MCL and MCLG for the four PFAS, PFNA, PFHxS, GenX, and PFBS, considers their toxicity as additive. The EPA has proposed a HI of 1.0 as the MCL and MCLG for the four PFAS combined.

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Insights

Setting the Stage for Effective Environmental Compliance Recordkeeping

March 21, 2023

Recordkeeping is an integral component of demonstrating compliance with environmental regulations.

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Insights

Equipment Decontamination and Replacement of Legacy Aqueous Film Forming Foams

December 21, 2022

Legacy AFFF used for firefighting are a significant source of PFAS in the environment. With current and expected regulation, many entities are looking for replacements.

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Insights

Preparing Your RMP Facility for a Future of Extreme Weather

November 29, 2022

Facilities dealing with hazardous materials must prepare for extreme weather events that pose a risk to their operations and the community.

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Regulatory Updates

NERC Releases Inverter-Based Resource Strategy Plan

October 25, 2022

The North American Electric Reliability Corporation (NERC) recently released an Inverter-Based Resource (IBR) Strategy, which details the steps needed to successfully integrate IBR facilities into the planning and operation of the power system. The strategy was put in place due to the rapid interconnection of IBR systems, which are extensively used for solar and wind generating facilities, including new battery-based energy storage systems and are one of the most significant drivers of power grid transformation. Because of control system inconsistencies, IBR facilities pose well-documented risks to power system reliability when this strategy’s practices are not adhered to. NERC’s plan calls attention to the need for thoughtful integration of IBRs and identifies current and future work required to mitigate reliability risks resulting from the deployment of this technology.

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Regulatory Updates

NERC Releases 2022 State of Reliability Report

September 16, 2022

The North American Electric Reliability Corporation (NERC) recently released its 2022 State of Reliability report, which examines power system performance in calendar year 2021 and evaluates reliability performance trends. The 2022 report identified six key findings regarding power system performance that are summarized as follows:

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Regulatory Updates

NERC Proposes Implementation Guidance for PRC-019-2

August 22, 2022

NERC has proposed implementation guidance for PRC-019-2, the standard that verifies coordination of generating unit facility or synchronous condenser voltage regulating controls, limit functions, equipment capabilities and protection system settings.

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Insights

Regulatory Compliance Items to Consider as Part of Transactional Due Diligence

July 19, 2022

Performing a limited environmental regulatory review can identify potential deficiencies with the environmental management of an acquisition.

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Regulatory Updates

Revisions to FAC-001 and FAC-002 Submitted for FERC Approval

July 12, 2022

Reliability Standards FAC-001-4 and FAC-002-will resolve uncertainty regarding the meaning of “materially modify” under the currently effective standards.

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Regulatory Updates

FERC Order No. 881-A Has Implications for NERC Compliance Programs

June 23, 2022

Updated Order will have significant impact on NERC compliance programs related to both PRC standards and facilities ratings. Utilities should review the Order’s requirements and prepare for changes needed to remain compliant.

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Insights

Climate Action and Environmental Justice are at the Forefront of EPA’s Strategic Plan

June 14, 2022

The EPA issued its Fiscal Year 2022-2026 Strategic Plan. Although the strategic plans emphases often change with administrations, we can be reasonably certain that the Plan reflects priorities through 2024.

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Regulatory Updates

NERC’s Revised PRC-024-3 Standard for Inverter-Based Generation Effective in October 2022

May 11, 2022

Changes to PRC-024-3 in support of inverter-based generation performance are going into effect in October of this year. Interconnection programs and documentation procedures may need to be updated in order to maintain compliance.

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Regulatory Updates

FERC Issues Notice of Inquiry Regarding Dynamic Line Ratings

April 25, 2022

There are significant technical challenges involved in implementing Dynamic Line Ratings in the planning and operation of utility systems. Utilities should be prepared to modify their NERC compliance programs as necessary to address the potential introduction of DLR in their businesses.

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Regulatory Updates

New NERC Guidance Supports the Implementation of Grid Forming Inverters

March 8, 2022

NERC has issued a new report highlighting the key attributes of various inverter controls to support proper implementation and to protect reliability.

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Regulatory Updates

NERC Recommends Approaches for Underfrequency Load Shedding Programs

February 24, 2022

In a recently released reliability guideline, NERC recommends additional approaches for Underfrequency Load Shedding (UFLS) program design to help utilities effectively consider the effects of Distributed Energy Resources (DERs). The guidance was developed to address the accelerated transition of the power system to locally installed, decarbonized resources that depend on inverters. These new technologies introduce operational controls issues into the electric grid. UFLS data gathering and analysis methodologies may require modification to address reliability risks.

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Regulatory Updates

NERC and FERC Recommend Protection System Commissioning Improvements

January 18, 2022

Between 18 and 36 percent of reported utility misoperations were attributed to issues that could have been detected through a properly implemented PSC.

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Regulatory Updates

FERC & NERC Issue Joint Report on Freeze Reliability Failures

December 15, 2021

The in-depth report outlines twenty-eight recommendations to address freeze reliability failures, including operating practices and recommendations for NERC standards modifications surrounding generator winterization and gas-electric coordination.

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Regulatory Updates

NERC Accelerates Additional Cold Weather Standards Changes

November 22, 2021

At its November 2021 meeting, NERC’s Board of Trustees took aggressive action to advance critical cold weather Reliability Standards. Most notably, the group approved the 2022-2024 Reliability Standards Development Plan, which prioritizes standards projects for the coming years including a resolution to include new cold weather operations, preparedness and coordination standards as high priority development projects.

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PRC-002-2 Disturbance Monitoring and Reporting Standard: Initial Mandatory Implementation Plan Dates Approach

November 18, 2021

The Federal Energy Regulatory Commission approved PRC-002-2 in September, 2015. The initial due date for system studies necessary to identify locations for the collection of disturbance related data under Requirement R1 is January 1, 2017.

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Insights

OSHA’s National Emphasis Program on Heat-Related Illness and Injuries

November 3, 2021

On September 20, 2021 in an OSHA National News Release, OSHA published a memorandum establishing an enforcement initiative that is designed to prevent and protect employees from heat-related illnesses and death. This initiative, which develops a National Emphasis Program (NEP) on heat inspections, is an expansion of an already existing Regional Emphasis Program (REP) in OSHA’s Region VI, which covers Arkansas, Louisiana, New Mexico, Oklahoma and Texas.

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Regulatory Updates

New Potential Compliance Standards Identified at FERC Technical Conference on Reliability

October 18, 2021

With a focus on the reliability impact of extreme weather and the shortcomings of current system planning approaches, both NERC and FERC conference participants opened the door to potential forthcoming compliance standard enhancements or changes.

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Regulatory Updates

NJDEP Implements New Jersey Environmental Justice Law Through Administrative Order

October 5, 2021

On September 22, 2021, the New Jersey Department of Environmental Protection (NJDEP) Commissioner announced the issuance of Administrative Order (AO) No. 2021-25 to implement New Jersey’s Environmental Justice (EJ) Law. This order is effective immediately, and applicants seeking to site new major source facilities, renew major source permits or expand existing facilities with major source permits (e.g., Title V air permits) in overburdened communities are affected. There are more than 4.5 million people that live within 331 municipalities that are overburdened communities in the state of New Jersey.

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Insights

OSHA Returns to In-Person Inspections As COVID-19 Restrictions Lift

August 4, 2021

The Occupational Safety and Health Administration (OSHA) is authorized by the Occupational Safety and Health Act of 1970 (OSH Act) to assure employers provide safe and healthful work conditions free of recognized hazards and by setting and enforcing standards and providing training, outreach, education and technical assistance. OSHA has recently announced the return to in-person inspections as COVID-19 restrictions begin to lift.

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News

TRC and T.D. Williamson Partner to Provide Safe, Innovative and Cost-Saving Services to Pipeline Operators

July 18, 2021

TRC is teaming with T.D. Williamson to help oil and gas clients navigate the compliance issues surrounding PHMSA’s upcoming Gas Mega Rule.

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Regulatory Updates

NERC Proposes Revisions to CIP-008

March 27, 2021

NERC’s CIP-008 standard aims to mitigate reliability risks resulting from a Cyber Security Incident by specifying incident response requirements. Newly proposed revisions would augment mandatory reporting to include incidents that compromise, or attempt to compromise, a utility’s Electronic Security Perimeter (ESP) or associated Electronic Access Control or Monitoring Systems (EACMS).

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Regulatory Updates

NERC Releases 2021 Compliance Monitoring and Enforcement Findings

February 8, 2021

NERC’s 2021 Compliance Monitoring and Enforcement Program reframes the previous year’s risks and their associated areas of focus. Utilities should review their compliance programs and internal controls to determine if enhancement or changes are need to maintain compliance.

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Regulatory Updates

2020 TSCA Chemical Data Reporting (CDR)

December 7, 2020

Earlier this year, EPA revised the CDR rule to reflect the 2016 amendments to TSCA, including changes for foreign-owned businesses and the reporting responsibilities of suppliers and contractors, as well as an exemption for small businesses.

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Insights

Integrity Dig Integrated Services

August 4, 2020

Our Integrity Engineers, Surveyors, Right-of-Way Experts and Environmental Scientists are well-versed in all phases of integrity dig programs from preparing the pipeline for a tool run, interpreting results, verifying proper repair procedures and obtaining federal and state environmental approvals. Our team includes former pipeline operators, survey experts, PHMSA and environmental regulators and trainers. We developed the current ILI training curriculum for PHMSA’s training program.

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News

INGAA Foundation Elects TRC’s Lauren O’Donnell as Chair

February 5, 2020

The board of directors of the INGAA Foundation elected Lauren O’Donnell as its chair for a one-year term.

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Insights

Targeting Perfection in the Construction and Operation of Pipelines

October 18, 2019

To have an impact on the delivery or operation of a pipeline, it’s vital to eliminate the intra- and inter-company barriers, including those in the areas of communications, culture and technology.

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Insights

How Much Does Operator Qualification Matter for In-Line Inspection of Pipelines?

October 9, 2019

Successful pipeline inspectors and analysts need more than just the right certifications. Even more important is proper experience and on-the-job training.

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Regulatory Updates

PHMSA Publishes New Rules to Increase the Safety of Hazardous Liquid Pipelines and Gas Transmission Pipelines

September 25, 2019

The Pipeline and Hazardous Materials Safety Administration this week published important new rules aimed at improving pipeline safety.

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Regulatory Updates

NERC Calls for New Approach to Reliability Planning Due to Gas Supply Disruption Risks

December 14, 2017

A recently published NERC report concludes that as reliance on natural gas to meet electric generation requirements increases, additional planning and operational measures must be considered to mitigate power system reliability risks.