NESHAP/NSPS Evaluations & Compliance
Permitting (State and USEPA)
Air Quality Training
GHG Evaluations & Compliance
Compliance Tracking & Planning
Method 9 Visible Emissions Monitoring
Risk Management Plans
» Read More
Our team of air quality specialists has over 80 years’ cumulative experience in providing air quality services for multiple industries including oil and gas (production, midstream, storage, and processing), foundries, rock quarries, manufacturing facilities and coating facilities. Our team’s air quality experience encompasses many states Including Oklahoma, Texas, Kansas, Wyoming, North Dakota, Tennessee, Kentucky, Indiana, Illinois, Wisconsin, and Minnesota.
Often the first step in air quality is the performance of air quality applicability determinations (ADs). We perform ADs to determine the applicability of State and Federal regulations based upon the industry category, air emission sources, and air emission quantities. In the event the AD determines the facility is not subject to air quality regulations then the AD can be placed in the client’s files as a documentation resource in the event of a regulatory agency inspection.
There are over 100 NESHAP regulations ranging from Subpart A (1A) to HHHHHHH (7H) and over 100 NSPS regulations ranging from Subpart A (1A) to UUUU (4U). Our team is knowledgeable and experienced in the identification of applicable NESHAP/NSPS regulations and how they impact an affected air emission source. In association with these regulations we can develop compliance plans, operations and maintenance plans, coordinate performance testing, prepare and submit routine reports to applicable regulatory agencies; conduct visible emissions observations, and provide training.
Depending upon a facility’s industrial category, air emission source types, and air emission quantities an air quality construction and/or operating permit may be required. We are experienced in evaluating and determining the appropriate air quality permit category that accommodates a facility’s existing status and allows for future planned growth and expansion. Whether it be a NESHAP/NSPS general permit, common general permit, permit by rule, synthetic minor permit, or major source permit we are qualified and efficient in the preparation and implementation of all types of air permit applications.
Once a facility has obtained an air permit, they are typically required to report air emissions annually. Our team is experienced and efficient in the preparation and submittal of air emission reports in multiple states. We make every effort to simplify this task for or clients by maintaining air emissions tracking sheets and facility information records containing information routinely needed to complete such reports.
We can help you evaluate the applicability of GHG regulations and the annual reporting rule for facilities emitting greater than 25,000 metric tons of carbon dioxide equivalent. Our team is also experienced in the implementation of the GHG regulations and can assist with the preparation and submittal of annual reports.
A & M can also prepare Risk Management Plans (RMP) in accordance with 40 CFR, Part 68, Subpart G including hazard assessments, offsite consequence analysis, release scenario analyses, release prevention procedures, and all other required components.
It is not uncommon for a permitted facility to overlook the need for air quality training and compliance plans. Both can significantly improve awareness among operations and EHS Managers and assist with overall compliance with the air permit conditions. We can provide on-site air quality training to assist with air permit conditions awareness and implementation. Our team is also adept in the development of air quality compliance plans that streamline the air permit conditions in an easy to read, easy to understand, quick reference format. With our air quality team on your side you can achieve and maintain compliance with applicable air quality regulations in an efficient and cost-effective manner.
Storm Water (SWP3)
Construction Storm Water Permits & SWP3s
Industrial Storm Water Permits & SWP3s
General Storm Water Permits & SWP3s
Storm Water Sampling
Storm Water Reporting
Storm Water Training
» Read More
Our compliance team is comprised of environmental specialists with specific experience in storm water regulatory compliance involving construction projects, industrial facilities, foundries, rock quarries, redi-mix concrete plants, natural gas processing plants, landfills, soil borrow pits, and a bulk crude oil storage terminal. Our environmental specialists are knowledgeable and experienced in construction storm water regulations in Oklahoma, Tennessee, Kentucky, Indiana, Illinois, Wisconsin, and Minnesota. We are also knowledgeable and experienced in USEPA industrial storm water regulations and those industrial storm water regulations imposed in the states of Oklahoma, Texas, Arkansas, Wyoming, and North Dakota. We have extensive experience in the implementation of OKR05, OKR10, and OKG11 in Oklahoma.
Construction projects that disturb equal to or greater than one (1) acre of land are required to obtain a construction storm water permit and develop/implement a storm water pollution prevention plan (SWP3). We can prepare and submit NOI permit application forms, design storm water runoff control features, designate BMPs and ECDs, prepare and implement the SWP3, and conduct routine construction site inspections.
Industrial facilities operating within designated industry categories are required to obtain an industrial or general storm water permit and develop/implement a SWP3. Our environmental specialists will visit your facility to identify potential storm water pollutant sources, evaluate runoff characteristics, and designate outfall locations. Based upon that information we can prepare and submit NOI application forms; prepare SWP3s; and perform routine industrial facility inspections.
Often visual observation and physical sampling of storm water is required by the storm water permit. We have on staff trained individuals that can perform both visual observations and physical sampling of storm water for laboratory analyses within the Tulsa, Oklahoma vicinity. In some scenarios a facility may have too many outfalls for a single individual to cover within the first 30 minutes of runoff. In such scenarios it helps to have additional support. Furthermore, it is not uncommon for a permit to require the discharger to perform field measurements during storm water sampling events. Many of our staff professionals are trained and certified for field measurement of pH and Dissolved Oxygen.
Storm water training is an important element of any SWP3 implementation. Such training is typically in particular regard to the storm water pollution prevention team (SWPPT) and contractors. We can provide such training either onsite or offsite to ensure that SWPPT properly implement the SWP3 and understand the BMPs and ECDs.
Spill Prevention Planning (SPCC)
AST Inspection & Integrity Testing Programs
Flowline Maintenance Programs
Facility Response Plans
» Read More
Our environmental specialists and engineers have extensive experience in the development of spill, prevention, control, and countermeasure (SPCC) plans and support programs including those for inspections, integrity, flowline maintenance, and contingency. Our staff of professionals includes an environmental specialist with over 223 years of related experience that previously served as the SPCC subject matter expert for a major natural gas transmission company. Our team’s related experience Includes implementation of the federal regulation (40 CFR Part 112) in many states including Oklahoma, Texas, Louisiana, Kansas, Missouri, Arkansas, Wyoming, North Dakota, Tennessee, Kentucky, Indiana, Illinois, Wisconsin, and Minnesota.
We are adept in the development and implementation of SPCC Plans in accordance with 40 CFR, Part 112 for both onshore facilities excluding production facilities (40 CFR, Part 112, Subpart 112.8) and onshore oil production facilities excluding drilling and workover facilities (40 CFR, Part 112, Subpart 112.9). Members of our team have developed hundreds of SPCC Plans for various industries including oil and gas production and transmission, natural gas processing, general manufacturing, aerospace foundries, automotive, landfills, food processing, construction, drilling mud processing, electric utilities, and a bulk crude oil storage terminal.
We understand the proper classification of bulk storage containers, oil-filled operating equipment, oil-filled manufacturing equipment, and flow through process vessels. Our team is proficient in the development of oil spill contingency plans, passive measures, active measures, sized secondary containment, and general secondary containment and is experienced in their proper implementation and use.
Our SPCC Plans are formatted in accordance with the regulatory requirements in an easy to follow structure. They include regulatory citations for easy reference and are equipped with the required capacity calculations, emergency procedures, and forms. Easy to use forms include those required for the documentation of amendments, reviews, inspections, secondary containment precipitation discharges, spills and releases, and spill reporting.
We also develop aboveground storage tank (AST) inspection and integrity programs and flowline maintenance programs. These programs are developed in accordance with industry standards to ensure compliance with 40 CFR, Part 112, Subpart 112.8 and 112.9, as appropriate. They include standard procedures for the proper inspection, maintenance, testing, and repair or replacement of ASTs (non-oil production facilities) and flowlines (oil production facilities). These programs are typically prepared in a general format that can be implemented system, asset, or company-wide.
Our team is experienced in evaluation of the substantial harm criteria for all types of facilities and the development of facility response plans (FRP) for a bulk crude oil storage terminal. In accordance with 40 CFR, Part 112, Appendix C, Section 2.0, a facility that has the potential to cause substantial harm to the environment in the event of a discharge must prepare and submit a FRP to the USEPA. We develop FRPs that are specific to the facility and include all required components in an easy to read and implement format supported by a regulatory cross reference table to simplify USEPA compliance reviews.
An important aspect to the proper and successful implementation of a SPCC Plan, companion programs, and FRPs is employee training. Our environmental specialists provide SPCC training either on-site or in a classroom setting. Training typically includes a review of the SPCC Plan, companion programs, and/or FRP contents; proper operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; discharge prevention briefing; and spill response procedures. Field exercises and emergency response materials deployment exercises may also be performed. At the completion of training a copy of the attendee sign-in sheet and training materials is provided to the client for documentation. If you are looking for practical and affordable SPCC related solutions, please contact A & M. We would be glad to help you out.