Air Quality

Applicability Determinations
NESHAP/NSPS Evaluations & Compliance
Permitting (State and USEPA)
Emissions Reporting
Air Quality Training
GHG Evaluations & Compliance
Compliance Tracking & Planning
Method 9 Visible Emissions Monitoring
Risk Management Plans

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.

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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.

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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

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.

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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.

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Spill Prevention Planning (SPCC)

SPCC Plans
AST Inspection & Integrity Testing Programs
Flowline Maintenance Programs
Facility Response Plans
SPCC Training

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.

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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.

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Wastewater

Wastewater Treatment Systems Evaluation
System Troubleshooting
Treatment System Design
Troubleshooting Effluent Limitations Exceedance
Wastewater Permit Applications and Sampling

Our CIH/CSP has extensive experience in wastewater treatment systems evaluation, troubleshooting, and design. A & M can assist you with wastewater treatment systems on all levels including troubleshooting to evaluate causes for effluent limitations exceedances. We have a great working relationship with the City of Tulsa and other city wastewater programs. Our staff can provide wastewater sampling of various types including manual grab sampling, manual composite aliquot sampling, and 24-hour automated sampling. We are experienced in the preparation of wastewater permit applications and toxic organic management plans (TOMPs). We have several professionals on staff that are certified for field measurements of pH and dissolved oxygen (DO).

Waste

SQG & LQG Permitting
Waste Sampling & Characterization
Waste Management Plans
Waste Disposal Plans
Waste Training

Our environmental specialists and CIH/CSP are very qualified and knowledgeable in waste management including sampling, characterization, profiling, planning, and permitting.

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Appropriate handling, transport, and disposal/recycling of wastes begins with proper waste characterization, profiling, and permitting in accordance with local, state, and federal (RCRA) regulations. Our team can assist you with proper sampling and characterization  of waste streams in order to determine  hazard classification and appropriate disposal/recycling methods. We are  knowledgeable in the proper evaluation of used oil and implementation of the used oil exemptions. We understand the oil and gas production waste exemptions and are experienced in related waste evaluation and implementation. Profiling and planning for  waste is something we specialize in whether it be new waste streams, re-evaluations, or development of waste management plans (WMPs) or waste disposal plans (WDPs). Our professionals are familiar with the requirements for all sizes of generators (very small, small, and large). We are also experienced in the implementation of the recently promulgated hazardous waste generator improvements rule and can assist with waste permitting on all levels (VSQG, SQG, LQG, TSD).

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Health & Safety

Health & Safety Programs
Employee Exposure Monitoring
Job Hazard Analyses
Safety Training
Process Safety Management
Asbestos Abatement Project Design
Asbestos Abatement Oversight
Asbestos Third Party Air Monitoring

A & M has an experienced and qualified safety team including a CIH/CSP that has provided related services for multiple industries including construction, oil and natural gas, general manufacturing, and foundries. The key to a safe workplace is the development and implementation of health and safety programs. We are experienced in the development and implementation of many types of health and safety programs for multiple industries including:

  • Corporate health and safety programs.
  • Project specific health and safety plans (construction and general industry).
  • Hazard communication programs (including GHS).
  • Energy control and lockout tagout (LOTO) programs.
  • Arc flash programs.
  • Emergency action and fire prevention (EAFP) programs.
  • Hearing conservation programs.
  • Bloodborne pathogens programs.
  • Respiratory protection programs.
  • Confined space programs.

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Often a facility’s health and safety needs include employee exposure monitoring. Such monitoring provides absolute evaluation of employee exposure and documentation of the levels of airborne contaminants present in the workplace. Exposure monitoring results can be compared to regulatory exposure levels to determine whether additional controls or personal protective equipment (PPE) is needed. Our team is experienced in the monitoring of personnel for noise, silica, particulates, and many other airborne contaminants.

An employer’s evaluation of occupational exposure must include job hazard analyses. We can assist any facility or construction project with the evaluation of their job hazards. This is typically performed by observing employees performing their routine job tasks on a typical day. Based upon those observations the job hazards are identified, exposure controls evaluated, and proper PPE designated. Documentation of the job hazard analyses is provided on a standard form.

It is important to follow through with health and safety programs by providing safety training in order to ensure employees fully understand their job hazards and the programs, controls, and PPE implemented to limit their exposure and to protect them from injury. Our team can provide safety training either onsite or in a classroom setting for hazard communication (including GHS), confined space awareness, energy control and LOTO awareness, emergency action and fire prevention, heat stress, respiratory protection and PPE, hearing conservation, bloodborne pathogens, forklift safety, ladder safety, and many others. Once completed a training package complete with a cover letter, training materials, and quizzes is provided to the client for their documentation and records.

A & M can provide Process Safety Management (PSM) services for highly hazardous chemicals in accordance with 29 CFR, Part 1910.119, including initial process hazard analysis/hazard evaluation; process hazard analysis; PSM program development; and development of practices and procedures including safe work, management of change, etc.

A & M’s CIH/CSP has over twenty (20) years of experience in the asbestos industry including the development and implementation of asbestos abatement project designs, abatement oversight, and third party air monitoring during asbestos abatement. Such services have been provided for commercial entities, national banking institutions, and city municipalities. If you are dealing with asbestos issues please don’t hesitate to give our CIH/CSP a call.  

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Due Diligence & Inspections

Phase I Environmental Site Assessments
Phase II Environmental Site Assessments
Asbestos Inspections
LBP Inspections
Mold Inspections

A & M provides due diligence and inspection services backed by extensive experience and capabilities. Our team of Environmental Specialists has over fifty (50) years of combined experience in providing due diligence and inspection services for national banks, government agencies, Native American tribes, commercial real estate professionals, environmental law firms, general industry, oil and gas exploration and transmission, and many other sectors. We have performed due diligence, asbestos, lead based paint (LBP), and mold inspections for the decommissioning of a major Air Force base. Every transaction is different and we strive to meet our clients’ specific needs. Some of our due diligence and inspection services are listed below.

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Phase I Environmental Site Assessments (ESAs)

Our Phase I ESAs conform to the latest standard developed by the American Society for Testing and Materials (ASTM), E1527-13. In addition to Phase I ESAs, A & M offers less-intensive due diligence options such as Transaction Screen Assessments (TSA) and desktop reviews which can be used as screening tools to determine whether a full Phase I ESA may be warranted.

Phase II ESAs

A Phase II ESA can characterize environmental concerns at the property in question. Every Phase II ESA is specific to the property and conditions, and our team of professionals will design a sampling plan meeting the requirements of ASTM E1903-02 to evaluate potential environmental impacts. Activities involved in a Phase II ESA can include the collection of soil and groundwater samples, ground-penetrating radar surveys, and the characterization of unidentified substances.

Asbestos Surveys

A & M provides asbestos surveys to assist our clients with the identification, management, and/or removal of ACM. Our team of professionals is licensed in accordance with state and local regulations and has conducted asbestos surveys for properties ranging from single-family homes to skyscrapers, factories, and schools.

Lead-Based Paint Surveys

Older buildings and equipment can be coated with lead-based paint (LBP). A & M can assist with lead-based paint surveys in accordance with USEPA regulations using non-destructive X-ray fluorescence (XRF) analyzers.

Mold and Moisture Investigations

Molds can be found almost anywhere and will grow on virtually any organic substance as long as moisture and oxygen are present. Delayed or insufficient maintenance practices are usually associated with moisture problems in commercial-use and multi-family residential buildings. Our trained staff can perform investigations to identify sources of moisture as well as elevated mold spore concentrations.

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Brownfields & VCP Programs

Due Diligence
Inspections
QAPPs
PSAPs
PWPs
RAWPs
Remediation
Redevelopment

Our environmental specialists  are experienced in the evaluation and redevelopment of abandoned, closed, and/or under-used industrial commercial facilities known as brownfields sites. We understand the expansion, redevelopment, or reuse of such real property can be complicated by the presence or potential presence of hazardous substances, pollutants, and/or contaminants.

We can provide the due diligence (Phase I and II Environmental Site Assessments) and inspections (asbestos, lead-based paint, mold) necessary to evaluate the actual presence of hazardous substances, pollutants, and/or contaminants at brownfields sites. A & M has provided such services for multiple brownfield sites including abandoned schools, illicit dump sites, former industrial properties, former commercial properties, and a former coal strip mine for various government agencies. We have also provided due diligence, asbestos inspections, lead-based paint inspections, and mold inspections during the decommissioning of a major Air Force base (non-brownfields project).

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We are experienced in the preparation and implementation of the quality assurance project plans (QAPP), project sampling and analyses plans (PSAP), project work plans (PWP), and project health and safety plans (PHASP) required for work associated with brownfield sites. These plans are integral to the success of the project during the evaluation and redevelopment phases.

Our team can also provide remediation and redevelopment services for brownfield sites. Related experience includes assistance with the construction of repositories for the deposition of contaminated soil for a  former zinc smelter site and soil remediation at a former industrial site.

A & M is also familiar with the Oklahoma Department of Environmental Quality (ODEQ) Voluntary Cleanup Program (VCP) including the plans, programs, procedures, negotiations, and timelines required. We have a good standing relationship with the ODEQ VCP and would be happy to assist you with such needs all the way from enrollment to completion and no further action designation.

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EPCRA & TRI

Tier 2 Reports
Form R Reports
Form A Reports
Planning

We are experienced in emergency planning, the community right-to-know act (EPRCRA), and toxic release inventory (TRI) reporting. Our team includes Environmental Specialists knowledgeable in such reporting in multiple states for various industries including general manufacturing, foundries, oil and gas, and coating facilities.

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We can assist any industry within any state with the preparation and submittal of their annual Tier 2 Reports. Submission of a Tier 2 Report provides state, local officials, and the public with specific information on potential hazards associated with hazardous chemicals present at a facility during the previous calendar year. These reports are required for hazardous chemicals present at a facility in quantities equal to or greater than the established threshold amounts. Submittal of Tier 2 Reports is integral to improving the public’s knowledge and access to information on chemicals at individual facilities, their uses, and releases into the environment. States and communities, working with facilities, can use the information to improve chemical safety and protect public health and the environment.

Our team has several years’ experience in the preparation of Tier 2 Reports in Oklahoma, Tennessee, Kentucky, Indiana, Illinois, Wisconsin, and Minnesota. Our Environmental Specialist will either perform a site visit or work with facility representatives remotely to develop a Tier 2 chemical candidate list and to compile safety data sheets (SDSs). Based upon the quantities of these chemicals onsite and their associated hazards a list of chemicals that must be reported will be compiled and reviewed with facility representatives. We make every effort to make this process as non-disruptive on day-to-day operations as possible using our experience and knowledge of the process. Once the final list of chemicals to be reported is agreed upon we prepare the Tier 2 Report for signature and submittal to the appropriate regulatory, state, and local agencies including fire departments and local emergency planning committees, as appropriate. Copies of the final reports submitted are provided to the client in PDF format for their records.

When it comes to annual Form A and Form R Reports our team is also ready to help. Our experience in the preparation of such reports extends to the same states and industries as our Tier 2 reporting capabilities. These reports are required for specific industry sectors (manufacturing, mining, electric power, etc.) that employ ten (10) or more full-time equivalent employees and manufacture, process, or otherwise use TRI-listed chemicals in quantities above the threshold levels in a given year. We use the same process in the development and submittal of these reports and also provide a complete PDF of the final reports submitted for the clients’ records.

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USACE Permitting

Nationwide Permitting
Section 404 Permitting
Planning

A & M has team members that are experienced in United States Corps of Engineers (USACE) permitting including nationwide permits and Section 404 Permits. We can assist with the implementation of such permits and prepare applications for Section 404 Permits for most any situation. We specialize in providing USACE permitting services for rock quarries and pipelines.

NEPA Environmental Assessments

NEPA EAs
Desktop Reviews
Threatened & Endangered Species Evaluations
Wetland Evaluations

Our team is experienced in the performance of National Environmental Policy Act (NEPA) environmental assessments (EA). We can assist with the implementation of the NEPA for pipeline corridors, cellular towers, and any other development with a federal nexus. With the assistance of subcontractors we have conducted threatened and endangered species evaluations and wetland evaluations for proposed developments; a newly proposed rock quarry; and a rock quarry expansion.

GROUNDWATER & HYDROLOGY

Monitor well design, installation, and testing
Deep injection well feasibility, design, and construction
Groundwater evaluations
Hydrology studies
Groundwater contaminant dispersion modeling
Groundwater contaminant fate and transport modeling
Subsurface geological investigations
Landfill site characterization and design
Water well design and construction

Our experienced geologists and hydrogeologists provide groundwater and hydrology services for a variety of industries, governmental, and Native American tribal entities. Typical projects range from sewer line groundwater investigations; injection wells (design, permitting, construction); chlorides contaminated groundwater dispersion modeling; and groundwater interceptor trenches/remediation systems (design, installation, operation) for various contaminants including perchloroethylene.

COMPLIANCE EVALUATIONS & AUDITS

Environmental Compliance Evaluations/Audits
Safety Compliance Evaluations/Audits
Compliance Evaluation/Audit Findings Resolution

Our environmental and safety compliance evaluation and auditing team is capable and experienced in assessing compliance for a variety of business sectors including general industry, construction, foundries, oil and gas (production, midstream, processing), and governmental agencies (including military bases). Our team’s environmental evaluation and auditing experience extends across many states throughout the southern and mid-western United States. Our safety evaluation and auditing experience is primarily focused in Oklahoma. These services typically include a review of applicability regarding local, state, and federal regulations (CAA, CWA, RCRA, TSCA, EPCRA, TRI, CERCLA, and OSHA), as appropriate.

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Whenever justified or requested, the available (optional) audit protocols established by the USEPA can be implemented. These audit protocols assist clients in developing programs to evaluate their compliance with environmental requirements under federal law and are intended solely as guidance in this effort. Our client’s legal obligations are determined by the terms of applicable environmental facility-specific permits, as well as underlying statutes and applicable federal, state and local law. Additionally, ASTM E2107-06 (2014) can be implemented as standard practice for environmental regulatory compliance audits, when necessary or requested. OSHA safety and health program audit tools may also be used at the discretion of the client for evaluating safety compliance.

Compliance evaluations are performed as a screening tool to provide a general understanding of a facility’s compliance status in a formative and summative manner. Our compliance evaluations typically include a general facility tour and review of existing programs, permits, and regulatory reports. The compliance evaluation report is formatted in a manner that summarizes the general regulatory applicability review findings, compliance requirements determinations, and regulatory gaps.

Compliance audits are performed as a more thorough and in-depth investigation of a facility’s compliance status. Compliance audits consist of the same components as a compliance evaluation but incorporate more investigation into validation, verification, and adherence. During this process, not only is the facility toured for general understanding, but it is analyzed for specific apprehension of processes and details. Not only is the existence of proper programs, permits, and regulatory reports ascertained but their compliance with regulatory requirements is verified. Compliance audits may even extend to third party waste vendors to ensure third party vendors are handling wastes properly and in manners that do not pose unnecessary liability to the generator. The compliance audit report is formatted to provide both summaries and specific detail regarding regulatory applicability, compliance requirements, regulatory gaps, validation, verification, and adherence.

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MINE PERMITTING

Siting and Feasibility Studies
Oklahoma Department of Mines Consultation
Natural Resources Studies
Jurisdictional Waters Studies
Permit Applications
Public Hearings
Environmental Operational Support

A & M’s team of permitting specialists have many years of experience in mineral/non-coal mine permitting and all associated aspects of compliance within the Oklahoma region. Our team members have an excellent working relationship with the Oklahoma Department of Mines (ODOM). Mineral/non-coal mines include limestone, dimensional stone, sand and gravel, gypsum, clay and shale, granite, caliche, tripoli, salt, iron ore, and chat. Before mining operations commence a permit must be obtained from the ODOM which includes submittal of an acceptable application and posting of adequate reclamation bonds. Preparation of such applications can be a burdensome process and require specific knowledge to ensure that all of the required legal and financial compliance information, environmental resources safeguards, operation plans, and detailed maps are provided. We can help with this effort in part or in its entirety depending upon the clients’ needs. We also provide the  turnkey compliance services related to the ODOM application and mine operations including air quality, storm water, SPCC, wastewater sampling, and safety.