4 The record articles

ALL4 at the Environmental Federation of Oklahoma Conference

Posted: November 4th, 2019

Authors: Frank D. 

With conference season in full “swing”, just as the baseball season is coming to a close, ALL4 has been hitting the road and attending conferences.  On October 8-9, 2019 ALL4 attended the Environmental Federation of Oklahoma (EFO) Conference held in Oklahoma City, OK.  In Oklahoma, there has been legislative activity impacting various media, including air, waste, and water.  This year’s EFO Conference underscored regulatory updates.  Through this blog, my intent is to share a summary of some important topics discussed and the key takeaways from each of those topics.

Specifically, as it relates to air quality the following four topics were highlighted:

  • Oklahoma’s Environmental, Health, And Safety Audit Privilege Act
  • Per- and polyfluoroalkyl substances (PFAS)
  • Continuous Emissions Monitoring Systems (CEMS) Regulatory Interpretation

Oklahoma’s Environmental, Health, And Safety Audit Privilege Act

Hot off the press!  Oklahoma’s Environmental, Health, And Safety Audit Privilege Act (abbreviated hereafter as the Act) became effective on November 1, 2019.  See the complete Bill information on the Oklahoma State Legislature’s website: here. The Act, which was heavily inspired by a similar program implemented by the Texas Commission of Environmental Quality (TCEQ), creates a level of immunity for companies from administrative and civil penalties by conducting a voluntary audit.  In order for a successful audit, a four-step process must be followed, including: [1] the submission of a Notice of Audit (NOA), [2] the submission of Disclosure of Violations (DOV) [3] the submission of an extension request (if needed) and [4] the submission of the Conclusion of Audit.  A good resource for you to evaluate your facility’s environmental compliance to uncover potential unknown environmental liabilities without the concern for actions is by conducting an audit in accordance with the Act.  If you need help conducting an audit or have questions about Oklahoma Department of Environmental Quality’s (ODEQ’s) procedure reach out to us.  ALL4 has assisted our clients in TX commence, execute and complete audits under TCEQ’s Environmental, Health, And Safety Audit Privilege Act, on which ODEQ has based their Act.  We can leverage our experience with TCEQ’s Environmental, Health, And Safety Audit Privilege Act to support audits within Oklahoma.


As our very own Kristen Aune eloquently explained in her blog, Sticky Situation: What You Should Know About PFAS, PFAS is center stage on both a Federal and State level.  To cater to the rising need for PFAS education, an entire two-and-a-half-hour session was dedicated to discussing potential regulatory nuances and testing requirements associated with PFAS.  Topics ranging from a general overview of the risks, uses, sources and exposures of PFAS to a summary of ODEQ’s evolving approach towards addressing PFAS and their acknowledgment of how difficult it can be to sample and create field and laboratory testing programs.  While there was a lot of buzz around PFAS at the EFO Conference, there still remains a significant amount of uncertainty associated with these compounds.  Stay tuned for updates from our team.  If you have additional questions, reach out to our team at info@all4inc.com.

CEMS Regulatory Interpretation

Our very own Eric Swisher has been instrumental in working alongside Oklahoma industry, the U.S. Environmental Protection Agency (U.S. EPA) and ODEQ on a very interesting issue regarding the interpretation of CEMS monitor downtime.  While I won’t delve into fine details, this topic illustrates an example of how ALL4 is continuing to shape environmental responsibility throughout the U.S., I will share the conclusion.  Essentially where things landed is following approximately a two-year process, on June 13, 2019 U.S. EPA withdrew a Regulatory Interpretation that would have changed the way hourly averages were evaluated as it relates to CEMS data.  If you’d like to understand more background details of the interpretation and its potential implication’s check our one of Eric’s original presentations located here.

Be sure to stop by our booth next year at the 29th annual EFO Conference to be held in Tulsa, OK.  In the meantime be sure to reach out to me if you have any additional questions or comments about the conference or our work within Oklahoma at fdougherty@all4inc.com or 281-933-5246 x302.


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