Document M4VnEp6qrZ53ovyEOpX6NDxk7

Memorandum AIR J PRODl/CTS To; From Date Sublet: R. C. Sander A. J. Dlgllo 12 January 1988 Environmental Emissions Reduction Dept Dept , Ext Chemicals Administration Corporate Environmental/8339 bcc: P. L. T. Brian T. J. Harriott, Jr. Bob: This Is In reply to your request for an analysis of the Chemicals environmental emissions for the years 1986 and 1987. Table I - Emissions Analysis shows that the highest number of emissions In 1986 were Pasadena opacity (82), Escambia NPOES (27), Paulsboro opacity (20) and Paulsboro NPOES (19). In 1987, the highest number of emissions were Calvert opacity (78), Pasadena opacity (44), Escambia odor (18), Paulsboro NPDES (13) and Calvert VCM (9). In 1987, Chemicals made excellent reductions In the following excursions: Pasadena opacity (82-44), Paulsboro opacity (20-1), Escambia NPDES (27-4), and Paulsboro NPDES (19-13). For 1988, emphasis should continue on the compliance programs (attachment 2) to reduce the emissions from: Calvert and Escambia VCM Emissions Calvert Opacity Pasadena Opacity Escambia Odors If the compliance programs are Implemented, significant reductions would occur not including the third party emissions. These are mostly leaking drums and are the subject of the 'Leaking Drum Containment* program which we expect to significantly reduce leaking drums In 1988. Isolated emissions are mostly spills and accidental releases. In 1987, 62 of these were recorded compared to 33 In 1986. Perhaps this Is the result of a better tracking system. On the other hand, release and spill prevention programs should be emphasized to reduce these occurrences In 1988. Please be advised of the BNA article (attachment 3) that shows EPA Is seeking $11.7 million penalty from Nevada Power Company for excess emissions of fly ash, carbon particles and sulfur dioxide from two generating units. Nevada Power Is distressed since It already paid state penalties of $8,000 for the excess emissions and now Is being sued by EPA for the same excursions. Please note Terry Wharton's document (attachment 4) shows analysis by categories for 1986 and 1987. He concludes that environmental emissions were up In all four categories, year to year, 1987 vs. 1986. rov 1020 * AP00024724 TO: R. C. Sander FROM: A. J. Dlgllo Page 2 12 January 1988 Indications are that If the compliance programs are Implemented early In 1988 we would expect a significant reduction In emissions for the year. Proportionately, your exposure to potential public reactions, state and EPA penalties would be reduced. AJO/pbr 0559v Attachments: 1) Table - Chemicals Emissions Analysis 2) Environmental Compliance Programs, Fourth Quarter 1987 3) Environment Reporter article "EPA Files Suit Against Nevada Power Co. Over 466 Alleged Violations of Clean Air Act", December 25, 1987 4) Memo from J. T. Wharton, 30 October 1987, FY37 Environmental Emissions Status AP00024725 9ZZfrZ000dV 220 275 CHEMICALS EMISSIONS ANALYSIS 03 > 00 O NO O O 0 0 0 0 0 CO CO (A Ol r* O CO 0 0 0 0 0 r- 0 t0 UD CM CM O r- O r* O 0 O 0 O <Ti CM CM 1 1 1 i 1 1 p- CM CD p O CM M^ r-- M nOrO* t6 CO I- ^CO 91 m *--CD pM** (NJ 10 tco r-- CM CM 00 SI 9> u") co cm o r-- 9) CM CM CM r-- p* ^ C*1 ^ D O' >1 T" VO O M *- W (0 t/> UJ UCOJ (0 U U 0. O a. k. O pc- a10. o 2a.* CD UN (O OO > p- U. W fO 0) a((mA0. -WP -CC j<CD *Z" OO O-P UM Ao 1r30>> pm- EW *- 3 U 10 <0 v <_> a. uj jQo f* 3IQ a. r0>-> y10 U_"Q" u(Ai -I <u0 4A 0) x: o TOTAL LZLbZOOOdV EPA SEEKS $11.6$ MILLION from Nevada Power Co. (or some 466 alleged violations of the Clean Air Act at the company's Reid-Gardner Generating Station near Moapa, Nev. (p. 1950). Enforcement CPA FILES SUIT AGAINST NEVADA POWER CO. OVER 4M ALLEGED VIOLATIONS OP CLEAN AIR ACT CARSON CITY, Nev. -- (By a BNA Special Correspon dent) -- The Environmental Protection Agency Dee. 1 mod Nevada Power Co. scefclna Si 1.85 million for some 4(6 alleged violations of the Clean Air Act it its Reid-Gardner Generating Station near Moapa, Nev. The complaint charged the company with mi. sions ofay Mh. carbon nartldaa and l~.m two of its four generating units. It also alleged failure to seep adequate records. Although EPA said the violations began in lilt, the aUeesd violations lilted to the complaint "* fWTl frnc. 16- IMS rnrniign Mil-rli B iflf fae cpm- slaint seeks $25,009 per violation oar dav (US v. Nevada The list cited in the complaint Includes an 11-day period in 19(5 when ooe of the four coal-fired generating units was operated by Nevada Power without pollution control equip ment The company hat already paid an $8,000 fine for that violation, according to Lew Dodgion, administrator of the Nevada Department of Environmental Protection. In addi tion, Nevada Power was assessed a $1,500 fine for two subsequent three-day periods when the pollution control equipment was bypassed, Dodgloa said. "We took enforcement action* at the state level over significant violations," Dodgion told BNA. "We've been working with [Nevada Power and)... the excess emissions have been reduced since 1914 by a substantial amount" Dodgion said the only complaints from residents in the sparsely-populated area concerned odors from effluent in the tsh pond. "We've worked with them on that too, and I tkinfc we have it corrected,'' he said. Virginia Donohue, with EPA Region IX in San Francisco, teid "meet of the Infractions were small. But when we did an audit and saw bow many there were . . we're just looking at the sheer weight of them." Donohue said EPA participated with the NDEP la an OB* site audit of Nevada Power in 198$, but the decision to file suit came after a recent internal audit of enforcement files. The Reid-Gardner Generating Station In located in the southeast corner of Nevada, near the Moapa River Indian Reservation and shoot three miles from the town of Glen- dak, which has a population of 80$. Between 49 and 50 people live in the Indian village of Moapa and another 75 to 1M residents are scattered throoghoat the reservation. Murray Westgate, spokesman for Nevada Power, said the company delivers electricity to aO of southern Nevada. "We have 2(0,060 customers," Westgate said. He declined to comment on the suit, however, referring BNA to the com pany's attorney, Charles Ivey of Giboon, Dunn, and Crutcher in Lot Angeles. "It is certainly true the company will vigorously resist the claims," Ivey told BNA. "Nevada Power did hare a proceed ing before the NDEP sod paid an ||OQO pnty".f aniae of the same violations EPA cited in its complaint He said the company is -autresseo that It went thrnush the state level ana paid penalties there and then not sued by the fedwal government." " Ivey said that most of the allegations in EPA's compliant are minor. "You would think that they would be overlooked, especially in view of the long history Nevada Power has working with the NDEP." Ivey said be has contacted EPA attorneys to open settle ment negotiations. Fnvfrnnmont. Renorter. December 25, 1987