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ENFORCEMENT REPORT December 1987
AGENDA ITEM VI
Introduction
In accordance with the amended Texas Clean Air Act (Act), this report has been prepared and describes the status of enforcement actions initiated by the agency. Recommendations for Board Orders with administrative penalties are included on the agenda and are reflected in this report.
Enforcement Summary
Since September 1, 1987, Notices of Violation were issued to 215 companies, individuals or governmental agencies. Of these violations, 92 have been resolved. From September 1, 1985, effective date of the amended Act, a total of 96 violation situations currently remain unresolved for more than 30 days and will require formal enforcement action. Specific details for each of the unresolved situations are contained in the attached Tables. Table 4 contains a listing of 9 companies in violation which constructed small facilities without a Board permit or exemption and for which Board Orders without adminis trative penalties are being developed or recommended. The cases for which Board Orders were approved at the November Board meeting have been removed from the report.
The following summarizes administrative penalty actions by the Board since September 1, 1987.
Agreed Administrative Board Orders Entered: 46 Total of Administrative Penalties Assessed: $278,125.00
The following summarizes legal actions resolved through court orders entered since September 1, 1987.
*
Cases Settled by Attorney General: 5 Total Civil Penalties Assessed: $243,750.00
Administrative Penalty Orders
Pursuant to Sections 3.20 and 4.041 of the Act and in accordance with the Guidelines for Assessing Administrative Penalties, the staff will be presenting the Board Orders that have been finalized with the companies for consideration and action by the Board. Although Table 2 includes brief reference to those situations for which penalties are being recommended, these cases will be considered separately during the Board meeting.
LAM 011755
DPMC-08132
Page i
TACB REGION
SOURCE city/county
7 Blacks Hi 1(work Houston/Karris County
7 W. R. Grace and Company Oeer Park/Harris County
8 Dext Company Dallas/Oallas County
n Carpenter Motors El Paso/El Paso County
Table 1
VIOLATIONS
From the September Enforcement Report (That Have Been Corrected)
TYPE OF FACILITY
Millwork Hotel Interiors
NOTIFICATION DATE
OS/25/87
TYPE OF VIOLATION No Permit
Petrochemical Manufacturing
06/30/87
Perm!t Conditions
Haste Food Processing 03/10/87
Permit Representations Opacity
Used Car Sales
08/08/87
Regulation IV {Kotor Vehicle Tampering)
COMMENT
The company constructed the nillwork facility withoui a Board permit. A Board Order without an adunnistr<i tlve penalty was proposed to the company; however, the owner has Indicated that the company is no longe* in business. The matter Is considered resolved.
Stack sampling results Indicate that the company's formaldehyde emissions exceed the permit allowable. The company has retested the process and the results indicate the unit is In compliance. The Regional Director considers the matter resolved.
The company was cited for Increasing the hours of operation in violation of permit representations, h appears this situation can be resolved through permit amendment which was submitted on March 31, 1987. Thi opacity violation was Issued on May 7, 1987. Opacit; levels have been reduced as Indicated by an inspection on Hay 27, 1987. Since the opacity prohlem was corrected within thirty days and only a clerical issue remains, this matter is considered resolved for this report.
The company was originally cited for ofiurmg for sale, vehicles with inoperative emission control devices. The vehicles were repaired Imnniiiately. However, It was later determined that the vehicles, while on the sales lot, were not actually intended for sale. The Regional Director Is recunmendtng tha1 the matter be resolved.
LAM 011756
DPMC-08133
Page l
TACD REGION
SOURCE CITY/COUNTY
1 Crown Cork and Seal Company, Incorporated
Abilene/Taylor County
TYPE OF FACILITY
Fabricated Metal Products
Table 2
VIOLATIONS
Since Septentier l, 1985 (That Util Continue More Than 30 Days)
NOTIFICATION DATE
09/21/87
TYPE OF VIOLATION
Board Order (87-06) NSPS*
2 American Demolition, Incorporated
Borger/Kutchinson County
Asbestos Contractor
12/16/86
NESHAP** (Asbestos)
2 Texaco U.S.A. ICIngsmlll Plant
Gray County
Gas Processin9
06/22/87
NESHAP (Asbestos)
New Source Performance Standards National Emission Standards for Hazardous Air Pollutants
COMMENT
The company failed to submit the NSPS reports required by Board Order 87-06. A Board Onler with an agreed administrative penalty of |7,8u<J.ou will be presented to the Board for adoption if the Order is finalized with the company prior to the Hoard meeting date.
The company was cited for improper removal of asbestos at the Phillips Chemical Company facility at Borger. A formal enforcement conference was held on April 22. 1987. A Board Order with an administra tive penalty has been proposed to the company. The company has submitted additional information regard ing the actual dates of violation which is being reviewed by the Legal Division.
The company had loose asbestos on the ground in an area where asbestos demolition had occurred. A formal enforcement conference was held on Septert>er 2, 1987. The Regional Director has recnm mended a Board Order with an administrative penalty; however, an additional analysis of the asbestos samples is being conducted prior to proceeding with development of a Board Order.
LAM 011757
DPMC-08134
Page 2
TACB REGION
SOURCE CITY/COUNTY
3 Classic Marble Company Austin/Travis County
TYPE OF FACILITY Cultured Marble
Table 2 VIOLATIONS
Since September 1, 1985 {That Will Continue More Than 30 Days)
NOTIFICATION OATE
07/18/87
TYPE Of VIOLATION No Permit
3 Highland Mall Joint Venture Shopping Mall
09/01/87
and falcon Associates
Asbestos Contractor
09/01/87
Austin/Travl s County
NESHAP (Asbestos) NESHAP (Asbestos)
3 Pharaoh and Associates, incorporated
Burton/Washlngton County
Oi1 and Gas Production
06/15/87
Nuisance (Odor) No Permit
COMMENT
The company constructed a cultured marble facility without a Board permit. Because the company had prior knowledge of the permit requirements, the Regional Oirector has recommended a Board Order with an administrative penalty, which has been proposed t the company. The company has submitted additional information and requested that the penalty amount be reconsidered.
The mall management was cited for improper removal o' asbestos-containing material during a renovation project. A formal enforcement conference was held o< September 17, 1987. Board Orders with an agreed administrative penalty of 54,000.00 each for the mal and the asbestos contractor will be presented to the Board for adoption if the Order is finalized with tb< companies prior to the Board meeting date.
The company was cited for nuisance odors from the unauthorized venting at a gas well. A formal enforcement conference was held on July ?0, 1987. ,\ Board Order with an admlnistrative penalty Has been proposed to the company; however, the company has nm agreed to the penalty and a review of the matter is continuing. Additional enforcement action will be recommended if an agreement cannot be reached.
LAM 011758
DPMC-08135
Page 3
TACB REGION
SOURCE CITY/COUNTY
3 P1 as Clad, Incorporated Temple/Bell County
TYPE OF FACILITY Wood Products
Table 2
VIOLATIONS
Since September 1, 19BS (That Will Continue Hore Than 30 Days)
NOTIFICATION DATE
08/13/87
TYPE OF VIOLATION Nuisance (Sawdust)
3 Structural Metals,
Painting Metal Fence 07/14/87
Incorporated
Posts
dba Southern Post Company
Austin/Travis County
No Penult
4 Anglo Iron and Metal Company, Incorporated
Harlingen/Cameron County
Scrap Metal Shredding 08/26/87
Outdoor Burning Nuisance (Smoke)
come nt
The company was cited for nuisance sawdust cnnhtin< created By defective air pollution control equipmen' (cydome). A formal enforcement conference was he 1. on September 24, 1987. A Board Order with an administrative penalty has been proposed to the company.
The company constructed a fence painting facility without a Board permit. A formal enforcement conference was held on September 23, 1987. A Board Order with an agreed administrative penalty of S7S0.00w11| be presented to the Board for adoption if the Order is finalized with the company prior to the Board meeting date.
The ewpaiiy was conducting outdoor burning of debriand created a nuisance smoke condition. A formal enforcement conference was held on October 9, 1987. The ftcftonal Director has recommended a Roard Order with an administrative penalty which Is being developed.
LAM 011759
DPMC-08136
Page *
TaMe 2 VIOLATIONS
Since September 1, 1985 (That Will Continue Horn Than 30 Days)
TACB REGION
SOURCE city/county
TYPE OF FACILITY
5 American Chrome and
Chromium Chemicals
Chemicals, Incorporated
Manufacturing
Corpus Christi/Nueces County
NOTIFICATION DATE
07/11/87
TYPE OF VIOLATION Opacity
5 Coastal Refining and
Petroleum Refining
Marketing, Incorporated
Corpus Chrtsti/Nueces County
10/10/87
NSPS (Monitoring and Hydrogen Sulfide Gas Content)
5 Kaspar Wire Works, Incorporated
Shiner/lavaca County
Fabricated Met a) Products
08/04/87
Permit Conditions No Permit
COMMENT
The company mas cited for excessive opacity from the chrome hearth stack. A formal enforcement conference was held on August 3, 1987. The company submitted a proposal to Install a baghouse to reduce emissions from the hearth. The Regional Oirector had recom mended a Board Order with an administrative penalty. Subsequently, the company requested additional time to further evaluate its abatement plan to insure adequacy. A Board Order *1th an administrative penalty has been proposed to the company.
The company as cited for nine Instances of excess hydrogen sulfide (n the refinery fuel gas system. A formal enforcement conference mas held on November 4, 1987. The Regional Oirector has recommended a Board Order with an administrative penalty which is being developed.
The co^iany was cited for an increase In production without obtaining a permit amendment. A format enforcement conference was held on Septembei 10, 1987. A Board Order with an administrative penalty has been proposed to the company.
LAM 011760
DPMC-08137
Page 5
Table 2 VIOLATIONS
Since September 1, 1985 (That Will Continue Hore Than 30 Days)
TACB REGION
SOURCE
NOTIFICATION
C1TY/COUNTV__________________ TYPE OF FACILITY____________ DATE________ TYPE Of VIOLATION __________________________ COMMENT
6 Champion Chemicals, Incorporated
Odessa/Ector County
General Chemicals
03/04/87
Nuisance (Odors) Rnard Order
The company was cited for nuisance odors anil non* compliance with Board Order No. 86-114(<i). The company had refused to accept the Board Or.i.*r and
administrative penalty which was proposed. However, the company has employed a consultant to develop an effective compliance plan. During a conference hel.t on October 7, 1987, the company proposed the model ling of four substances handled hy the plant for downwind nuisance potential. On Noveofcer 12, 1987,
the company confirmed that additional housekeeping
measures had been Implemented to reduce the potent)* for nuisance odors. A settlement Is being
negotiated.
6 Dynegen, Incorporated
Synthetic Rubber
A General Tire Subsidiary
Manufacture
Odessa/Ector County
09/30/87
Nuisance (Odor)
The company was cited for nuisance Styrene odors which ere attributed primarily to the cruut> rubber
dryer vents. The company has applied for a permit t
replace the dryers and to install stacks to improve
emission dispersion. A formal enforcement conferee was held on October 20, 1987, The Regional Director has recommended a Board Order with a administrative penalty which is being developed.
LAM 011761
DPMC-08138
Page 6
TACfi REGION
SOURCE CITY/COUNTY
6 Leigh Brothers Coatings Odessa/Ector County
Table 2
VIOLATIONS
Since September 1, 1985 (That Will Continue More Than 30 Days)
TYPE OF FACILITY
01lfield Equipment Coatings
NOTIFICATION DATE
08/05/87
TYPE OF VIOLATION
No Permit Permit Conditions Permit Representations
6 Neleh Gas Systems McCamey/Crockett County
Gas Processing
09/05/87
No Permit Permit Conditions
7 Amoco Chemicals Company
Petrochemical
Tens City/Galveston County
Manufacturing
04/14/86
Permit Conditions NESHAP (Benzene)
COMMENT
The company was cited for conducting sandblasting outdoors Instead of in a building as required by the speclal permit. A formal enforcement conference held on August 13, 1987, A Board Order with an agreed administrative penalty of 52,000.1)0 will he presented to the Board for adoption If the Order is finalized with the coepany prior to the Board meet in date.
The company was cited for a modification of its production process that resulted In a significant Increase In emissions of sulfur dioxide. A formal enforcement conference was held on October 7, 19H7. The Regional 01 rector has recommended a Board Order with an administrative penalty which Is being developed.
The company reported that 2,400 pounds of benzene were released through a defective relief valve. Th, company claimed Its process was not subject to the NESHAP benzene regulation. The matter was referred to the PA. A recent determination from the CPA indicates the release is regulated under (.he benze", NESHAP standards. A Board Order with an ajreed administrative penalty of 59,500.00 will be presents to the Board for adoption if the Order is finalized with the company prior to the Board meeting date.
LAM 011762
DPMC-08139
Page 7
Table 2 VIOLATIONS
Since September 1, 1985 (That Will Continue More Than 30 Days)
TAC8 REGION
SOURCE CITY/COUNTY
7 Amoco Oil Company Texas City/Galveston County
TYPE OF FACILITY Petroleum Refining
7 ARCO Chemical Company
Chemical Plant
Channelviav/Harris County
7 A1 Cleaners Webster/Harrls County
Dry Cleaning
NOTIFICATION
DATE
TYPE OF VIOLATION
COWENT
06/17/87
N$PS (Performance Testing) Permit Conditions
The company was found operating in violation uf the
NSPS Monitoring requirements for carbon nnnoxide wit< regard to the operation of the fluid catalytic erod ing unit. A formal enforcement conference was held on Septeeber 10, 1987. The Regional Director has recommended a Board Order with an administrative penalty. Additional violations are being considered
for Inclusion in the Board Order.
08/08/87
NESHAP (Benzene)
The coMpany was found In violation of several NESHAP benzene fugitive emission control provisions. A formal enforcement conference was held on Septe^er 14, 1987. The company failed to install and maintain a flame sensing device on the plant flare In benzene service as required by the NESHAP benzene regulations. A Board Order with an adminis trative penalty has been proposed to the company.
09/20/87
Regulation V (VOC***)
The dry cleaning company was operating the clothes drying machines without the solvent recovery system operating properly. A formal enforcement conference was held on November 12, 1987. The Regional Oirector Is reviewing the matter to determine the appropriate
enforcement action.
`Volatile Organic Compounds
LAM 011763
DPMC-08140
Page 8
Table 2
VIOLATIONS
Since September 1, 1985 (That Will Continue Wore Than 30 Days)
TACB REGION
SOURCE
NOTIFICATION
Cm/COUNTT__________________ TYPE OF FACILITY____________ DATE________ TYPE OF VIOLATION____________________________ COMMENT
A1 Dry Cleaners Houston/Harrls County
Ory Cleaners
09/19/87
Regulation V (VOC)
The dry cleaning company was operating the clothes drying machines without the solvent recovery system operating properly. A formal enforcement conference was held on November 10, 1987. The Regional Direct' is reviewing the matter to determine the appropriate enforcement action.
Crown Cork and Seal Company, Incorporated
Galena Park/Harris County
Fabricated Metal Products
02/26/87
No Permit WPS
The company increased production and added addition, capacity to its beverage can manufacturing facility without a Board permit and in violation of the Federal NSPS. The Legal Division completed a revm of the matter for viability. The facility is cur rently shut down. The Board Order with an adminis trative penalty is being revised to reflect an accelerated compliance date. An additional legal review of the NSPS issues is in progress.
Custom Cleaners Huidile/Harrl s County
Ory Cleaners
10/14/87
Regulation V (VOC)
The dry cleaning company was operating the clothes drying machines without the solvent recovery system operating properly. A formal enforcement conference was held on November 12, 1987. The Regional DirectIs reviewing the matter to determine the appropriate enforcement action.
LAM 011764 DPMC-08141
Pag* 9
TACB REGION
SOURCE CITY/COUNT*_____________
7 0 and ft Metal finishing HeuUOfl/HArrH County
7 Denka Chewfcal Corporation Houston/Karrls County
Table 2 millions
Since September 1, 4985 (That Mill Continue Here Than 30 Pays)
NOTIFICATION
TYPE Of fACUITYOAK
TTPE OF VIOLATIPW__________________ _________ COMMENT
Sandblasting,
04/01/8?
Painting and Plating
No Permit
The company constructed and continues to aerate a metal finishing facility without a Board perati. Three attempts were made to deliver the violation letter before it was accepted. A formal L*nforcemern conference was held on July 30. 198?. A hoard Order with an agreed administrative penalty of tl.SOO.OQ will be presented to the Board for adoption if the Order is finalized with the company prior tn the Board meeting date.
Neoprene and Maleic
10/04/87
Anhydride Manufacture
Regulation V (VQC) NSPS Nuisance
The coapany was cited for violations of the Texas Clean Air Act after aafcient monitoring irt nelghhorin communities revealed elevated levels of chioroprene. followup Investigations showed additional violation' of Board Rules and Regulations. A formal enforcemen' conference was held on October ?, 1987. lhv Regions Director has reconwended formal enforcement action. The Director of Enforcement is reviewing tw matter to determine the appropriate type of action.
LAM 011765
DPMC-08142
Page 10
Table 2
VIOLATIONS
Since Septentier l, 1985 (That Will Continue More Than 30 Oays1
TACR REGION
SOURCE
NOTIFICATION
C1TY/C0UNTY__________________ TYPE OF FACILITY____________ OATC________ TYPE OF VIOLATION____________________________ COMMENT
7 Doty Landfill Houston/Harris County
Landfill
03/16/87
Nuisance (Odors)
The company operates a landfill which has heen thp subject of numerous citizen complaints. A Hoard Order with an administrative penalty has been proposed to the company. The company res|>onded w>u additional Information Indicating that a consulting engineer has been hired to prepare a comprehensive compliance plan by Oecenfcer 11, 1987 irfiich may he used to reconsider the penalty amount.
7 Exxon Chemical Americas Naytown/Harris County
Petrochemical Hanufactoring
08/29/87
NESHAP (Benzene)
The company failed to Install and maintain flame sensing devices on the plant flares in benzene
service as required by the NESHAP-Benzene regula tions. A formal enforcement conference was held on Septe^er 21, 1987. A Board Order with an adminis
trative penalty has been proposed to the company.
7 Fifty Four 0 One Dashwood, Office Complex
Incorporated Bellaire/Harrls County
07/27/87
NESHAP (Asbestos)
The company operated the building comping and was responsible for a renovation project in which asbestos was Improperly removed. A Board Order with an administrative penalty has been proposed to the company; however, an additional analysis u< the asbestos samples 1$ being conducted. Since the sample results were disputed by the company, the Legal Division is reviewing the matter boforp the Order is finalized.
LAM 011766
DPMC-08143
Page 11
TACB REGION
SOURCE cnr/couMY
7 Fusion, Inc. Houston/Harris County
TYPE OF FACILITY Chrome Plating
Table 2 VIOLATIONS
Since September 1, 1966 (That Will Continue Hore Than 30 Oays)
NOTIFICATION DATE
08/26/07
TYPE OF VIOLATION No Permit
7 Gulf States Asphalt Company, Incorporated
Deer Parfc/Harris County
7 Microdot, Incorporated Houston/Harris County
Asphalt Products (With Asbestos)
Caskets and Seals of Rubber
07/26/87
NESHAP (Asbestos)
10/24/87
No Permit
7 Monsanto Company Alvln/Brazori a County
Petrochemical Manufacturing
08/10/87
NESHAP (Benzene)
COMMENT
The company constructed and continues to operate a chrome plating facility without a Board permit. A permit application has been submitted and is under review. A Board Order with an agreed administrative penalty of 1750.00 will be presented to the floard fu adoption If the Order Is finalized with the company prior to the Board meeting date.
The conpany was cited for visible emissions emanatin from a process where asphalt containing asbestos is manufactured. The matter is under review in the Legal Division to determine NESHAP applicability.
The co^iany constructed and continues to operate a rubber seal and gasket manufacturing facility with out a Board permit. A formal enforcement conference was held on November 5, 1987. The Regional 111 recto* 1$ preparing a recommendation for appropriate enforcement action.
The coiqiany was found in violation of the NESHAPBenzene regulation regarding leak testing and cali bration of the leak test equipment. A format enforr ment conference was held on September 28, 198/. Ihe Regional Director has recommended a Board Order with an administrative penalty which is being -!veloped.
LAM 011re7
DPMC-08144
Page 12
Table 2
VIOLATIONS
Since September 1, 1986 (That Util Continue More Than 30 Days)
TACB REGION
SOURCE
NOTIFICATION
CtnyCOUNTY_______________ TYPE OF FACILITY___________ DATE________ TYPE OF VIOLATION____________ ;_______________ COMMENT
7 Occidental Chemical Corporation
Pasadena/Marrls County
PVC Manufacturing
03/04/87
NESHAP (Vinyl Chloride) Permit Conditions
The company reported a vinyl chloride release m violation of the NESHAP regulations. A Hoard Order with an agreed administrative penalty was to he presented to the Board for adoption; however, additional violations have been cited and will be Included In a revised Board Order. The Legal Division Is reviewing the applicability of the NESHM regulation with regard to the additional violations.
7 01shan Demolition Houston/Harris County
Landfill
03/16/87
Nuisance (Odors)
The company operates a landfill which has t>een th subject of numerous odor complaints. The file has been under review by the Oeputy Executive Director. A Board Order with an agreed administrative |*nalty of (21,750.00 will be presented to the Board for adoption If the Order is finalized with the company
prior to the Board meeting date.
7 Paktank Corporation Deer Part/Harris County
Storage Terminal
07/15/87
NESHAP (Benzene) Board Order No. 86-114(1) Permit Conditions
The company's terminal and storage facility were found to be In violation of permit conditions and NESHAP (Benzene) monitoring and recordkeeping requirements regarding pumps in benzene service. Th. company was also cited for violating a Board Order
which requires compliance with NESHAP regulations, a formal enforcement conference was held on August 3. 1987. The Director of Enforcement is reviewing the matter for appropriate enforcement action.
011768
DPMC-08145
Page 13
Table 2
VIOLATIONS
Since September 1, 1985 (That Hill Continue More Than 30 Days)
TACB REGION
SOURCE
NOTIFICATION
CITY/COUNTT__________________ TYPE OF FACILITV____________ OATE________ TYPE Of VIOLATION____________________________ COMMENT
Rigs R Us Houston/Harris County
Drilling Structures
03/30/87
Ho Permit
The company constructed and continues to operate a
sandblasting and painting facility without a Board permit. A Board Order with an agreed administrative penalty of 12,000.00 will be presented to the Board for adoption if the Order is finalised with the company prior to the Board meeting date.
Texas Tx T* Marine Transportation, Incorporated
Mouston/Harris County
Petroleum Coke Temi rial
01/28/87
Permit Representations Permit Conditions
The company was operating a coke storage and loading facility In a manner not authorized hy the Board pe< mlt. Additional violations have been issued to the company and will be Incorporated Into a revised Boat Order with an administrative penalty.
United States Postal
Service Bellaire/Uarrls County
U. S. Post Office
07/27/87
NESKAP (Asbestos)
The Postal Service owns an office complex which was the site of an improper asbestos renovation project. An additional analysis of the asbestos samples was conducted. A Board Order with an administrative penalty was proposed to the Postal Service; however, additional Information Is under review by tite Legal Division and the EPA to determine the appropriate enforcement action in this matter.
Wood Material aka Barbee Enterprise,
Incorporated Conroe/Montgomery County
Asphaltic Concrete Plant
05/14/86
Opacity Permit Conditions NSPS (Opacity)
The company was found in violation of NSPS, opacity and permit conditions at the asphaltic concrete plant. Additional odor complaints have been received and a meeting was held with the otupany. a Board Order with an administrative penalty was pro posed to the company; however, the company did not agree to the Board Order. The file Is being prepare1 for referral to the Attorney General's Office for lawsuit.
LAM 011769
DPMC-08146
Page 14
TACB REGION
SOURCE CITY/COUNTY
8 Boney Construction Company, Incorporated
Sachse/Oailas County
TYPE OF FACILITY
Read/mix Concrete Plant
Table 2
VIOLATIONS
Since September 1, 1985 (That Will Continue Hore Than 30 Days)
NOTIFICATION OATE
09/30/87
TYPE OF VIOLATION
Permit Conditions Upset Reporting
6 City Wide Fuels Distributors,
Incorporated Southlake/Tarrant County
Gasoline Bulk Terminal Blending Facltlty
09/19/87
No Permit
8 OHS Refining, Incorporated Silver Recovery Dal las/Dallas County
07/21/87
No Permit
COMMENT
The company was cited for violation of the condti< of the Standard Exemption under which it operates to excessive dust emissions from an Inoperative central dust collector. The Regional Director is reviewing the matter to determine the appropriate enforcement action.
The co^any constructed and continues to operate a gasoline terminal and blending facility without a Board permit. A permit application has been sub mitted and Is under review. The Regional Director has recommended a Board Order with an administrate penalty idiich 1$ being developed.
The company relocated Its silver reclamation facih without a Board permit. A permit application has been submitted and is under review. Thu Director c Enforcement Is reviewing the matter for appropriate enforcement action.
LAM 011770
DPMC-08147
Page 15
TACB REGION
SOURCE CITY/COUNTY
8 flexible Foam Products Terrell/Kaufman County
TYPE OF FACILITY
Foam Rubber Manufacturing
Table 2
VIOLATIONS
Since September 1, 1985 (That Will Continue More Than 30 Oays)
NOTIFICATION DATE
OS/OS/87
TYPE OF VIOLATION No Permit
8 Ingram Enterprises Somervel 1 County
Readymix Concrete Plant
10/03/87
Permit Conditions
8 Larry Jones, Incorporated Cabinet Shop Arlington/Tarrant County
12/12/85
No Peralt
COMMENT
The company constructed and continues to operate a foam and carpet pad manufacturing facility without a Board permit. A permit application has been submit ted and is under review. A Board Order with an agreed administrative penalty of $5,250.00 will he presented to the Board for adoption if the Order is finalized with the company prior to the Hoard iipeein date.
The co^tany continues to operate the facility m violation of the permit conditions due to an inoper able central dust collector. The Regional Director is reviewing the matter to determine the appropriate enforcement action.
The company constructed a custom wooden cabinet manufacturing facility without a Board permit. A public hearing was held on May 26, 1987; however, no opposition attended. The Board Order on the contested cese hearing was entered at the July 17, 1987 Board fleeting and a peralt was issued to the cc*xpany. A Board Order with an agreed administrative penalty of $1,500.00 will be presented to the Board for adoption if the Order Is finalized with the company prior to the Board meeting date.
LAM 011771
DPMC-08148
Page I ft
Taftle 2 VIOLATIONS
Since September 1, 1985 (That Will Continue More Than 30 Oays)
TAC8 REGION
SOURCE
NOTIFICATION
CITY/COUNTY__________________ TYPE OF FACILITY____________ DATE________ TYPE Of VIOLATION____________________________ COMMENT
8 lattimore Materials Company Wet Hatch Concrete
Greenville/Hunt County
Plant
07/06/87
Permit Conditions
8 North Texas Aggregates, Incorporated
Chico/Wise County
Portable Rock Crushing Plant
08/17/87
Permit Exemption Conditions
The company was cited for several provisions of its permit including heavy dust emissions and inadequaf abatement equipment. A Board Order with an agreed administrative penalty of $2,900.00 wi11 he presentto the Board for adoption if the Order is finalized with the company prior to the Board meeting date.
The company was cited for violation of the condi tions of the exemptions trfiich included the failure to keep in-plant roads watered and inadequate water sprays. The company Initiated repairs on the water spray system and the violation was thought to be resolved. Subsequent investigation revealed that water sprays were still inadequate. A Board Order with an agreed administrative penalty of $1,60U.OO will be presented to the Board for adoption if the Order is finalized with the company prior tn the Board meeting date.
8 Overwraps, Incorporated Dalias/Dallas County
Flexographic Printing OS/25/87
No Permit
The company constructed and continues tn operate a printing facility without a Board permit. A consul tant has been hired to identify appropriate controls and prepare a permit application. The cunpany has proposed changes to control the emissions from the printing process and In addition has requested that the proposed administrative penalty be reconsidered.
LAM 011772
DPMC-08149
Page V
Table ?
VIOLATIONS
Since September 1, 1986 (That Hill Continue More Than 30 Days)
TACB REGION
SOURCE
NOTIFICATION
CITT/COUNTY__________________ TYPE OF FACILITY____________ OATE________ TYPE OF VIOLATION____________________________ COMMENT
8 Pamarcn, Incorporated Oallas/Dallas County
Printing Press Repair
06/14/87
No Permit
The company constructed and continues to operate a printing press roller refurbishing facility without Board permit. The company has submitted a permit application. Initial review indicates that the facility does not qualify as a snail source. A Board Order with an administrative penalty is being developed.
8 Rushing Paving Company,
Inc. Sherman/Grayson County
Asphaltic Concrete Batch Plant
08/30/87
Opacity Permit Conditions
The facility has a history of violations of opacity limits and permit conditions. It was agam found to be In violation for excess opacity from the scruhber stack and dust emissions from in-plant traffic. Th. company has shut down the factlfty until correction' are completed. A Board Order with an agreed admin is tratlve penalty of (2,000.00 will be presented to ti> Board for Adoption If the Order is final wed with ti< conpany prior to the Board meeting date.
8 Southwest Heat Exchanger
Air Conditioning
Fort Worth/Tarrant County
Condensers
08/17/87
No Permit
The company constructed and continues to operate a vapor degreaser without a Board permit. A permit
application has been submitted and is under review. The Regional Director has recommended a Board Order with an administrative penalty which is hoing developed.
LAM 011773
DPMC-08150
Page IH
TACB REGION
SOURCE CITI/C0UNTY
8 Tarrant County Hospital Di strict
Fort Worth/Tarrant County
TYPE OF FACILITY Incinerator
Table 2 VIOLATIONS
Since September 1, 1905 (That Will Continue More Than 30 Days)
NOTIFICATION
DATE
TYPE OF VIOLATION
10/05/87
No Permit
9 The Paks Corporation Junct ion/Kmt>le County
General Chemicals
06/01/87
Nuisance (Sawdust) Opacity
COMMENT
The Hospital District was cited for operating the incinerator without a permit or exemption since the unit had not been registered under a standard exemption. The Regional Director Is reviewing the matter to determine If the incinerator qualifies for Standard Exemption No. 90 and to determine the appropriate enforcement action.
The company was cited for excessive opacity from the air pollution control equipment (cyclone) and for nuisance conditions created by burning sawdust. There is not a continuing nuisance condition create by the plant's operation. The company has determine that the scrubber proposed in their compliance plan is prohibitively expensive to operate and has hired consultant to evaluate other less costly controls. The Regional Director Has recommended a Hoard Order with an administrative penalty which is being developed.
LAM 011774
DPMC-08151
Page 19
Table 2
VIOLATIONS
Since September 1, 190S (That Will Continue More Than 30 Days)
TAC8 REGION
SOURCE
NOTIFICATION
CITY/COUNTY__________________ TYPE OF FACILITY____________ OATE________ TYPE OF VIOLATION____________________________ COMMENT
9 Powerwall, Incorporated Poteet/Atascosa County
Fiber fteinforced Stucco
06/29/87
No Permit
The company constructed and continues to <>|K*rate the facility without a Board permit. A formal enforce ment conference was held on July 14, 1987. The development of a Board Order with an administrative penalty was delayed due to Che company owner being te the hospital and unable to submit the additional
Information on capital costs needed to complete the review. The company has hired a consultant to pre
pare the appropriate permit or exemption application. The Regional Oirector has recommended a Board Order with an administrative penalty which is being developed.
9 Texarome, Incorporated Lertey/Real County
Cedar Oi 1 Hill
04/11/67
Permit Representations Excessive Visible
Emissions
The company was cited for not constructing the plan*
as represented in the permit application and for excessive visible emissions. A formal enforcement conference was held on April 28. 1987. On November 17, 1987, a meeting was held in Austin tn hear the company's objection to the proposed enforce ment action. After reviewing the Information pre sented by the company, a revised Board Order with an administrative penalty was proposed to the company.
LAM 011775
DPMC-08152
Page ?U
Table 2 VIOLATIONS
Since September l, 1985 (That Will Continue More Than 30 Oays)
TACB REGION
SOURCE CITY/COUNTY_____________
NOTIFICATION TYPE OF fACILITT____________ OATE________ TYPE OF VIOLATION____________________________ COMMENT
10 American Pptrofina
8ulk Hydrocarbon
Pipeline Company
Terminal
Port Arthur/Jefferson County
07/17/8?
Nuisance (Odors)
The company was cited for creating nuisance (odor) conditions when a gasoline storage tank overfilled and 1,600 barrels of gasoline were spilled. Adverse health effects were confirmed. A satisfactory compliance plan has been submitted to prevent forth*-' incidents. Additional' elements of a long term compliance plan are being negotiated with the company. A Board Order with an agreed administrate penalty of $6,000.00 will be presented to the Board for adoption If the Order Is finalized with the co^>any prior to the Board meeting date.
10 Bright Coop, Incorporated Nacogdoches/Nacogdoches County
Hood Pallet Manufacturing
07/21/86
No Permit
The company has Increased its production rate and added manufacturing equipment over the past several
years without permit authorization. A request for a permit amendment has been submitted and is under review. The regional office staff has conducted sampling to evaluate emissions from the source and t assist In the development of a control plan. Sampl ing conducted by the regional office staff indicates that emission levels are acceptable. The permit amendment Is being processed and a Board Order with an administrative penalty Is being developed.
LAM 011776
DPMC-08153
Page 21
Table 2
VIOLATIONS
Since September 1, 1985 (That Util Continue More Than 30 Oays)
TACB REGION
SOURCE CITY/COUNTY
TYPE OF FACILITY
10 Chevron IJ.S.A.,
Petroleum Refining
Incorporated
Port Arthur/Jefferson County
NOTIFICATION DATE
09/01/87
TYPE OF VIOLATION
Nuisance (Odors) Adverse Health impact
10 Chevron U.S.A.,
Incorporated fieaumont/Jefferson County
Petroleum Refining
07/15/87
Permit Conditions Regulation V (VOC) NSPS
10 Modern Equipment Manufacturers
Luafcerton/liardin County
Industrial Oumpster Manufacture
09/27/87
No Permit Nuisance (Oust)
COMMENT
Process upsets at the Chevron refinery caused excess emissions of uncombusted hydrocarbons and hydrogen sulfide which resulted in an air pollution episode, Including nuisance conditions and adverse health Impacts. Corrections were made at the time of the incident and an acceptable plan to prevent future occurrences of this nature has been submitted. A Board Order with an administrative penalty has been proposed to the company.
The company was cited for failure to conduct the annual Inspections of secondary seals on the storage tanks and other violations of state and federal rule' regarding secondary seals on petroleum storage tanks. A Board Order with an administrative penalty has bee' proposed to the company.
The regional office has received numerous complaints of odors and dust emissions from the facility's sandblasting and spray painting operations. Initial Investigations did not confirm nuisance level emissions, but the company was cited for operating without a Board permit. A compliance plan to control the emissions and obtain a permit was submitted. Recently, additional complaint Investigations have confirmed that uncontrolled sandblasting emissions were creating a nuisance for the area. The Regional 01 rector has recommended a Board Order with an administrative penalty which is being developed.
LAM 011777
DPMC-08154
Page 12
TACB REGION
SOURCE CITT/COUNTY
10 Temple Eastex, Incorporated Pineland/Sabine County
TYPE OF FACILITY Pine Plywood
Tahle 2
VIOLATIONS
Since September 1, 1985 (That Will Continue Hore Than 30 Days)
NOTIFICATION DATE
04/20/87
TYPE OF VIOLATION Permit Representations
10 The Texas Pipe Line Coe^any Storage Terminal Port Arthur/Jefferson County
10 Halters Property Jefferson County
Metal Salvage
09/28/87
Nuisance (Odors)
10/07/87
Outdoor Burning
11 Baltimore Spice Company Hestway/El Paso County
Processing/Packaging Spices
06/03/87
No Permit
COMMENT
The company exceeded the plywood production rate specified In permit provisions. The Regional Director has recommended a Board Order with an administrative penalty. The Oirector of Enforcemen Is reviewing the matter to determine the appropnai enforcement action.
The company was cited for creating a nuisance due i odors from a leaking gasoline storage tank. The Regional Director has recommended a Board Order *u> an admlntstratlve penalty which is being developed.
The Halters' have received several violations for tfiauthorlzed outdoor burning of rubber tires to salvage the metal rims. Previous enforcement situations were Initially considered resolved based on commitments to cease :ne outdoor burning. Recen complaint Investigations confirm the outdoor burn in is continuing. A Board Order with an administrativ penalty Is being developed.
The company was cited for construction and operatic of an ethylene oxide sterilization unit without a Board permit. A permit application has been sub mitted and is under review. A Board Order with an greed administrative penalty of $1,500.00 will he presented to the Board for adoption if the Order is finalized with the company prior to the hoard meet date.
LAM 011778
DPMC-0315l:>
Page 23
Table 2
VIOLATIONS
Since September 1, 1905 (That Will Continue More Than 30 Days)
TACB REGION
SOURCE
NOTIFICATION
Cm/COUNTT__________________ TTPE Of FACILITY____________ DATE
TTPE OF VIOLATION____________________________ COMMENT
11 Chaparral Motors, Incorporated
El Paso/El Paso County
Used Car Sales
08/22/87
Regulation IV (Motor Vehicle Tampering)
The company was cited for offering for sale, vehicle with inoperative emission control devices. A formal enforcement conference was held on October /, 1987. A Board Order with an administrative penally has bee proposed to the company.
11 Department of Defense, U. S. Army
Fort Bliss/El Paso County
Building Renovation
07/16/87
NESHAP (Asbestos)
The Department of Oefense was cited for improper
removal of asbestos at the Fort Bliss facility. Thi matter was referred to the Attorney General's Office on November 9, 1987 for inclusion in an existing lawsuit.
11 Elcor Corporation Van Horn/Culberson County
Abandoned Sulfur Plant 04/19/87
NESHAP (Asbestos)
The company was cited for improper removal of asbestos during the dismantling of buildings and equipment at a closed sulfur production facility. A formal enforcement conference was held on June 2, 1987. A Board Order without an administrative penalty will be presented to the Board for adoption If the Order Is finalized with the company prior to the Board meeting date.
11 El Paso Refining Company. Ltd.
El Paso/El Paso County
Petroleum Refining
08/30/87
Opacity
The company was cited on two occasions for excessive visible emissions. A formal enforcement conference
was held on August 18, 1987. Corrective actions hav been completed and the company is operating in compl ance. A Board Order with an administrative penalty
has been proposed to Che company.
LAM 011779
DPMC-08156
Page ?4
TAC8 REGION
SOURCE CITY/COUNTY
l? Pabco insulation Tucker/Anderson County
Table 2
VIOLATIONS
Since September 1, 198S (That Will Continue More Than 30 Gays)
TYPE OF FACILITY
NOTIFICATION DATE
Fiberglass Insulation 03/30/87
TYPE OF VIOLATION
Permit Conditions NSPS (Monitoring)
12 Prengler Iron A Metals
Company Athens/Henderson County
Metal Salvage
09/04/87
Outdoor Burning
COMMENT
The company was cited for eicessWe stack emissions above permit allowables on particulates, phenol and aldehydes. Corrective measures have been completed A formal enforcement conference was held on August 2$, 1987. The Regional 01 rector has recommended the matter be referred to the Attorney General's Office for lawsuit. The matter is under review in the Legal Division for viability.
The company conducted outdoor burning of wire Insulation, plastic pipe and debris. A formal enforcement conference was held on September 11, 1987. A Board Order with an agreed administrative penalty of $1,000.00 will be presented to the Hoard for adoption if the Order Is finalized with the company prior to the Board meeting date.
lam 011780
DPMC-08157
Page 1
Table 3
VIOLATIONS
Since September 1, 1985 {Approved for Referral to Attorney General's Office)
TACB REGION
SOURCE
NOTIFICATION
CITY/COUNTV__________________ TYPE OF FACILITY____________ DATE________ TYPE OF VIOLATION____________________________ COMMENT*
l Bean Hog Farm Brownwoori/Rrown County
Confined Animal Feedlot
11/21/66
Nuisance (Odors) Board Order (85-12)
The file on this company was referred to the Attorney General's Office on May 21, 1986. The company vio lated a Board Order issued in October, 19HS which required a reduction in the number of animals in the feedlot and prohibited the creation of any further nuisance conditions. It is projected that this law suit can be resolved within 1 month thromiii agreed action.
3 Pool Production Services Company
Kervln/Freestone County
Oil Separation and
Injection Well Facility
03/23/07
Permit Conditions
The file on this company was referred to the Attorney General's Office on October 29, 19BS for violations which occurred prior to Septeafcer 1, 1985. Addi tional violations were forwarded on April 14, 1987 for Inclusion In the lawsuit. This lawsuit is not expected to reach agreed settlement. Trial on the merits has been continued until the first week of March. Depositions of company employees are scheduled for Oecember 16, 1987.
3 Gerald Company. Incorporated
Hamilton County
Grain Handling
04/17/87
Nuisance (Odor)
The file on this company was referred to the Attorney General's Office on September 3, 1987. The ccn^iny operates a feed mil) which has heen the subject of several odor complaints and has failed to initiate
corrective actions. It Is not projected that this sutt can be resolved through an agreed settlement.
If settlement cannot be reached and additional court action Is necessary, then It may take 2 years to resolve these lawsuits.
LAM 011781
DPMC-08158
Page
Table 3
VIOLATIONS
Since September l, 1985 (Approved for Referral to Attorney General's Office)
TACfl REGION
SOURCE
NOTIFICATION
C1TY/COHNTY__________________ TYPE OF FACILITY____________ DATE________ TYPE OF VIOLATION____________________________ COMMENT*
5 Oceanside Asphalt, Incorporated
Robstown/Niieces County
Portable Asphalt Plant
06/26/86
Permit Conditions Nuisance (Oust)
The company was cited for failure to water the stockpiles and roads as required in the Hoard permit and for creating a nuisance dust condition. The fti on this company was referred to the Attorney General's Office on May 28, 1987. It is projected that this lawsuit can be resolved within 9 months If an agreed settlement Is reached.
6 Bryson Tank Company Odessa/Ector County
Tank Manufacturing (Spray Painting)
10/08/85
Nuisance (Paint Overspray)
The company is continuing to operate without the needed controls and the nuisance problem remains. The file on this company was referred to the AttornGeneral's Office on January 31, 1986. Tim petition was filed on August 13, 1986. Cause was dismissed because of Inability to serve the defendant. The case may be reflled.
6 CBN Enterprises Hlrilanri/Hidland County
Sandblasting
10/24/85
Nuisance (Oust) No Permit
The company has a history of violations which tnclu<i nuisance (dust) conditions. The file on this cnmpat was referred to the Attorney General's Office on January 31, 1986. The Attorney General's Office filed suit against the wrong company. The lawsuit was reflled on Septertier 24, 1987. The deposition o the owner of the company was taken on November 11, 1987, It Is projected that the lawsuit can be resolved within 2 months If an agreed settlement is reached.
If settlement cannot be reached and additional court action is necessary, then U may take 2 years to resolve these lawsuits.
law 011782
DPMC-08159
Page 3
Table 3
V101 AT IONS
Since September l, 1985 (Approved for Referral to Attorney General's Office)
TACR REGION
SOURCE
NOTIFICATION
CITY/COUNTY__________________ TYPE OF FACILITY____________ DATE________ TYPE OF VIOLATION___________________,_________ COHHENT
6 Permian Chemical Company, Fertilizer Plant Incorporated
Odessa/Ector County
10/22/85
Permit Representations Permit Conditions Nuisance (Acid Emissions)
.
The file on this company was referred to the Attorn. General's Office on October 22, 1985 for violations occurring prior to September 1, 1985, Additional v< tations were forwarded on January 29, 19H/ for tncl<
sion in the lawsuit. The lawsuit Is not expected t< reach agreed settlement. An agreed temporary mjnn
tion was signed by the company and sent to the Court on June 22, 1987. It requires compliance with Sections 3.27(a) and 4.01(a) of the Act and Rules 101.7 and 111.21. Trial on the merits was continue indefinitely and a modified temporary injunction was entered on October 13, 1987 requiring the cunpany t.
cease production until further order of the court. The company has filed an appeal from the October 13
Order with the Court of Civil Appeals.
7 Cuyahoga Wrecking and Corporation
5 Galveston County
San Patricio County
Asbestos Contractor
07/30/86
NESHAP (Asbestos)
The file on this company was referred to the Attorn General's Office on Hay 8, 1987. The company con ducted asbestos removal projects at Amoco Products Company (Galveston County) and Sun Exploration (San Patricio County) In violation of the NESHAP-Asbesto' standards. The company has filed for bankruptcy, i Is projected that the lawsuit can be resolved withn 2 months If an agreed settlement is reached.
If settleawnt cannot he reached and additional court action Is necessary, then it may take 2 years to resolve these lawsuits.
LAM 011783
DPMC-08160
Page 4
Table 3 VIOLATIONS
Since September 1, 1965 (Approved for Referral to Attorney General's Office)
TACB REGION
SOURCE CITY/COUNTY
TYPE Of FACILITY
7 la Porte Chemicals Corporation,
Vinyl Chloride Monomer Production
Diamond Shamrock Corporation,
Diamond Shamrock Plastics
Corporation
Deer Park/Harris County
NOTIFICATION DATE
01/28/86
TYPE OF VIOLATION
NESHAP (Vinyl Chloride) Perm!t Conditlons
7 Tenneco Polymers, Incorporated
Pasadena/Harris County
Chemical Manufacturing 10/24/85 (Vinyl Chloride)
NESHAP (Vinyl Chloride) Permit Conditions
7 Texas City Refining,
Refinery
Incorporated
Texas City/Galveston County
06/26/86
Permit Provisions MSPS (High Sulfur Crude)
COMMENT*
On June 2, 1986, the file on this company was referred to the Attorney General's Office because of the hazardous substance Involved. Additional viola tions have been periodically referred to the Attorn.General's Office for inclusion in the lawsuit. On October 7, 1987, an agreed final judgment was enters assessing a penalty of $120,000.00 and attorney's fees of $5,000.00 against La Porte Chemicals. A settlement with Diamond Shamrock has been reached; a. agreed final judgment is being prepared.
On December 31, 1985, the file on this company was referred to the Attorney General's Office because of the hazardous substance involved. The company sold its vinyl chloride plant in April, 1986. Further settlement negotiations took place on July l, 1987. A tentative settlement was reached on July 1, 1987. An agreed final judgment is being drafted.
The file on this company was referred to the Attorns General's Office on July 12, 1983. Subsequent vio lations have been periodically forwarded to the Attorney General's Office for Inclusion in the lawsuit. It is proj^ettii that this lawsuit can be resolved within 2 months If an agreed settlement is reached.
If settlement cannot be reached and additional court action is necessary, then it may take 2 years to resolve these lawsuits.
LAM 011784
DPMC-08161
Page 5
Table 3
VIOLATIONS
Since September 1, 1905 (Approved for Referral to Attorney General's Office)
IACB REGION
SOURCE
NOTIFICATION
CfTf/COUNTr_____________ TTPE Of FACILITY____________ DATE________ TTPE OF VIOLATION____________________________COftfNT*
7 Union Carbide Corporation Chemical Manufacturing 02/16/86 Texas City/Galveston County
NESHAP (Vinyl Chloride and Benzene)
The file on this company was referred to the Attonn General`s Office on March 18, 1986. Additional vio lations Nave been periodically included in the law suit. The company has signed and returns! the proposed final Judgment with a check for civil penalties. On Noveofcer 23, 1987, an agreed final judgment was entered assessing a penalty of 138,600.00 and attorney's fees and investigative costs of S5.000.00.
8 Brandywilde Development Corporation
Valley View/Cooke County
Rock Crushing Plant
09/18/85
Permit Conditions
The company has a history of violations beginning m 1983 ken It constructed without a Board permit. Tf file on this company was referred to the Attorney General's Office on February A, 1986. It is pro jected that this lawsuit can be resolved within 2 months If an agreed settlement Is reached. An agr^<
Judgment was milled to the defendant for signature i early F^ruary by certified mall but was apparently lost In the mall. Another agreed judgment was mail*to the defendant on March 16, 1987. Settlement negn tlatloes hive not achieved an agreement. Interrog atories were sent to the cmepany and answered in June, 1967. The company Is no longer operating at the site.
If settlement cannnt he reached and additional court action is necessary, then It may take 2 years to resolve these lawsuits.
LAM 011785
DPMC-08162
Page 6
Table 3
VIOLATIONS
Since September 1, 1906 (Approved for Referral to Attorney General's Office)
TAC8 REGION
SOURCE
NOTIFICATION
CITY/COUNTY__________________ TTPE OF FACILITY____________ DATE________ TYPE OF VIOLATION____________________________ COMMENT*
8 Willie Grant Tarrant County
Individual
02/21/86
Outdoor Burning Court Order
A Judgment was entered against this individual on May 31. 1985 prohibiting future violations of Regulation I. An additional violation ot unautho rized burning has since been documented. The file
was referred to the Attorney General's Office on May 15, 1986. It is projected that this contempt action cannot be resolved by agreement.
10 Great Lakes Carbon
Carbon Plant
Corporation
Port Arthur/Jefferson County
09/27/05
Opacity Excessive Particulate
Emissions Peml t Condi tlons
The file on this company was referred to the Attorn.General *s Office on September 27. 1985 fur violation occurring prior to September 1, 1985. Subsequent violations were forwarded to the Attorney General fo Inclusion In tbe lawsuit. Sampling Is needed before injunctive relief can be drafted. The strike at th plant has recently ended. Resampling was conducted on March 9, 1987. The' resampling indicated continu
ing violations which were forwarded to the Attorney General on June 18. 1987. A settlement meeting was held with the company on Novenfcer 5. 1987. A follow up meeting is scheduled for December 17. ism? to discuss a possible compliance plan. It is projected that this lawsuit can be resolved within 6 months i> an agreed settlement is reached.
If settlement cannot be reached and additional court action is necessary, then it may take 2 years to resolve these lawsuits.
LAM 011786
DPMC-08163
Page 7
Table 3
VIOLATIONS
Since September 1, 1985 (Approved for Referral to Attorney General's Office)
TACB REGION
SOURCE
NOTIFICATION
CITY/COUNTY__________________ TYPE Of FACILITY____________ PATE
TYPE OF VIOLATION____________________________ COMMENT*
U Department of Defense,
Building Renovation
tl. S. Army
Matyear Construction Co*v>any
Pioneer Sheet Netal Worts,
Incorporated
Fort Bliss/El Paso County
09/1 ?/8b
NESHAP (Asbestos Removal)
1? OalUs Demolition and Excavating Company
Tyler/Smith County
Building Demolition
09/16/85
NESHAP (Asbestos Removal)
The file on the Army and the two companies was referred to the Attorney General's Office on April ! 1986 for legal action because of the hazardous sub stance involved. On duly 17, 1987, an agr*>.*d final judgment was entered by the court resolving the vio lations against Matyear and Pioneer. Civil penalty of S5.000.00 were assessed and the companies were prohibitorlly enjoined from violating Rule 101.20(2) In the future. Notice of intent to sue the Depart ment of Defense is being drafted. The lawsuit against the Department of Defense will bo filed in Federal court. It is not projected that the suit ca< be resolved through an agreed settlement. An additional violation was referred to the Attorney General's Office on November 9, 1987 for inclusion ii the lawsuit.
The excavating company was in the process of readyin< a building for Implosion without proper notification and handling of asbestos. This lawsuit is not expected to reach agreed settlement. Interrogatories were sent to the company in June, 1987 and answers to Interrogatories were received on June 20. 1987.
If settlement cannot he reached and additional court action is necessary, then it may take 2 years to resolve these lawsuits.
LAM 011787
DPMC-08164
Page 8
Table 3
VIOLATIONS
Since September 1, 1985 (Approved for Referral to Attorney General's Office)
TACB REGION
SOURCE
NOTIFICATION
CITY/COUNTY__________________ TYPE OF FACUITY___________ OATE_________TYPE OF VIOLATION____________________________ COW1ENT*
12 Poly Cycle Industries, Incorporated
Tecula/Cherokee County
Battery Case Recycling
02/19/86
Permit Conditions Permit Representations
Poor maintenance and cleaning practices at the com pany ' $ hattery case recycling facility have results In high lead concentrations in the soil near the grinding process. Additional samples taken confirms the high lead levels in the soil. The file on this company was referred tb the Attorney General's Oftio On October 22, 1986. Settlement negotiations took place In March, 1987. Another settlement meeting wa
held on July 1, 1987. It is projected that this law
Suit can be resolved within 3 months If an agreed settlement is reached. A proposed closure plan has been submitted to the agency for review of clean-up plans.
12 Southwest Railroad
Railcar Salvage
and Car Parts -
3 Jack sonvi Me/Cherokee County
Jewett/Leon County
03/18/86
Outdoor Burning Nuisance (Smoke)
The file on this company was referred to the Attorney General's Office on July 12, 1985 for violations occurring prior to September l. 1985 at two different sites. Subsequent violations have been forwarded to the Attorney General for inclusion In the lawsuit. Since the defendant's attorney is a state legislator, settlement nay not be possible until the fall of 1987. The Attorney General has requested a settlement meeting with the company in Nove*d>er or December, 1987.
If settlement cannot be reached and additional court action is necessary, then It may take 2 years to resolve these lawsuits.
LAM 011788
DPMC-08165
I'age 9
Table 3 VIOLATIONS
Since September 1, 1985 (Approved for Referral to Attorney General's Office)
TACB REGION
SOURCE
NOTIFICATION
CITY/COUNTY__________________ TYPE OF FACILITY____________ OATE________TYPE OF VIOLATION____________________________ COMMENT*
12 Texas Basic Resources Overton/Rusk County
Grain Transfer
04/04/86
No Permit Nuisance (Oust)
The file on this company was referred to the
Attorney General's Office on March 6, 1987 for constructing and operating a grain transier facility
without a Board permit. It is projected that this lawsuit can be resolved within 9 months if an agrees settlement is reached. The lawsuit was filed on June 17, 1987 and the defendant was serv.-'l on June 29, 1987.
*lf settlement cannot be reached and additional court action Is necessary, then It may take 2 years to resolve these lawsuits.
LAM 011789
DPMC-08166
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LAM 011790
DPMC- 08167
Horizon Retread Center El Paso/El Paso County
08/03/87
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LAM 011791
DFMC-08168
ADMINISTRATIVE PENALTIES AND ORDERS OF THE TEXAS AIR CONTROL BOARD
ORDER NO. 87-11(a) 87-11(b|
87-11 (cl
87-ll(d| 87-lHe) 87-11() 87-11lg)
RESPONDENT
Augat Elfab 1097 Yates Lewisville, TX
Bethania Regional Health Care Center
1600 11th Street Wichita rails, TX
Coastal Refining and Marketing, Inc.
1300 Cantwell Lane Corpus Christi, TX
Elcor Corporation Culberson County, TX
Falcon Associates Travis County, TX
Fusion, Inc. 6911 Fulton Houston, TX
Highland Mall Joint Venture
Travis County, TX
DATE ENTERED 12/18/8?
PENALTY AMOUNT
VIOLATIONS/REMEDIAL ACTION
Construction and operation of a board manufacturing facility without a permit
12/18/87 12/10/87
12/18/87 12/18/87 12/18/87
$325 if sub stantial addi tional controls necessary
$4,000 $750
Construction of a hospital pathological incinerator without a permit
Excessive odor emissions from a coker unit/Continued implementation of interim compliance plan, implementation of the Delayed Coker Blowdown Vapor Control Procedure, records maintenance
Violation of NESHAP established for asbestos/Compliance by properly disposing of asbestos-containing materials
Violation of NESHAP established for asbestos
Construction and operation of two chrome plating tanka without a permit
12/16/B7
$4,000
Violation of NESHAP established for asbestos
MH001AK/1S5E01
-1-
LAM 011792
DPMC-08169
ORDER NO. 87-11<h)
67-11<it 07-11 (j| 87-11 (kt
87-11<1>
RESPONDENT
Larry Jones, Znc. 7900 Valcaei Arlington, TX
DATE ENTERED 12/10/87
PENALTY AMOUNT
f 1 ,500 over a six-month period
Lattimore Materials Co. 1033 Spencer Street Greenville, TX
Leigh Brothers Coating 2720 West 81st Odessa, TX
Prengler Iron 8 Metals Co. Henderson County, TX
12/18/87 12/18/67 12/18/87
82,900
82,000 over a six-month period 81,000
Rushing Paving Co., Inc. 6102 Theresa Drive Sherman, TX
12/18/87
82,000
VIOLATIONS/REMEDIAL ACTION
Construction and operation of a woodworking facility without a permit
Violation of special provisions of permit
Outdoor sandblasting in violation of special permit
Outdoor burning of wire insulation, various plastics, cable wire and debris/ Implementation of fire prevention procedures
Exceedance of 201 opacity limit for visible emissions and failure to comply with special provision of permit/ Cessation of operation of plant pending developnent and implementation of effective abatement Measures
MH0G1AK/1S5E01
LAM 011793
DPMC-08170
ORDER NO. 10584-01 12651-01
10493-02
10374-01 01406
10142-01 11169-01
ADMINISTRATIVE PENALTIES AND ORDERS OF THE TEXAS WATER COMMISSION
RESPONDENT
Menorial Villages Water Authority Sewage Treatment Plant
United States Department of the Air ForceLaughlin Air Force Base
Val Verde County, TX
City of Hemphill
DATE ENTERED 11/10/87 11/10/87
11/17/87
PENALTY AMOUNT
Stipulated penalties
City of Texarkana
11/17/87
Pioneer Aggregates, Inc. Wise County, TX
11/17/87
Stipulated penalties
>4,450
Atascosa County Water Control and Improvement District No. 1
Bayridge Utility District Galveston County, TX
11/18/87 11/18/87
VIOLATIONS/REMEDIAL ACTION
Outlined in 9/10/86 Agreed Order/ Collection of composite water samples during all rainfall events.
Exceedance of permitted 30-day daily average concentration of BODe/Correctivc action according to submitted plan.
Exceedance of permitted 30-day average concentration of TSS/Improvements to existing facility, submission of monthly reports and compliance by 1/1/88.
Exceedance of permitted 30-day average concentrations of BOD,, and TSS/Certain actions to assure compliance.
Unauthorised discharge from one of two rainfall runoff eatch baains/Analyais of grab samples for TSS and monitoring solids accumulation in outfall basins.
Exceedance of permitted daily average concentrations of TSS and BOD^.
Exceedance of permitted 30-day average concentrations of BOD^ and TSS.
MHOO1AL/155E0I
lam 011794
DPMC-08171
ORDER NO. 11193-01 10022-01 10401-06
10693-01 10601-002 10695-01 10633-03 11212-01 11399-01 10922-001 11762-01
RESPONDENT
Britmore Utility, Inc. Harris County, TX
City of Buffalo
DATE ENTERED 11/16/67
11/18/87
PENALTY AMOUNT
City of Corpus ChristiFlour Bluff Laguna Hadre Plant
City of Jacksonville
11/16/87 11/18/87
City of Jefferson
11/18/87
City of Kemp City of McAllen
11/18/87 11/18/87
City of Roma
11/18/87
City of Windthorst
11/18/87
City of Winona
Domestic Utility Company Harris County, TX
11/18/87 11/18/87
VIOLATIONS/REMEDIAL ACTION
Exceedance of permitted 30-day average limit for flow of 0.250 MGD.
Exceedance of permitted daily average concentration of TSS.
Exceedance of permitted daily average flow limitation.
Exceedance of permitted daily average flow limitation.
Exceedance of permitted daily average concentration of TSS.
Exceedance of permitted daily average concentrations of BOD^ and TSS.
Exceedance of permitted daily average concentration for TSS.
Ku zeedance of permitted daily average concentrations of BOD,, and TSS.
Exceedance of permitted 30-day average concentration of BOD^.
Exceedance of permitted daily average flow
Exceedance of permitted 30-day average concentrations for BOD^ and TSS.
MH001AL/15 5EO I
lam 011795
DPMC-08172
ORDER NO. 12005-01
02550
12664-01
13059-01 11096-01 10236-01 10748-01
00721 10610-01 11205-01
RESPONDENT
Harris-Fort Bend County Municipal Utility District No. 1
Fort Bend County, TX
Intercontinental Motors, Inc.
Harris County, TX
Iola Independent School District
Grises County, TX
Kwik-Kopy Corp. Harris County, TX
Motel 11 Motor Inn San Patricio County, TX
Oakwilde Utility Co. Harris County, TX
Pettus Municipal Utility District
Bee County, TX
Phillips 66 Company Brazoria County, TX
Southern Sanitary Corp. Harris County, TX
Tennessee Pipeline Construction Co.
Nueces County, TX
DATE ENTERED 11/18/07
PENALTY AMOUNT
11/18/87
11/18/87
11/18/87 11/18/87 11/18/87 11/18/87
11/18/87 11/18/87 11/10/87
VIOLATIONS/REMEDIAL ACTION Exceedance of permitted 30-day average concentration for TSS.
Exceedance of permitted 30-day average concentration of BODg.
Exceedance of permitted 30-day average concentration of TSS.
Exceedance of permitted 30-day average TSS concentration.
Exceedance of permitted daily average flow.
Exceedance of permitted 30-day average concentration of BODg.
Exceedance of permitted daily average flow.
Exceedance of permitted 30-day average sulfate loading.
Exceedance of permitted daily average concentrations of BODg and TSS.
Exceedance of permitted daily average flow.
MHO01AL/155EOL
LAM 011796
DPMC-08173
ORDER NO. 00993 11593-01 10742-01 12326-01
11375-01
11504-01 12149-01
RESPONDENT
Texssgulf, Inc. Wharton County, TX
Trophy Club Municipal Utility District No. 1
Denton County, TX
Willie H. Wagner, Jr. Victoria County, TX
A. W. Walker Harris County, TX
Angleton Asphalt Corp. Brazoria County, TX
DATE ENTERED 21/10/07
PENALTY AMOUNT
ll/IB/87
11/18/87 11/18/87 11/23/87
Creekside Utilities, Inc. Harris County, TX
11/23/87
Texas Electric Cooperatives 11/23/87 Jasper County, TX
William A. Swinney Bexar County, TX
11/24/87
King Interests, Inc. of Texas
Harris County, TX
12/01/07
VIOLATIONS/REMEDIAL ACTION
Exceedance of permitted daily maximum flow.
Exceedance of permitted 30-day average concentrations of BOD^ and TSS.
Exceedance of permitted 30-day average concentration of TSS.
Exceedance of permitted 30-day average concentration of TSS.
Unauthorized discharge of oil and grease/ Construction of an appropriate treatment system and removal of all standing wastewater and oily sediment.
Exceedance of permitted daily average flow/Improvementa to treatment system.
Management of industrial wastes in such a manner as to cause a discharge or threat of discharge/Completion of RI/FS.
Failure to voluntarily cancel permit or pay annual inspection fee/Revocation of permit.
Exceedance of dally average flow discharge limltations/Completion of an engineering study and sludge management plan and upon approval, implementation of plan.
MH001AL/155E01
LAM 011797
DPMC-08174
ORDER NO. 1H43-01
10219-01 10219-02 02756 10126-01
RESPONDENT Splendors Independent
School District Montgomery County, TX Army Mr Defense Center
and Fort Bliss El Paso County, TX
City of McGregor
Arco Chemical Co. Harris County, TX
City of Bells
Cominco American, Inc. Hutchinson County, TX
DATE ENTERED 12/01/B7
PENALTY AMOUNT
Stipulated penalties
12/02/87
12/04/87 12/11/87 12/11/87
$7,500
Stipulated penalties
$1,000
12/11/87
VIOLATIONS/REMEDIAL ACTION
Exceedance of permitted 30-day average flow limit/Construction of a new wastewater treatment plant.
Management of industrial solid wastes in such a manner as to cause a discharge or threat of discharge, failure to comply with various reporting and record-keeping requirements/Closure of the fire fighter training area and compliance with reporting and record-keeping requirements.
Allowance of unauthorized bypasses of partially treated and raw sewage on several occasions/Construction of a new wastewater treatment plant.
Failure to complete construction of a stormwater management system/Modification of timetable for completion in provisions of permit.
Exceedance of permit grab sample limits for BOD and TSS concentration by allowing raw aewage to bypass the sewage treatment plant/Construction of a new treatment plant.
Discharge of industrial solid waste from the solid waste management units to the soil, surface water and groundwater without a permit/Completion of an RI/FS addressing the asnonia leak area.
MH001AL/155E01
LAM 011798
DPMC-08175
ORDER NO.
RESPONDENT
Pelican Bay Joint Venture Tarrant County, TX
DATE ENTERED 12/11/87
PENALTY AMOUNT $3,000
Safety-Kleen Wichita County, TX
12/11/87
$750
VIOLATIONS/REMEDIAL ACTION
Operation and construction of a treatment plant without a permit and discharge of untreated sewage/Obtain a permit and dispose of sewage at an authorized wastewater disposal facility for treatment until permit obtained.
Storage of containers of ignitable hazardous waste within 50 feet of the facility's property line/Alteration of site to meet setback requirements or closure of site.
MHO01AL/15SEO1
LAM 011799
DPMC-08176
AGENDA ITEM VI
ENFORCEMENT REPORT December 1987
Introduction
In accordance with the amended Texas Clean Air Act (Act), this report has been prepared and describes the status of enforcement actions initiated by the agency. Recommendations for Board Orders with administrative penalties are included on the agenda and are reflected in this report.
Enforcement Summary
Since September 1, 1987, Notices of Violation were issued to 215 companies, individuals or governmental agencies. Of these violations, 92 have been resolved. From September 1, 1985, effective date of the amended Act, a total of 96 violation situations currently remain unresolved for more than 30 days and will require formal enforcement action. Specific details for each of the unresolved situations are contained in the attached Tables. Table 4 contains a listing of 9 companies in violation which constructed small facilities without a Board permit or exemption and for which Board Orders without adminis trative penalties are being developed or recommended. The cases for which Board Orders were approved at the November Board meeting have been removed from the report.
The following summarizes administrative penalty actions by the Board since September 1, 1987.
Agreed Administrative Board Orders Entered: 46 Total of Administrative Penalties Assessed: $278,125.00
The following summarizes legal actions resolved through court orders entered since September 1, 1987.
*
Cases Settled by Attorney General: 5 Total Civil Penalties Assessed: $243,750.00
Administrative Penalty Orders
Pursuant to Sections 3.20 and 4.041 of the Act and in accordance with the Guidelines for Assessing Administrative Penalties, the staff will be presenting the Board Orders that have been finalized with the companies for consideration and action by the Board. Although Table 2 includes brief reference to those situations for which penalties are being recommended, these cases will be considered separately during the Board meeting.
LAM 011800
DPMC-08177
Page 1
TACB REGION
SOURCE CITT/COUNTT
7 Blacks Millwork Houston/Harris County
7 H. R. Grace and Company Deer Park/Harris County
8 Deal Company Oallas/Oallas County
n Carpenter Motors El Paso/El Paso County
Table 1 VIOLATIONS
Fran the September Enforcement Report (That Have Been Corrected)
TYPE Of FACILITY
Mi 1 lMort. Hotel Interiors
NOTIFICATION OATE
05/25/87
TYPE OF VIOLATION No Permit
Petrochemical Manufacturing
06/30/87
Permit Conditions
Waste Food Processing 03/10/87
Permit Representations Opacity
Used Car Sales
08/08/87
Regulation IV (Motor Vehicle Tampering)
COMMENT
The company constructed the millwork facility wlthot/ a Board permit. A Board Order without an adrainistr* tive penalty was proposed to the company; however, the owner has indicated that the company is no longi in business. The matter is considered resolved.
Stack sampling results indicate that the company's formaldehyde emissions exceed the permit allowable. The company has retested the process and the results Indicate the unit Is in compliance. The Regional Director considers the matter resolved.
The company was cited for increasing the hours of operation in violation of permit representations, l appears this situation can be resolved through perm amendment which was submitted on March 31, 1987. Tn opacity violation was issued on Nay 7, 1987. Opacii levels have been reduced as indicated by an Inspection on May 27, 1987. Since the opacity proh* lem was corrected within thirty days and only a clerical Issue remains, this matter Is considered resolved for this report.
The company was originally cited for offering for sale, vehicles with inoperative emission control devices. The vehicles were repaired Immediately. However, It was later determined that the vehicles, while on the sales lot, were not actually intended for sale. The Regional Director is recommending tiM the matter he resolved.
LAM 011801
DPMC-08178
Page 1
TACO REGION
SOURCE CITY/COUNTY
l Crown Cork and Seal Company, Incorporated
Abilene/Taylor County
TYPE OF FACILITY
Fabricated Metal Products
Table 2
VIOLATIONS
Since September I, 1985 (That Mill Continue Note Than 30 Oays)
NOTIFICATION
DATE
TYPE OF VIOLATION
09/21/8?
Board Order (87-06) NSPS*
2 American Demolition, Incorporated
Borger/Hutchlnson County
Asbestos Contractor
12/16/86
NESHAP** (Asbestos)
2 Texaco U.S.A, Klngsmil l Plant Gray County
Gas Processing
06/22/8?
NESHAP (Asbestos)
New Source Performance Standards 'National Emission Standards for Hazardous Air Pollutants
COMMENT
The company failed to submit the NSPS reports required by Board Order 87-06, A Board Order with an agreed administrative penalty of $7,800.00 will be presented to the Board for adoption if the Order is finalized with the company prior to thi hoard meeting date.
The company was cited for improper removal of asbestos at the Phillips Chemical Company facility at Borger. A formal enforcement conference was held on April 22, 1987. A Board Order with an administra tive penalty has been proposed to the company. The company has submitted additional information regard ing the actual dates of violation which is being reviewed by the Legal Division.
The company had loose asbestos on the ground in an area tdiere asbestos demolition had occurred. A formal enforcement conference was held on September 2, 1987. The Regional Director has rec<vn mended a Board Order with an administrative penalty, however, an additional analysis of the asbestos samples is being conducted prior to proceeding with development of a Board Order.
LAM 011802 DPMC-08179
Page 2
TACB REGION
SOURCE CITY/COUNTY
3 Classic Marble Company Austin/Travis County
TYPE OF FACILITY Cultured Marble
Fahle 2
VIOLATIONS
Since September 1, 19RS (That Will Continue More Than 30 Days)
NOTIFICATION DATE
07/18/87
TYPE OF VIOLATION No Permit
3 Highland Mall Joint Venture Shopping Hall
09/01/87
and
Falcon Associates
Asbestos Contractor
09/01/87
Austin/Travis County
NESHAP (Asbestos) NESKAP (Asbestos)
3 Pharaoh and Associates, Incorporated
Burton/Washington County
Oil and Gas Production
06/15/87
Nuisance (Odor) No Permit
COMMENT
The company constructed a cultured marble facility without a Board permit. Because the company had prior knowledge of the permit requirements, the Regional Oirector has recommended a Board Order witn an administrative penalty, which has been promised t, the company. The company has submitted additional information and requested that the penalty amount ho reconsidered.
The mall management was cited for improper removal o' asbestos-containing material during a renovation project, A formal enforcement conference was held m September 17, 1987. Board Orders with an agrepd administrative penalty of (4,000.00 each for the mai and the asbestos contractor will be presented to the Board for adoption if the Order is finalized with th. companies prior to the Board meeting date.
The company was cited for nuisance odors from th unauthorized venting at a gas well. A forma! enforcement conference was held on July 20, 1987, > Board Order with an administrative penally has hern proposed to the company; however, the company has no: agreed to the penalty and a review of the matter is continuing. Additional enforcement action will he recommended if an agreement cannot be re<*rhwi.
LAM 011803
DPMC-08180
Page 3
TACB REGION
SOURCE city/county
3 Pits Clad. Incorporated Temple/llel) County
TYPE OF FACILITY Wood Products
Table ?
VIOLATIONS
Since September 1, 1985 (That Will Continue More Than 30 Days)
NOTIFICATION DATE
00/13/87
TYPE OF VIOLATION Nuisance (Sawdust)
3 Structural Metals,
Painting Metal Fence 07/14/87
Incorporated
Posts
dba Southern Post Company
Austin/Trawls County
No Permit
4 Anglo Iron and Metal Company, Incorporated
Harlingen/Cameron County
Scrap Metal Shredding 08/26/87
Outdoor Running Nuisance (Smoke)
COMMENT
The company was cited (or nuisance sawdust conditni created by defective air pollution control equipme" (cyclone). A formal enforcement conference was hel on September 24, 1987. A Board Order with an administrative penalty has been proposed to the company.
The company constructed a fence painting facility without a Board permit. A formal enforcement conference was held on September 23, 1987. A Roar.i Order with an agreed administrative penalty of J750.00 will be presented to the Board for adoption if the Order 1$ finalized with the company prior to the Board meeting date.
The company was conducting outdoor burning of debn and created a nuisance smoke condition. A formal enforcement conference was held on October 9, 1987. The Regional Director has recommended a Board Order with an administrative penalty which is being developed.
LAM 011804
DPMC-08181
Page 4
Table 2 VIOLATIONS
Since September 1, 198S (That Hill Continue More Than 30 Days)
TACB REGION
SOURCE CITY/COUNTY
TYPE OF FACILITY
S American Chrome and
Chromium Chemicals
Chemicals, Incorporated
Manufacturing
Corpus Chrlsti/Nueces County
NOTIFICATION OATE
07/11/87
TYPE OF VIOLATION Opacity
S Coastal Refining and
Petroleum Refining
Marteting, Incorporated
Corpus Christi/Nueces County
10/10/87
NSPS (Monitoring and Hydrogen Sulfide Gas Content)
S Kaspar Wire Worts, Incorporated
Shiner/Lavaca County
Fabricated Hetal Products
08/04/87
Permit Conditions No Permit
COMMENT
The company was cited for eicessive opacity from the chrome hearth stack. A formal enforcement conference was held on August 3, 1987. The company submitted a proposal to Install a baghouse to reduce emissions from the hearth. The Regional Director had recom mended a Board Order with an administrative penalty. Subsequently, the company requested additional time to further evaluate its abatement plan to insure adequacy. A Board Order with an administrative penalty has been proposed to the company.
The company was cited for nine Instances of excess hydrogen sulfide In the refinery fuel gas system. A formal enforcement conference was held on November 4, 1987. The Regional Director has recommended a Board Order with an administrative penalty which is being developed.
The company was cited for an increase in production without obtaining a permit amendment. A formal enforcement conference was held on September 10. 1987. A Board Order with an administrative penalty has been proposed to the company.
LAM 011805
DPMC-08182
Page 5
Table 2 VIOLATIONS
Since September 1, 1985 (That Will Continue More Than 30 Days}
TACB REGION
SOURCE
NOTIFICATION
CITV/COUNTY__________________ TTPC OF FACILITY____________ DATE________ TTPE Of VIOLATION __________________________ COMMENT
6 Champion Chemicals, Incorporated
Odessa/Ector County
General Chemicals
03/04/87
Nuisance (Odors) Board Order
The company was cited for nuisance odors and noncompliance with Board Order No. 86-114(d). The company had refused to accept the Board Oni<*r and administrative penalty trfiich was proposed. However, the company has employed a consultant to develop an effective compliance plan. During a conference heM on October 7, 1987, the company proposed the model ling of four substances handled by the ptant for downwind nuisance potential. On Noveoter 12, 19U7, the company confirmed that additional housekeeping measures had been Implemented to reduce the potently for nuisance odors. A settlement is being negotiated.
6 0yna9en, Incorporated
Synthetic Rubber
A General Tire Subsidiary
Manufacture
Odessa/Ector County
09/30/87
Nuisance (Odor)
The company was cited for nuisance styrene odors which are attributed primarily to the ervnt- rubber dryer vents. The company has applied fo> a permit t replace the dryers and to install stacks to improve emission dispersion. A formal enforcement conferem was held on October 20. 1987. The Regional Director has recommended a Board Order with a administrative penalty which Is being developed.
LAM 011806
DPMC-08183
Page 6
TACB REGION
SOURCE CITY/COUNTY
6 Leigh Brothers Coatings Odessa/tctor County
Table 2
VIOLATIONS
Since September l, 1985 (That Will Continue More Than 30 Days)
TYPE OF FACILITY
01 Ifleld Equipment Coatings
NOT IFICATION DATE
08/05/87
TYPE OF VIOLATION
No Permit Permit Conditions Permit Representations
5 Neleh Gas Systems McCamey/Crockett County
Gas Processing
09/05/87
No Permit Permit Conditions
7 Amoco Chemicals Company
Petrochemical
Texas City/Galveston County
Manufacturing
04/14/86
Permit Conditions NESHAP (Benzene)
COMMENT
The company was cited for conducting sandblasting outdoors Instead of in a building as required by the special permit. A formal enforcement conference was held on August 13. 1987. A Board Order wuii an agreed edmlnlstratlve penalty of J2,000.(i0 will be presented to the 8oard for adoption If the Order is finalized with the company prior to the Hoard meet in date.
The company was cited for a modification of its production process that resulted in a significant increase In emissions of sulfur dioxide. A formal enforcement conference was held on October 7, 1987. The Regional Director has recommended a Hoard Order with an administrative penalty which is being developed.
The company reported that 2.400 pounds of benzene were released through a defective relief valve. The company claimed Its process was not subject to the NESHAP benzene regulation. The matter was referred to the CPA. A recent determination from the CPA Indicates the release is regulated under tin* benzene NESHAP standards. A Board Order with an agreed administrative penalty of J9.500.00 will he presenter to the Board for adoption if the Order is finalized with the company prior to the Board meeting da to.
LAM Oil807
DPKC-08184
Page 7
Table 2
VIOLATIONS
Since September 1, 1985 (That Wilt Continue More Than 30 Days)
TACB REGION
SOURCE CITY/COUNTY
7 Amoco Oi1 Company Texas City/Galveston County
TYPE OF FACILITY Petroleum Refining
7 ARCO Chemical Company
Chemical Plant
Channelvlew/Harrls County
7 A1 Cleaners Wehster/Harns County
Dry Cleaning
NOTIFICATION
DATE
TYPE OF VIOLATION
COMMENT
08/17/87
NSPS (Performance Testing) Permit Conditions
The company was found operating In violation of the NSPS monitoring requirements for carbon monoxide wilt regard to the operation of the fluid catalytic crack ing unit. A formal enforcement conference was held on September 10, 1987, The Regional Director has recomenried a Board Order with an administrative penalty. Additional violations are being consihero.I for inclusion In the Board Order.
08/08/87
NESHAP (Benzene)
The company was found in violation of several NESHAP benzene fugitive emission control provisions. A formal enforcement conference was held on September 14, 1987. The company failed to install and maintain a flame sensing device on the plant flare in benzene service as required by the NESHAP benzene regulations. A Board Order with an adminis trative penalty has been proposed to the company.
09/20/87
Regulation V (VOC***)
The dry cleaning company was operating the clothes drying -machines without the solvent recovery system operating properly. A formal enforcement conference was held on November 12. 1987. The Regional Directoi
is reviewing the matter to determine the appropriate enforcement action.
Volatile Organic Compounds
LAM 011808
DPMC-08185
Page 0
TACB REGION
SOURCE CITY/COUNTY
7 A1 Ory Cleaners Houston/Harris County
TYPE OF FACILITY Dry Cleaners
Table 2 VIOLATIONS
Since September 1, 198S {That Win Continue More Than 30 Oays)
NOTIFICATION OATE
09/19/87
TYPE OF VIOLATION Regulation V (VOC)
7 Crown Cork and Seal
Fabricated Metal
Company, Incorporated
Products
Galena Park/llarris County
02/26/87
No Permit NSPS
7 Custom Cleaners Himfele/Harrls County
Dry Cleaners
10/14/87
Regulation V (VOC)
COMMENT
The dry cleaning company was operating the clothes drying machines without the solvent recovery system operating properly. A formal enforcement conference was held on November 10, 1987. The Regional Direct is reviewing the matter to determine the appropriate enforcement action.
The company Increased production and added addition capacity to Its beverage can manufacturing facility without a Board permit and In violation uf the Federal NSPS. The legal Oivlsion completed a revt.of the matter for viability. The facility is cur rently shut down. The Board Order with an adminis trative penalty Is being revised to reflect an accelerated compliance date. An additional legal review of the NSPS Issues Is in progress.
The dry cleaning company was operating the clothes drying machines without the solvent recovery system operating properly. A formal enforcement conference was held on November 12, 1987. The Regional Hired is reviewing the matter to determine the appropriate enforcement action.
t-AM 011809
DPMC-08186
Page 9
Table 2
VIOLATIONS
Since September 1, 1985 (That Will Continue More Than 30 Oays)
TACO REGION
SOURCE
NOTIFICATION
CITT/COUNTY__________________ TYPE OF FACILITY____________ DATE________ TYPE OF VIOLATION____________________________ COMMENT
7 0 and R Metal Finishing Houston/Harris County
Sandblasting,
04/01/87
Painting and Plating
No Permit
The company constructed and continues to operate a metal finishing facility without a Board permit. Three attempts were made to deliver the violation letter before It was accepted. A formal enforcement conference was held on July 30, 1987. A Board Order with an agreed administrative penalty of Sl.5o0.00 will be presented to the Board for adoption if the Order 1$ finalized with the company prior to the Board meeting date.
7 Denka Chemical Corporation Neoprene and Maleic 10/04/87
Houston/Harris County
Anhydride Manufacture
Regulation V (VOC) NSPS Nuisance
The company was cited for violations of the Texas Clean Air Act after ambient monitoring in neighhorinu
communities revealed elevated levels of chloropren. Follow-up investigations showed additional violations of Board Rules and Regulations. A formal enforcement conference was held on October 7, 1987. The Regional Director has recommended formal enforcement action. The Director of Enforcement Is reviewing the matter to determine the appropriate type of action.
LAM 011810
DPMC-08187
Page 10
Table 2 VIOLATIONS
Since Septenfier 1, 1985 (That Will Continue More Than 30 Days)
TACO REGION
SOURCF
NOTIFICATION
CITY/COUNTY__________________ TYPE OF FACILITY____________ DATE________ TYPE Of VIOLATION____________________________ COMMENT
7 Doty Landfill Houston/Harris County
Landfill
03/16/87
Nuisance (Odors)
The company operates a landfill which has been the subject of numerous citizen complaints. A Hoard Order with an administrative penalty has been
proposed to the company. The company rr?S|>on<ipd wit additional information indicating that a consultin'] engineer has been hired to prepare a comprehensive compliance plan by December 11. 1987 which may he used to reconsider the penalty amount.
7 Exxon Chemical Americas Raytown/Harris County
Petrochemical Manufacturing
08/29/87
NESHAP (Benzene)
The company failed to install and maintain flame sensing devices on the plant flares in benzene service as required by the NESHAP-Benzene regula tions. A formal enforcement conference was held on Septedter 21, 1987. A Board Order with an adminis
trative penalty has been proposed to the company.
7 Fifty Four 0 One Oasbwood, Office Complex
Incorporated Bellaire/Marris County
07/27/87
NESHAP (Asbestos)
The company operated the building coaplex and was responsible for a renovation project in winch asbestos was improperly removed. A Board Order wit' an administrative penalty has been proposed to the company; however, an additional analysis o' the asbestos samples is being conducted. Since the sample results were disputed by the company, the Legal Division is reviewing the matter before the Order is finalized.
LAM 011811
DPMC-08188
Page U
TAC8 REGION
SOURCE CITV/COUNTY
7 Fusion, Inc. Houston/Harris County
TYPE OF FACILITY Chrome Plating
Table 2
VIOLATIONS
Since September 1, 198S (That Will Continue More Than 30 Days)
NOTIFICATION OATE
08/26/87
TYPE Of VIOLATION No Permit
7 Gulf States Asphalt Company, Incorporated
Deer Park/llarrls County
7 Hicrodot, Incorporated Houston/Harris County
Asphalt Products (With Asbestos)
Gaskets and Seals of Rubber
07/26/87
NESHAP (Asbestos)
10/24/87 ' No Permit
7 Monsanto Company Al vi n/Brazori a County
Petrochemical Manufacturing
00/10/87
NESHAP (Benzene)
COMMENT
The company constructed and continues to oi**rate a chrome plating facility without a Board (omiit. A permit application has been submitted and is under review. A Board Order with an agreed administrative penalty of 1750.00 will be presented to the Board fo adoption If the Order is finalized with the company prior to the Board meeting date.
The company was cited for visible emissions emanatinfrom a process where asphalt containing asbestos is manufactured. The utter is under review in the Legal Division to determine NESHAP applicability.
The company constructed and continues to operate a rubber seal and gasket manufacturing facility with out a Board permit. A formal enforcement conference was held on NoveAer S, 1987. The Regional Director is preparing a recommendation for appropriate enforcement action.
The company was found In violation of the NESHAPBenzene regulation regarding leak testing and cali bration of the leak test equipment. A formal enforc ment conference was held on September 28, 1987. The Regional Otrector has recommended a Board Older with an administrative penalty which is being rfc-veloped.
LAM 011812
DPMC-08189
Page 12
Table 2 VIOLATIONS
Since September 1, 1985 (That Will Continue More Than 30 Days)
TACB REGION
SOUKCC
NOTIFICATION
CITY/COUNTY__________________ TYPE OF FACILITY____________ DATE________ TYPE Of VIOLATION____________ ;_______________ COMMENT
7 Occidental Chemical Corporation
Pasadena/lUrri s County
PVC Manufacturing
03/04/87
NESHAP (Vinyl Chloride) Permit Conditions
The company reported a vinyl chloride release in violation of the NESHAP regulations. A Board Order with an agreed administrative penalty was to be presented to the Board for adoption; however, additional violations have been cited and will be Included in a revised Board Order. The legal Division Is reviewing the applicability uf the NESHA' regulation with regard to the additional violations.
7 Olshan Demolition Houston/Harris County
Landfill
03/16/87
Nuisance (Odors)
The company operates a landfill which has lee the subject of numerous odor complaints. The file has been under review by the Deputy Executive Director. A Board Order with an agreed administrative penalty of $21,750.00 will be presented to the Board for adoption If the Order is finalized with the company
prior to the Board meeting date.
7 Paktank Corporation Oeer Park/Harris County
Storage Terminal
07/15/87
NESHAP (Benzene) Board Order No. 66-ll*(i)
Penalt Conditions
The company's terminal and storage facility were found to be in violation of permit conditions and NESHAP (Benzene) moni toring and recordkeeping requirements regarding pumps In benzene service. Th company was also cited for violating a Board Order
which requires compliance with NESHAP regulations. t formal enforcement conference was held on August 3, 1987. The Director of Enforcement Is reviewing tbe matter for appropriate enforcement action.
LAM 011813
DPMC-08190
Page 13
Table 2
VIOLATIONS
Since September 1, 1985 (That Will Continue More Than 30 Days)
TACB REGION
SOURCE
NOTIFICATION
CITY/COUNTY__________________ TYPE Of FACILITY____________ DATE________ TYPE OF VIOLATION____________________________ COHHENT
Rigs R Us Houston/Harris County
Drilling Structures
03/30/87
No Permit
The company constructed and continues to operate a sandblasting and painting facility without a Board permit. A Board Order with an agreed administrative penalty of $2,000.00 will be presented to the Board for adoption if the Order is finalised with the company prior to the Board meeting date.
Te*as T* T* Marine Transportation, Incorporated
Houston/Harris County
Petroleum Coke Termi nal
01/28/87
Permit Representations Permit Conditions
The co4>any was operating a coke storage and loading facility In a manner not autltorlzed hy the Hoard pei
wit. Additional violations have been issued to the company and will be incorporated into a revised Rodi Order with an administrative penalty.
United States Postal Service
Bellaire/Harris County
U. S. Post Office
07/27/87
NESHAP (Asbestos)
The Postal Service owns an office complex which was the site of an improper asbestos renovation project. An additional analysts of the asbestos samples was conducted. A Board Order with an administrative penalty was proposed to the Postal Service, however, additional information is under review by the Legal Dtvision and the CPA to determine the appropriate enforcement action in this matter.
Wood Material aka Barbee Enterprise,
Incorporated Conroe/Hontgomery County
Asphaltic Concrete Plant
05/14/86
Opacity Perm!t Conditions NSPS (Opacity)
The coapany was found in violation of NSRs, opacity and permit conditions at the asphaltic concrete
plant. Additional odor coaqilalnts have been received and a meeting was held with the company. * Board Order with an administrative penalty was pro posed to the company; however, the company did not
agree to the Board Order. The file is being prepare,
for referral to the Attorney General's Office for lawsuit.
LAM 011814
DPMC-08191
Page M
TACB REGION
SOURCE CITY/COUNTY
8 Boney Construction Company, Incorporated
Sachse/Oallas County
TYPE OF FACILITY
Readymix Concrete Plant
Table 2 VIOLATIONS
Since September 1, 198$ (That Kill Continue More Than 30 Days)
NOTIFICATION DATE
09/30/87
TYPE OF VIOLATION
Permit Conditions Upset Reporting
8 City Wide fuels Distributors, Incorporated
Southlake/Tarrant County
Gasoline Bulk Terminal Blending Fad llty
09/19/87
No Permit
8 OKS Refining, Incorporated $11 ver Recovery Oallas/Dallas County
07/21/87
No Permit
COMMENT
The company was cited for violation of the conditi of the Standard Exemption under which it operates < to excessive dust emissions from an inofwrativ* central dust collector. The Regional Director is reviewing the matter to determine the appropriate enforcement action.
The company constructed and continues to operate a gasoline terminal and blending facility without a Board permit. A permit application has been sub mitted and is under review. The Regional Director has recommended a Board Order with an administrati penalty which is being developed.
The company relocated its Silver reclamation faci1< without a Board permit. A permit application has been submitted and is under review. The Director Enforcement is reviewing the matter for appropriat> enforcement action.
LAM 011815
DPMC-08192
P9e 1**
TACB REGION
SOURCE CITY/COUNTY
8 Flexible Foam Products Terrel 1/Kaufman County
TYPE OF FACILITY
Foam Rubber Manufacturing
Table ? VIOLATIONS
Since September 1, 1985 (That Wiil Continue Hore Than 30 Oays)
NOT IF[CATION DATE
05/05/87
TYPE OF VIOLATION No Permit
8 Ingram Enterprises Somervel! County
Readymix Concrete Plant
10/03/87
Permit Conditions
8 Larry Jones, Incorporated Cabinet Shop Arlington/Tarrant County
12/12/85
No Permit
COMMENT
The company constructed and continues to operate a foam and carpet pad manufacturing facility without a Board permit. A permit application has been submit ted and is under review. A Board Order with an agreed administrative penalty of $5,250.00 will he presented to the Board for adoption if the Order is finalized with the company prior to the Board meeting date.
The company continues to operate the facility in violation of the permit conditions due to an inoper able central dust collector. The Regional Director Is reviewing the matter to determine the appropriate enforcement action.
The company constructed a custom wooden cabinet manufacturing facility without a Board permit. A public hearing Mas held on May 26, 1987; however, no opposition attended. The Board Order on the con tested case hearing Mas entered at the July 17, 198? Board meeting and a permit was issued to the com pany. A Board Order with an agreed administrative penalty of $1,500.00 Mill be presented to the Board for adoption if the Order Is finalized with the company prior to the Board meeting date.
LAM 011816
DPMC-08193
Page 16
Table 2
VIOLATIONS
Since SepteiNier l, 198S {That Will Continue More Than 30 Days)
TACB REGION
SOURCE
NOTIFICATION
C1TY/COONTY__________________ TYPE OF FACILITY____________ DATE________ TYPE OF VIOLATION____________________________ COMMENT
B lattimore Materials Company Wet Batch Concrete
Greenvi He/Hunt County
Plant
07/06/67
Permit Conditions
8 North Texas Aggregates, Incorporated
Chico/Wise County
Portable Rock Crushing Plant
08/17/87
Permit Exemption Conditions
8 Overwraps, Incorporated Oallas/Oallas County
Flexographic Printing 0S/2S/87
No Permit
The company was cited for several provisions of < permit including heavy dust emissions and marieq. abatement equipment. A Board Order with an ayre. administrative penalty of S2.900.00 will lie pres> to the Board for adoption 1 f the Order is f mal i.with the company prior to the Board meeting darn.
The company was cited for violation of the condi tions of the exemptions irfiich Included the failur to keep in-plant roads watered and inadequate wat sprays. The company Initiated repairs on the wat spray system and the violation was thought to be resolved. Subsequent investigation revealed that water sprays were still Inadequate. A Board Orde with an agreed administrative penalty of SI.60U.il will be presented to the Board for adoption if ti> Order is finalized with the company prior to the Board meeting date.
The company constructed and continues to operate printing facility without a Board permit. A cons, tant has been hired to identify appropriate contr and prepare a permit application. The company ha proposed changes to control the emissions from tn. printing process and in addition has reqnesied th, the proposed administrative penalty be rr-cnnsuler.
LAM 011817
DPMC-08194
Page I?
Table 7
VIOLATIONS
Since September 1, 1985 (That Will Continue More Than 30 Days)
TAC8 REGION
SOURCE
NOTIFICATION
CITY/COUNTY__________________ TYPE Of FACILITY____________ OM________ TYPE OF VIOLATION____________________________ COHHENT
9 Pamarco, Incorporated Oallas/Oallas County
Printing Press Repair
06/14/87
No Permit
The company constructed and continues to operate a printing press roller refurbishing facility without Board permit. The company has submitted a i>ermit application. Initial review Indicates that the facility does not qualify as a small source. A Board Order with an administrative penalty is being developed.
i
6 Rushing Paving Company, Inc.
Sherman/Grayson County
Asphaltic Concrete Batch Plant
09/30/87
Opacity Permit Conditions
The facility has a history of violations of opacity limits and permit conditions. It was again found to be In violation for excess opacity from the scrubber stack and dust emissions from In-plant traffic. The company has Shut down the facility until corrections are completed. A Board Order with an agreed adminis trative penalty of $2,000.00 will be presented to the Board for Adoption If the Order Is finalized with tiu conpany prior to the Board meeting date.
6 Southwest Heat Exchanger
Air Conditioning
Fort Worth/Tarrant County
Condensers
08/17/87
No Permit
The company constructed and continues to operate a vapor degreaser without a Board permit. A permit application has been submitted and is under review. The Regional Director has recommended a Board Order with an administrative penalty which is being developed.
LAM 011818
DPMC-08195
Page IP
TACB REGION
SOURCE CITY/COONTY
8 Tarrant County Hospital Oistrict
fort Worth/Tarrant County
TYPE OF FACILITY Incinerator
Table 2 VIOLATIONS
Since Septenfcer 1, 1985 (That Mill Continue More Than 30 Days)
NOTIFICATION DATE
TYPE OF VIOLATION
10/05/87
No Permit
9 The Paks Corporation Junct ion/KiRt>1e County
General Chemicals
06/01/87
Nuisance (Sawdust) Opacity
COMMENT
The Hospital District was cited for operating the incinerator without a permit or exemption since the unit had not been registered under a standard exemption. The Regional Director is reviewing the matter to determine if the incinerator qualifies for Standard Exemption No. 90 and to determine the appropriate enforcement action.
The company was cited for excessive opacity from the air pollution control equipment (cyclone) and for nuisance conditions created by burning sawdust. There Is not a continuing nuisance condition created by the plant's operation. The company has determim that the scrubber proposed in their compliance plan is prohibitively expensive to o:erate and has hired consultant to evaluate other less costly controls. The Regional Director has recommended a Hoard Order with an administrative penalty which is being developed.
LAM 011819
DPMC-Qt:
Page 19
TACB REGION
SOURCE CITY/COUNTY___________
9 Powerwal1, Incorporated Poteet/Atascosa County
9 Texarome, Incorporated Leakey/Real County
Table 2
VIOLATIONS
Since September 1, 198S (That Will Continue More Than 30 Pays)
NOTIFICATION TYPE Of FACILITY______________DATE_________ TYPE OF VIOLATION_______________________________ COMMENT
Fiber Reinforced Stucco
06/29/87
No Permit
The company constructed and continues to operate th< facility without a Board permit. A formal nforcement conference was held on July 14, 1987. The development of a Board Order with an administrative penalty was delayed due to the company owner being ' the hospital and unable to submit the additional Information on capital costs needed to complete the review. The company has hired a consultant to pre pare the appropriate permit or exemption application The Regional Director has recommended a Board Order
with an administrative penalty which is being developed.
Cedar Oil Mill
04/U/87
Permit Representations Excessive Visible
Emissions
The company was cited for not constructing the plant as represented in the permit application and for excessive visible emissions. A formal enforcement conference was held on April 28, 1987. On Nove^er 17, 1987, a meeting was held in Austin to hear the company's objection to the proposed enforce ment action. After reviewing the Information pre sented by the company, a revised Board Order with an administrative penalty was proposed to tin- company.
LAM 011820
DPMC-08197
Page
TAC8 REGION
SOURCE CIT V/COUNTY
TYPE OF FACILITY
10 American Petrofina Pipeline Company
Bulk Hydrocarbon Term!nal
Port Arthur/Jefferson County
Table 2 VIOLATIONS
Since September 1, 1986 (That Will Continue Hare Than 30 Days)
NOTIFICATION DATE
TYPE OF VIOLATION
07/17/87
Nui (Odors)
10 Bright Coop, Incorporated Nacogdoches/Nacogdoches County
Wood Pallet Hanu factur1ng
07/21/86 No t
COMMENT
The company was cited for creating nuisance (odor) conditions when a gasoline storage tank overfilled and 1,600 barrels of gasoline were spilled. Adverv health effects were confirmed. A satisfactory compliance plan has been submitted to prevent forth, incidents. Additional elements of a long term compliance plan are being negotiated with the company. A Board Order with an agreed adranustrati penalty of 16,000.00 will be presented to the Goard for adaption if the Order is finalized with the company prior to the Board meeting date.
The company has increased its production rate and added manufacturing equipment over the past several years without permit authorization. A request for a permit amendment has been submitted and is under review. The regional office staff has conducted sampling to evaluate emissions from the source anti t assist in the development of a control p)a. Sampl ing conducted by the regional office staff indicate that emission levels are acceptable. The permit amendment is being processed and a Board Order with an administrative penalty is being developed.
LAM 011821
DPMC-08198
Page 2I
Table 2 VIOLATIONS
Since September 1, 1985 (That Hill Continue More Than 30 Oays)
TAC8 REGION
SOURCE CITY/COUNTY
TYPE OF FACILITY
10 Chevron U.S.A.,
Petroleum Refining
Incorporated Port Arthur/Jefferson County
NOTIFICATION OATE
09/01/8?
TYPE OF VIOLATION
Nuisance (Odors) Adverse Health impact
10 Chevron U.S.A., Incorporated
Beaumont/Jefferson County
Petroleum Refining
07/15/8?
Permit Conditions Regulation V (VOC) NSPS
10 Modern Equipment Manufacturers
luMtoerton/llardln County
Industrial Dumpster Manufacture
09/27/87
No Permit Nuisance (Oust)
COMMENT
Process upsets at the Chevron refinery caused excess emissions of uncombusted hydrocarbons and hydrogen sulfide which resulted in an air pollution episodp, including nuisance conditions and adverse health impacts. Corrections were made at the time of the incident and an acceptable plan to prevent future occurrences of this nature has been submitted. A Board Order with an administrative penalty has been proposed to the coapany.
The company was cited for failure tc conduct the annual inspections of secondary seals on the storage tanks and other violations of state and federal ml-?' regarding secondary seals on petroleum storage tanks. A Board Order with an administrative penalty has hee proposed to the company.
The regional office has received numerous complaints of odors and dust emissions from the facility's sandblasting and spray painting operations. Initial investigations did not confirm nuisance level emissions, but the company was cited for operating without a board permit. A compliance plan to control the emissions and obtain a permit was submitted. Recently, additional conplaint Investigations have confirmed that uncontrolled sandblasting emissions were creating a nuisance for the area. The Regional Director has recommended a Board Order wilh an administrative penalty which is being deviliiped.
LAM 011822
DPMC-08199
Page 22
TACB REGION
SOURCE CITY/COUNTY
10 Temple Eastex, Incorporated PIneland/Sabine County
TYPE OF FACILITY Pine Plywood
Table 2
VIOLATIONS
Since September 1, 1985 (That Will Continue More Than 30 Days)
NOTIFICATION
DATE
TYPE OF VIOLATION
04/20/87
Permit Representations
10 The Texas Pipe Line Company Storage Terminal Port Arthur/Jefferson County
10 Walters Property Jefferson County
Metal Salvage
09/28/87
Nuisance (Odors)
10/07/87
Outdoor Burning
11 Baltimore Spice Company Westway/E) Paso County
Process 1ng/Packagi ng Spices
06/03/87
No Permit
COMMENT
The company exceeded the plywood productiim rate specified In permit provisions. The Regional Director has recommended a Board Order wtlh an administrative penalty. The Director of Enforce Is reviewing the matter to determine the aiipropr enforcement action.
The company was cited for creating a nuisance du< odors from a leaking gasoline storage tank. The Regional Director has recommended a Board Order * an administrative penalty rfilch Is being dcvlop<
The Walters' have received several violations for unauthorized outdoor burning of rubber tires to salvage the metal rims. Previous enforcement situations were initially considered resolved has on commitments to cease the outdoor burning. Aec complaint investigations confirm the outdoor burn Is continuing. A Board Order with an administrat penalty is being developed.
The company was cited for construction and nperat of an ethylene oxide sterilization unit without & Board permit. A permit application has been subKitted and Is under review. A Board 0r<k.*r with * agreed administrative penalty of il.50O.im will i> presented to the Board for adoption if the Order finalized with the company prior to the Hoard mep' date.
LAM 011823
DPMC-08200
Page 23
TACB REGION
SOURCE CITY/COUNTY
n Chaparral Motors, Incorporated
E) Paso/El Paso County
n Department of Defense, U. S. Army
Fort Bllss/El Paso County
n Elcor Corporation Van Horn/Culberson County
n El Paso Refining Coejiany, Ltd.
El Paso/El Paso County
Table 2 VIOLATIONS
Since September 1, 19A5 (That Hill Continue More Than 30 Days)
TYPE OF FACILITY Used Car Sales
NOTIFICATION OATE
08/22/87
rrpf Of VIOLATION
COMMENT
Regulation IV (Kotor Vehicle Tampering)
The company mas cited for offering for sale, vehicle with inoperative emission control devices. A formal enforcement conference mas held on October 7, 1987. A Board Order mfth an administrative penalty has bee proposed to the company.
Building Renovation
07/18/87
MESHAP (Asbestos)
The Department of Defense mas cited for improper removal of asbestos at the Fort Bliss facility. Thi matter mas referred to the Attorney General's Office on Noveaber 9, 1967 for Inclusion In an existing lawsuit.
Abandoned Sulfur Plant 04/19/87
NESHAP (Asbestos)
The company mas cited for Improper removal of asbestos during the dismantling of buildings and equipment at a closed sulfur production facility. A formal enforcement conference mas held on June 2, 1987. A Board Order mlthout an administrative penalty mill be presented to the Board for adoption if the Order is finalized mith the company prior to the Board meeting date.
Petroleum Refining
06/30/67
Opacity
The company mas cited on tmo occasions for excessive visible emissions. A formal enforcement conference mas held on August 18, 1987. Corrective actions havi been completed and the company is operating in compl ance. A Board Order mith an administratwe penalty has been proposed to the company.
LAM 011824
DPMC-08201
Page ?4
TACB REGION
SOURCE CITY/COUNTT
12 Pabco Insulation Tucker/Anderson County
Table 2
VIOLATIONS
Since September 1, 1985 (That Will Continue More Than 30 Days)
TYPE OF FACILITY
NOTIFICATION DATE
Fiberglass Insulation 03/30/87
TYPE OF VIOLATION
Permit Conditions NSPS (Monitoring)
12 Prengler Iron A Metals Company
Athens/Henderson County
Metal Salvage
09/04/87
Outdoor Burning
COMMENT
The company was cited for eicessive stack emissions above permit allowables on particulates, phenol and aldehydes. Corrective Measures have been complete! A formal enforcement conference was held on August 25, 1987. The Regional 01 rector has recoMaended the Matter be referred to the Attorney General's Office for lawsutt. The matter 1$ under review In the Legal Oivision for viability.
The company conducted outdoor burning of wire Insulation, plastic pipe and debris. A formal enforcement conference was held on September 11, 1987. A Board Order with an agreed administrative penalty of $1,000.00 will be presented to the Board for adoption If the Order is finalized with the company prior to the Board meeting date.
LAM 011825
DPMC-08202
P a ge 1
Tahle 3
VIOLATIONS Since September l, 1985 (Approved Tor Referral to Attorney General's Office)
TACB REGION
SOURCE
NOTIFICATION
Cm/COUNTT____________________ TYPE OF FACILITY______________PATE
TTPE OF VIOLATION_______________________________ COME NT*
1 Bean Hog Farm Brownwood/Rrown County
Confined Animal Feedlot
U/21/B6
Nuisance (Odors) Board Order (85-12)
The file on this company was referred to the Attorn. General's Office on Nay 21, 1986. The company vio lated a Board Order issued in October, 19H5 which required a reduction in the nuntoer of animals in the feedlot and prohibited the creation of any further nuisance conditions. It ts projected that this law suit can be resolved within 1 month through agreed action.
3 Pool Production Services Company
Kervln/Freestone County
Oil Separation and Inject ton WeiJ Facility
03/23/87
Permit Conditions
The file on this company was referred to the Attorn< General's Office on October 29, 1985 for violations which occurred prior to September 1, 1985. Addi tional violations were forwarded on April 14, 19R7 for Inclusion in the lawsuit. This lawsuit is not expected to reach agreed settlement. Trial on the merits has been continued until the first week of Kerch. Depositions of company employees are scheduled for Decerf*r 16, 1987.
3 Gerald Conytany. Incorporated
Ham 1 ton County
Grain Handling
04/17/87
Nuisance (Odor)
The file on this company was referred to (he Attorn. General's Office on Septeafcer 3, 1987. lhe company
operates a feed mill rfiich has been the subject of several odor complaints and has failed tu initiate corrective actions. It is not projected that this suit can be resolved through an agreed settlement.
If settleiwnt cannot be reached and additional court action is necessary, then It may take 2 years to resolve these lawsuits.
lam om
DPMC-08203
Page /
Table 3
VIOLATIONS
Since September l, 1985 (Approved for Referral to Attorney General's Office)
TACR REGION
SOURCE
NOTIFICATION
CITf/COUNTY____________________ TYPE Of FACILITY______________OATE_________ TYPE OF VIOLATION________________________________COMMENT*
5 Oceanside Asphalt, Incorporated
Robstown/Niieces County
Portable Asphalt Plant
06/26/86
Permit Conditions Nuisance (Dust)
The company was cited for failure to water the stockpiles and roads as required In the Hoard penoti and for creating a nuisance dust condition. The Ml on this company was referred to the Attorney General's Office on May 28, 1987. H Is projected that this lawsuit can be resolved within 9 months If an agreed settlement is reached.
6 Bryson Tank Company 0iessi/ctor County
Tank Manufacturing (Spray Painting)
10/08/85
Nuisance (Paint Overspray)
The company is continuing to operate without the needed controls and the nuisance problem remains. The file on this company was referred to the AttornGeneral's Office on January 31, 1986. Ihe petition was filed on August 13, 1986. Cause was dismissed because of Inability to serve the defendant. The case may be refiled.
6 C I M Enterprises Midland/Midland County
Sandblasting
10/24/85
Nuisance (Oust) No Permit
The company has a history of violations which includ nuisance (dust) conditions. The file on this compan was referred to the Attorney General's Olfice on January 31, 1986, The Attorney General's Office filed suit against the wrong company. The lawsuit was refiled on September 24, 1987. The deposition tv the owner of the company was taken on Noveuil>er 11. 1987. It is projected that the lawsuit can be resolved within 2 months If an agreed settlement is reached.
If settlement cannot be reached and additional court action is necessary, then It may take 2 years to resolve these lawsuits.
LAM 011827
DPMC-08204
Page 3
Table 3
VIOLATIONS
Since September 1, 1985 (Approved for Referral to Attorney General's Office)
TACR REGION
SOURCE
NOTIFICATION
CITT/COUNTY____________________ TYPE Of FACILITY______________DATE_________ TYPE OF VIOLATION_______________________________ COffNT
6 Permian Chemical Company, Fertilizer Plant Incorporated
Odessa/Ector County
10/22/85
Permit Representations Permit Conditions Nuisance (Acid Emissions)
The file on this company was referred to the Attorn< General's Office on October 22, 1985 for violations occurring prior to September l, 1985. Additional vi. lations were forwarded on January 29, 1987 for inclu sion in the lawsuit. The lawsuit is not e*(>ected to reach agreed settlement. An agreed temporary injunc tion was signed by the company and sent to the Court on June 22, 1987. It requires compliance with Sections 3.27(a) and 4.01(a) of the Act anil Rules 101.7 and 111.21. Trial on the merits was continued indefinitely and a modified temporary injunction was entered on October 13, 1987 requiring the company to cease production until further order of the court. The company has filed an appeal from the October 13 Order with the Court of Civil Appeals.
7 Cuyahoga Wrecking and Corporation
5 Galveston County San Patricio County
Asbestos Contractor
07/30/86
NESHAP (Asbestos)
The file on this company was referred to the Attorm-. General's Office on Hay 8, 1987. The company con ducted asbestos removal projects at Amoco Production Company (Galveston County) and Sun Exploration (San
Patricio County) in violation of the NESHM'-Ashesios standards. The company has filed for bankruptcy. I1 is projected that the lawsuit can be resolved within 2 months if an agreed settlement is reached.
If settlenent cannot he reached and additional court action is necessary, then it may take 2 years to resolve these lawsuits.
LAM 011828
DPMC-08205
Page *
Table 3
VIOLATIONS
Since September l, 1985 (Approved for Referral to Attorney General's Office)
TAC8 REGION
SOURCE
NOTIFICATION
C1TY/C0UNTV____________________ TYPE Of FACILITY______________DATE_________TYPE OF VIOLATION_______________________________ COWENT*
7 La Porte Chemicals
Vtnyl Chloride
01/28/86
Corporation,
Monomer Production
Diamond Shamrock Corporation,
Diamond Shamrock Plastics
Corporation
Deer Park/Harris County
NESHAP (Vinyl Chloride) Permit Conditions
On June 2, 1986, the file on this company was referred to the Attorney General's Office because o' the hazardous substance involved. Additional viola tions have been periodically referred to the Atior-i General's Office for Inclusion in the lawsuit. Do October 7, 1987, an agreed final judgment was enter assessing a penalty of $120,000.00 and attorney's fees of is,000.00 against La Porte Chemicals. A
settlement with Diamond Shamrock has been reached; , agreed final judgment Is being prepared.
7 Tenneco Polymers, Incorporated
Pasadena/Harris County
Chemical Manufacturing 10/24/86 (Vinyl Chloride)
NESHAP (Vinyl Chloride) Permit Conditions
On December 31, 19BS, the file on this company was
referred to the Attorney General's Office because o' the hazardous substance Involved. The co<npany sold its vinyl chloride plant In April, 1986. Further settlement negotiations took place on July 1, 1987. A tentative settlement was reached on July l, 1987. An agreed final judgment Is being drafted.
7 Teas City Refining,
Refinery
Incorporated
Tea$ City/Galveston County
06/26/86
Permit Provisions NSPS (High Sulfur Crude)
The file on this company was referred to the Attorn. General's Office on July 12, 1983. Subs-nuent vio lations have been periodically forwarded in the Attorney General's Office for inclusion in the lawsuit. It is projected that this lawsuit can be resolved within 2 months If an agreed settlement is reached.
If settlement cannot he reached and additional court action Is necessary, then It may take 2 years to resolve these lawsuits.
LAM 011829
DPMC-08206
Page 5
Table 3 VIOLATIONS
Since September 1, 1985 (Approved for Referral to Attorney General's Office)
TACB REGION
SOURCE CITV/COUNTT_____________
NOTIFICATION TYPE OF FACILITY______________ DATE_________TYPE Of VIOLATION_______________________________ COMMENT*
7 Union Carbide Corporation Chemical Manufacturing 02/16/86 Texas City/Galveston County
NESHAP (Vinyl Chloride and Benzene)
The file on this company mas referred to the Attorn. General's Office on March 18, 1986. Additional vio lations Nave been periodically included in the law suit. The company has signed and returned the proposed final judgment with a check for civil penalties. On November 23, 1987, an agreed final judgment was entered assessing a penalty of $38,500.00 and attorney's fees and Investigative costs of $5,000.00.
B Brandyvtlde Development Corporation
Valley View/Cooke County
Rock Crushing Plant
09/18/BS
Permit Conditions
The company has a history of violations beginning in 1983 when H constructed without a Board permit. Tn.
file on this company was referred to the Attorney General's Office on February 4, 1986. H is pro jected that this lawsuit can be resolved within 2 months If an agreed settlement Is reached. An agrer judgment was mailed to the defendant for signature < early February by certified mail but was apparently lost in the mall. Another agreed judgment was mail*to the defendant on March 16, 1987. Settlement negn tlations have not achieved an agreement. Interrog atories were sent to the company and answered in June, 1987. The company is no longer operating at the site.
If settlement cannot be reached and additional court action is necessary, then it may take 2 years to resolve these lawsuits.
LAM 011830
DPMC-08207
Page 6
Table 3
VIOLATIONS
Since September 1, 1985 (Approved for Referral to Attorney General's Office)
TAC8 REGION
SOURCE
NOTIFICATION
CITY/COUNTY____________________ TYPE OF FACILITY______________DATE_________ TYPE Of VIOLATION_______________________________ COMMENT*
8 Willie Grant Tarrant County
Individual
02/21/86
Outdoor Burning Court Order
A judgment was entered against this individual on May 31, 1986 prohibiting future violations of Regulation I. An additional violation of unautho rized burning has since been documented. The file was referred to the Attorney General's Office on Hay 16, 1986. It Is projected that this contempt action cannot he resolved by agreement.
10 Great lakes Carbon
Carbon Plant
Corporation
Port Arthur/Jefferson County
09/27/86
Opacity Excessive Particulate
Emissions Permit Conditions
The file on this company was referred to the Attorn. General's Office on September 27, 1986 for violatin' occurring prior to September 1, 1986. Subsequent violations were forwarded to the Attorney General fo Inclusion In the lawsuit. Sampling is needed befor. injunctive relief can be drafted. The strike at tn. plant has recently ended. Resampling was conducted on March 9, 1987. The resampling Indicate*! continu ing violations which were forwarded to the Attorney General on June 18. 2987. A settlement meeting was held with the company on November 6, 1987. A follm up meeting is scheduled for Oecember 17, 1987 to
discuss a possible compliance plan. It is projected that this lawsuit can be resolved within 6 months << an agreed settlement is reached.
If settlement cannot be reached and additional court action is necessary, then it may take 2 years to resolve these lawsuits.
LAM 011831
DPMC-08208
Page 7
Table 3
VIOLATIONS
Since September 1, 1985 (Approved for Referral Co Attorney General's Office)
TACB REGION
SOURCE
NOTIFICATION
C1TY/C0UNTY____________________ TYPE OF FACILITY______________ DATE
II Department of Defense,
Building Renovation
U. S, Army
Katyear Construction Company
Pioneer Sheet Hetal Wnrts,
Incorporated
Fort Bliss/El Paso County
09/17/85
1? Dallas OemolItlnn and Excavating Company
Tyler/Smith County
Building Demolition
09/16/85
TYPE OF VIOLATION_______________________________ COMMENT*
NESHAP (Asbestos Removal)
The file on the Army and the two companies was referred to the Attorney General's Office on April > 1986 for legal action because of the hazardous sub stance involved. On July 17, 1987, an agr**d final judgment was entered by the court resolving the vio lations against Matyear and Pioneer. Civil penal tm of S6.000.00 were assessed and the companies were prohfbitorily enjoined from violating Role 101.20(2} in the future. Notice of intent to sue the Depart ment of Defense is being drafted. The lawsuit against the Department of Defense will be filed in Federal court. It is not projected that the suit ca> be resolved through an agreed settlement. An additional violation was referred to the Attorney General's Office on Novenfcer 9, 1987 for inclusion i the lawsuit.
NESHAP (Asbestos Removal)
The excavating company was In the process of readym
a building for Implosion without proper notification and handling of asbestos. This lawsuit is not expected to reach agreed settlement. Interrogator)?' were sent to the company In June, 1987 aivi answers t< interrogatories were received on June 20, l98?.
If settlement cannot be reached and additional court action is necessary, then it may take 2 years to rpsolvr these lawsuits.
LAM 011832
DPMC-08209
Pag* 8
Table 3
VIOLATIONS
Since September 1, 1985 (Approved for Referral to Attorney General's Office)
TACB REGION
SOURCE
NOTIFICATION
CITY/COUNTY____________________ TYPE OF FACILITY______________DATE_________ TYPE OF VIOLATION_______________________________ COMMENT*
12 Poly Cycle Industries, Incorporated
Tecula/Cherokee County
Battery Case RecycIing
02/19/86
Permit Conditions Permit Representations
Poor maintenance and cleaning practices at the com pany's battery case recycling facility have results in high lead concentrations in the soil near the grinding process. Additional samples taken confirmr.i the high lead levels in the soil. The file on this company was referred to the Attorney General's Offic. on October 22. 1986. Settlement negotiations took place in March. 1987. Another settlement meeting w . held on July l, 1987. It Is projected that this laxsuit can be resolved within 3 months if an agreed settlement is reached. A proposed closure plan has been submitted to the agency for review nf clean-up plans.
12 Southwest Railroad
Railcar Salvage
and Car Parts
3 Jacksonvi 1 le/Cherokee County
Jewett/Leon County
03/18/66
Outdoor Burning Nuisance (Smoke)
The file on this company was referred to the Attorney General's Office on July 12, 1985 for violations occurring prior to September 1, 1985 at two different sites. Subsequent violations have
been forwarded to the Attorney General for inclusion In the lawsuit. Since the defendant's attorney is a state legislator, settlement may not be possible until the fall of 1987. The Attorney General has requested a settlement meeting with the company in Noveatoer or Oecember, 1987.
If settlement cannot be reached and additional court action is necessary, then it may take 2 years to resolve these lawsuits.
LAM 011833
DPMC-08210
Page 9
Table 3 VIOLATIONS
Since September 1, 1985 {Approved for Referral to Attorney General's Office)
TAC8 REGION
SOURCE
NOTIFICATION
CITT/COUNTY____________________ TYPE OF FACILITY_____________ DATE_________TYPE OF VIOLATION_______________________________ COMMENT*
1? Texas Basic Resources Overton/Rusk County
Grain Transfer
04/04/86
No Permit Nuisance (Oust)
The file on this company was referred to the Attorney General's Office on March 6, L9H7 for constructing and operating a grain transfer facility without a Board permit. It Is projected that this lawsuit can be resolved within 9 months if an agreed settlement Is reached. The lawsuit was filed on June 17, 1987 and the defendant was served on June 29, 1987.
If settlement cannot be reached and additional court action is necessary, then U may take 2 years to resolve these lawsuits.
LAM 011834
DPMC-08211
Page I
Table 4 VIOLATIONS On Small Sources With No Permit
The following co^anies constructed end operated small facilities without Board permits or exemptions. The companies indicated no prior knowledge of the permitting requirements and had no previous permit violations. Applications have been submitted. Board Orders without administrative penalties will be presented to the Board for adoption if the Order Is finalized prior to the Board meeting date. The Board Orders require the companies to obtain permits or exemptions.
REGION l 7 7 7 8 6 9
SOURCE CITY/COUNTY
TYPE Of FACILITY
Bethanla Regional Health Care Center Wichita Falls/Wichita County
Incinerator
Intermedics, Incorporated Brazorta County
Medical Equipment
K T Bolt and Galvanizing Katy/Harris County
Galvanized Bolts
Packaging Service Company, Incorporated Harris County
Repackaging Chemicals and Solvents
Augat Elfab Lewisville/Denton County
Printed Circuit Board Manufacturing
BASF Corporation CarrolIton/Dallas County
Urethane Blending Plant
Oe Los Santos Ready Nix Eagle Pass/Haverick County
Ready Nix Concrete
NOTIFICATION DATE
07/27/87 06/24/87 09/26/87 07/26/87 06/23/87 07/31/87 04/22/87
LAM 011835
DPMC-08212
Pag* 2
Table 4 VIOLATIONS On Snail Sources With No Penalt
The following companies constructed and operated snail facilities without Board pemits or exemptions. The conpanies Indicated no prior knowledge of the permitting requirements and had no previous permit violations. Applications have been submitted. Board Orders without administrative penalties will be presented to the Board for adoption if the Order Is finalized prior to the Board meeting date. The Board Orders require the companies to obtain permits or exemptions.
REGION 9
11
SOURCE CITY/COUNTY
Bay Ellison Industries San Antonio/8exar County
Horizon Retread Center El Paso/El Paso County
TYPE OF FACILITY Cultured Marble
Tt re Retread!ng
NOTIFICATION DATE
06/08/87
08/03/87
LAM 011836
DPMC-08213
ADMINISTRATIVE PENALTIES AND ORDERS OF THE TEXAS AIR CONTROL BOARD
ORDER MO. 87-11 (at <7-11(bl
87-11(c)
87-11(d) 87-11(e) 87-11(f) 87-11(g)
RESPONDENT
Augat Elfab 1097 Yates Lewisville, TX
Bethania Regional Health Care Center
1600 11th Street Wichita Palls, TX
Coastal Refining and Marketing, Inc.
1300 Cantwell Lane Corpus Christ!, TX
Elcor Corporation Culberson County, TX
falcon Associates Travis County, TX
Fusion, Inc. 6911 Fulton Houston, TX
Highland Mall Joint Venture
Travis County, TX
DATE ENTERED 12/18/87
PENALTY AMOUNT
VIOLATIONS/REMEDIAL ACTION
Construction and operation of a board manufacturing facility without a permit
12/18/87 12/18/87
12/18/87 12/18/87 12/18/87
$325 if sub stantial addi tional controls necessary
$4,000 $750
Construction of a hospital pathological incinerator without a permit
Excessive odor emissions from a coker unit/Continued implementation of interim compliance plan, implementation of the Delayed Coker Blowdown Vapor Control Procedure, records maintenance
Violation of NESKAP established for asbestoa/Cos^liance by properly disposing of asbestos-containing materials
Violation of MBSHAP established for asbestos
Construction and operation of two chrome plating tanks without a permit
12/18/87
$4,000
Violation of NESHAP established for asbestos
MH001AK/155E01
LAM 011837
DPMC-08214
ORDER NO. 8 7 -11 (h)
07-11 U) 87-ll( j) 87-ll<k;l
87-11(1)
RESPONDENT
Larry Jones, Inc. 7900 Valcasi Arlington, TX
DATE ENTERED 12/18/87
Lattimore Materials Co. 3033 Spencer Street Greenville, TX
Leigh Brothers Coating 2720 West 81st Odessa, TX
Prengler Iron & Metals Co. Henderson County, TX
12/18/87 12/10/87 12/18/87
PENALTY AMOUNT 81,500 over a six-month period
$2,900
$2,000 over a six-month period $1,000
Rushing Paving Co., Inc. 6102 Theresa Drive Sherman, TX
12/18/87
<2,000
VIOLATIONS/REMEDIAL ACTION
Construction and operation of a woodworking facility without a permit
Violation of special provisions of permit
Outdoor sandblasting in violation of special permit
Outdoor burning of wire insulation, various plastics, cable wire and debris/ Implementation of fire prevention procedures
Exceedance of 20% opacity limit for visible emissions and failure to comply with special provision of permit/ Cessation of operation of plant pending development and implementation of effective abatement measures
MH001AK/155E01
LAM 011838
DPMC-08215
/ //
/
AGENDA ITEM VI
ENFORCEMENT REPORT November.1987
Introduction
In accordance with the amended Texas Clean Air Act (Act), this report has been prepared and describes the status of enforcement actions initiated by the agency. Recommendations for Board Orders with administrative penalties are included on the agenda and are reflected in this report.
Enforcement Summary
From September 1, 1985 effective date of the amended Act, through August 31, 1986, Notices of Violation were issued to 1,304 companies, individuals or governmental agencies. From September 1, 1986 through August 31, 1987, Notices of Violation were issued to 1,193 companies, individuals or governmental agencies. Of these violations, 2,184 have been resolved. A total of 117 violation situations currently remain unresolved for more than 30 days and will require formal enforcement action. Specific details for each of the unresolved situations are contained in the attached Tables. Table 4 contains a listing of 14 companies in violation which constructed small facilities without a Board permit or exemption and for which Board Orders without adminis trative penalties are being developed or recommended. The cases for which Board Orders were approved at the September Board meeting have been removed from the report.
The following summarizes administrative penalty actions by the Board since September 1, 1987.
Agreed Administrative Board Orders Entered: 17 Total of Administrative Penalties Assessed: $29,400.00
The following summarizes legal actions resolved through court orders entered'si nee September 1 , 1987.
Cases Settled by Attorney General: 2 Total Civil Penalties Assessed: $85,000.00
Administrative Penalty Orders
Pursuant to Sections 3.20 and 4.041 of the Act and in accordance with the Guidelines for Assessing Administrative Penalties, the staff will be presenting the Board Orders that have been finalized with the companies for consideration and action by the Board. Although Table 2 includes brief reference to those situations for which penalties are being recommended, these cases will be considered separately during the Board meetina.
LAM 011839
DPMC-08216
Page 1
Table 1
VIOLATIONS
Fran the September Enforcement Report (That Have Been Corrected)
TACB REGION
SOURCE
NOTIFICATION
CITY/COUNTY____________________ TYPE Of FACILITY______________DATE_________ TYPE OF VIOLATION_______________________________ COMMENT
2 Nix Electric Company tubbock/lubbock County
Transformer Repair
04/17/87
Nuisance (Odor)
The transformer repair facility was cited for nui sance odors from the burnout oven and the painting operation. A formal enforcement conference was hel on July 7, 1987. Since no additional violations he been confirmed and the company appears to he operating in compliance, this matter Is considered resolved.
1 Acne Brick Company Sealy/Austln County
Brick Manufacturing
07/12/87
Permit Conditions Regulation III
(Hydrogen Fluoride)
Stack sampling results indicated that hydrogen fluoride emissions exceeded the permit allowable, formal enforcement conference was held on August in 1987. The violation was resolved with a permit amendment on September 14, 1987 and no additional control equipment was required.
7 Ash Lake Sand and Gravel Incorporated
Sprlng/Hontgomery County
Soil Stabilization Plant
05/24/87
Exception Conditions
The company constructed and continued to operate a soil stabilization facility without a Board permit. The matter was initially considered for a Hoard Order; however, an additional review by the legal Division concluded a Standard Exemption was applicable, and the matter is resolved.
7 Asphalt for Roofing Dayton/llberty County
Roofing Asphalt
07/06/87
Permit Conditions Permit Representations NSPS*
The company was found In violation of NSPS and perm provisions at the asphalt blowing facility. A fon:i enforcement conference was held on July 13, 1987. Additional sampling conducted indicated the faciht. was operating In compliance. The Regional Director considers the matter resolved.
hew Source Performance Standards
LAM 011840
DPMC-08217
Page 7
Table 1
VIOLATIONS
Fran the September Enforcement Report (That Have Been Corrected)
TACB REGION
SOURCE
NOTIFICATION
CITY/COUNTY____________________ TYPE Of FACILITY______________DATE_________ TYPE OF VIOLATION________________________________COMMENT
7
Intercontinental Terminals
Storage Terminal
Company
Deer Park/Harris County
07/22/87
MESHAP (Benzene)
The company Mas using an unauthorized gas for cal bratlng Its leak detection instruments. Ihe subs tution is not allowed ynder the NESHAP-Benzene regulation. The company has requested authorizat from EPA to use the gas. This matter is consider clerical and resolved for this report.
7 Sisson Paper Company Pasadena/Harris County
Paper Manufacture
06/14/87
Court Order
The paper mill was operating in violation of the Court Order with regard to total reduced sulfur emissions. A formal enforcement conference was he on July 21, 1987. Since the Court Order cited wa issued to the prior owner, a legal viability was requested in this matter. The Legal Division determined that it is inappropriate to enforce th Court Order Issued to the previous owner.
8 Burrus Foods Sanger/Denton County
Grocery Store (Incinerator)
07/06/87
Permit Conditions
The company was observed operating Its incinerato without the afterburner in service in violation o the conditions of the permit exemption. The faci was reinspected and found in compliance. The Regional Director considers the matter resolved.
8 Hardcast, Incorporated Wylie/Collin County
Adhesives and Sealants 05/12/87
No Permit
The company constructed and operated the facility without a Board permit. The facility has been so' to the Carbide Corporation and shut down. The Regional Director considers the matter resolved w regard to Hardcast, Incorporated. An inspection 1 scheduled to confirm the compliance status of the owner.
National Emission Standards for Hazardous Air Pollutants
LAM 011841
DPMC-08218
Pa^ 3
TACB REGION
SOURCE CITY/COUNTY
8 Research Polymers International
Grand Prairie/ Tarrant County
ft Source Lumber Systems ,
International Joshua/Johnson County
8 USA 1 Oallas/Oallas County
TYPE OF FACILITY
Plastics Material Compounds
Table 1 VIOLATIONS
from the September Enforcement Report (That Have Been Corrected)
NOTIFICATION DATE
06/14/87
TYPE OF VIOLATION Permit Provisions
Woodworking
06/28/87
No Permit
Fiberglass Products
07/12/87
Permit Conditions
9 Hestex Aromatics, Incorporated
Leakey/Real County
Cedarwood Olstlllery
04/04/87
Opacity
COMMENT
The company added manufacturing processes to the facility without amending its permit. Since addi tional controls are not required and a permit amend ment is under review, the matter is considered resolved.
The company relocated its facility without jmtmii t authorization. The operation has ceased and the Regional Director considers the matter resolved.
The company constructed the fiberglass products manufacturing facility without a permit. A reinspition found the facility had been sold and was shut down. The Regional Director considers the matter resolved.
The company was cited for excessive opacity from th boiler stack. Firebox changes were made m an attempt to Improve combustion but this was uusucces ful. On July 27, 1987, the company notified us of change fn management and comnitted to providing a compliance plan with sped Me remedies in the near future. A recent fire has caused the plant to ceas operation for the Interim. The matter is, consider.resolved providing the facility is restarted in compliance.
LAM 011842
DPMC-08219
Page <
TACB REGION
SOURCE CITY/COUNTY
9 US Brick, Incorporated Elmendorf/Bexar County
Table 1 VIOLATIONS
From the Septet>er Enforcement Report {That Have Been Corrected)
TYPE OF FACILITY Brick Manufacturing
NOTIFICATION DATE
TYPE OF VIOLATION
04/06/87
Permit Conditions Fluoride Emissions
10 Texaco Refining and
Petroleum Refining
Market log, Incorporated
Port Arthur/Jefferson County
07/01/87
Permit Conditions NSPS
12 Trinity Industries longview/Gregg County
Steel Fabrication (Hopper Cars) (Sandblasting and Spray Painting)
10/28/86
No Permit
COMMENT
Tbe company was cited for exceeding the permit alio. able for emissions of fluorides. The company con tended the violation was invalid which delayed the submittal of an acceptable compliance plan. A form enforcement conference was held on July 21, 1987. Tbe Legal Division is evaluating tbe company's positioo as outlined in Us August 10, 1987 letter. Since this matter is expected to he resolved with a permit amendment requiring no additional control equipment, the Issues are considered clerical and resolved for this report.
The company was cited for failure to conduct perfon ance tests on two process units as required by the NSPS rules and permit conditions. A company reques for waiver of the requirement for performance testi' has been evaluated and a recommendation will be for warded to EPA asking that a waiver be granted. If tbe initial review indicates a waiver can h? grants this matter will be resolved for this report.
The company started construction on a spray pjmtin facility without a Board permit. A permit and a permit amendment have since been issued to tb.> company and the matter is considered resolved.
LAM 011843
DPMC-08220
Page 1
Table 2 VIOLATIONS
Since September l, 1985 (That Util Continue More Than 90 Days)
TAC8 REGION
SOURCE
NOTIFICATION
CITt/COUNTY____________________ TYPE OF FACILITY______________DATE_________ TYPE OF VIOLATION_______________________________ COMMENT
I K G Gas Processors, Ltd. Winters/Runnels County
Gas Processing
07/05/87
Permit Conditions N5PS
The company failed to submit the emission reports required by NSPS on gas processing facilities. A Board Order with an agreed administrative penalty of $500.00 will be presented to the Board for adoption If the Order is finalized with the company prior to the Board meeting date.
2 Amarillo By-Products AmarlUo/Potter County
Rendering Plant
09/08/86
Nuisance (Odor) Permit Conditions No Penal t Maintenance Reporting
The company Installed a larger capacity cooker with out a Board permit. Odors from unprocessed material' stored outdoors *4iile the cooker was being replaced created nuisance conditions for the area. A permit application has been submitted and is under review. A Board Order with an agreed Administrative penalty of $13,000.00 will be presented to the Board for adoption if the Order is finalized with the company prior to the Board meeting date.
2 American Demolition,
Incorporated Borger/Hutchlnson County
Asbestos Contractor
12/16/86
NESHAP (Asbestos)
The coapany was cited for improper removal of asbestos at the Phillips Chemical Company facility at Borger. A formal enforcement conference was held on April 22, 1907. A Board Order with an administra tive penalty has been proposed to the company. The company has submitted additional information regard ing the actual dates of violation which is h*ing reviewed by the Legal Division.
Lam oi1844
DPMC-08221
Page 2
Table 2 VIOLATIONS
Since September 1, 1985 (That Will Continue More Than 30 flays)
TACB REGION
SOURCE
NOTIFICATION
CITY/COUNTY____________________ TYPE OF FACILITY______________DATE_________ TYPE OF VIOLATION
2 Perryton Equity Exchange Claude/Armstrong County
Grain Storage
05/07/87
No Permit
2 Phillips 66 Company Borger/Hutchinson County
Chemical Manufacturing 12/16/86
NESHAP (Asbestos)
2 Texaco U.S.A. Kingsmi 11 Plant Gray County
Gas Processing
06/22/87
NESHAP (Asbestos)
COMMENT
Thu company constructed ami continues to operate a grain elevator without a Board permit. A Hoard Orj with an agreed administrative penalty of $3,175.00 will be presented to the Board for adoption if the Order is finalized with the company prior to the Board meeting date.
The company was cited for improper removal of asbestos during the dismantling of buildings and equipment at the chemical manufactjring facility. The Job was contracted to American Demolition, Incorporated. Additional samples were taken from a second location on the property and tested positive for asbestos. The Regional Director has recmwnende that the violations at both sites on the Borger facility be addressed with a single Board Order wit an administrative penalty. A Board Order with an agreed administrative penalty of $175,000.00 will b. presented to the Board for adoption if the Order Is finalized with the company prior to the Board meeti date.
The company had loose asbestos on the ground in an area where asbestos demolition had occurred- A formal enforcement conference was held on September 2, 1987. The Regional Director has recom mended a Board Order with an administrative penalty however, an additional analysis of the asbestos samples is being conducted prior to proceeding with development of a Roard Order.
LAM 011845
DPMC-08222
Page 3
TACB REGION
SOURCE CITT/COUNTY
3 Classic Marble Company Austin/Travis County
TYPE Of FACILITY Cultured Marble
Table 2
VIOLATIONS
Since September 1, 1965 (That Mill Continue More Than 30 Days)
NOTIFICATION DATE
07/1B/87
TYPE Of VIOLATION No Permit
3 Henry Whited Austin/Travis County
Copper Wire Recycling 07/01/87
Outdoor Burning
3 Pharaoh and Associates, incorporated
Burton/Washington County
Oil and Gas Production
06/15/87
Nuisance (Odor) No Permit
COMMENT
The company constructed a cultured marble facility without a Board permit. Recause the company had prior knowledge of the permit requirements, the Regional Director has recommended a Roard Order wit' an administrative penalty. A Board Order with an agreed administrative penalty of $800.00 wilt be presented to the Board for adoption If the Order is finalized with the company prior to the Board meetti date.
The individual was cited for unauthorized outdoor burning of insulation from copper wire. A Board Order with an agreed administrative penalty of 1250.00 wi 11 be presented to the Board for adoption if the Order Is finalized with the individual prior to the Board meeting date.
The company was cited for nuisance odors from the unauthorized venting at a gas weli. A forma 1 enforcement conference was held on July 20, ly87. Board Order with an administrative penalty has been proposed Co the company.
LAM 011846
DPMC-08223
Page 4
TAC8 REGION
SOURCE CITY/COUNTY
3 Plas Clad, Incorporated Temple/Bell County
TYPE OF FACILITY Wood Products
Table 2
VIOLATIONS
Since September 1, 1985 (That Will Continue More Than 30 Days)
NOTIFICATION DATE
TYPE OF VIOLATION
08/13/87
Nuisance (Sawdust)
3 Southwest Railroad Car Parts
Jewett/Leon County
Metal and Wood Salvage
05/03/87
Permit Conditions
Opacity Outdoor Burning
3 Structural Metals, Incorporated
Austin/Travis County
Painting Metal Fence Posts
07/14/87
No Permit
C0M4ENT
The company was Cited for nuisance sawdust condition created by defective air pollution control equipment (cyclone). A formal enforcement conference was hel<l on Septert>er 24, 1987. The Regional Director has recommended a Board Order with an administrative penalty which fs being developed.
The company was cited for outdoor burning, excessive visible emissions and for failure to comply with the Board permit exemption conditions at Its railcar incineration operation. A formal enforcement confer ence was held on August 20, 1987. Process changes and *odificatlons were developed and Implemented to bring the facility into compliance on the opacity an the permit conditions. A follow-up Investigation is scheduled to confirm the compliance status. The outdoor burning violation Is being forwarded to the Attorney General's Office for Inclusion lo an exist ing lawsuit.
The co<m>any constructed a fence painting facility without a Board permit. A formal enforcement conference was held on September 23, 1987. A hoard Order with an administrative penalty has bwrn proposed to the company.
LAM 011847
DPMC-08224
Page 5
TACB REGION
SOURCE CITY/COIINTY
4 Anglo Iron and Metal Company, Incorporated
Harlmgen/Cameron County
Table 2 VIOLATIONS
Since September 1, 1905 (That Will Continue More Than 30 Days)
TYPE Of FACILITY
NOTIFICATION DATE
TYPE OF VIOLATION
Scrap Metal Shredding 08/26/87
Outdoor 8urn1ng Nuisance (Smoke)
5 Amerada Hess Corporation
Oil Refinery
Corpus Christl/Nueces County (Closed)
06/23/87
NESHAP (Asbestos)
5 American Chrome and
Chromium Chemicals
Cheat cals, incorporated
Manufacturing
Corpus Chrtstl/Nueces County
07/11/817
Opiclty
COMMENT
The company was conducting outdoor burning uf debris and created a nuisance smoke condition, A formal enforcement conference was held on October 9, 1987. The Regional Director will complete a review of the company's compliance plan prior to submitting a recommendation for appropriate enforcement action.
The company was cited for improper removal of asbestos Insulation during demolition of the oil refinery. A formal enforcement conference was held on June 30, 1987. A Board Order with an agreed administrative penalty of $7,000.00 will he present' to the Board for adoption If the Order is finalized with the com? my prior to the Board meeting date.
The company was cited for excessive opacity from th< chrome hearth stack. A formal enforcement conferenc was held on August 3, 1987. The company submitted < proposal to Install a baghouse to reduce emissions from the hearth. The Regional Director had reconmended a Board Order with an administrative penalty. Subsequently, the company requested additional time to further evaluate Us abatement plan to insure adequacy. A proposed Board Order is now being final1 red.
LAM 011848
M'HC-08225
Page 6
ZTable
VIOLATIONS
Since September 1, 1985 (That Win Continue More Than 30 Days)
TACR REGION
SOURCE cjty/county
TYPE OF FACILITY
5 Formosa Plastics
Plastics Manufacture
Corporation Texas
Point Comfort/Calhoun County
NOTIFICATION OATE
TYPE OF VIOLATION
06/14/07
NESHAP (Vinyl Chloride)
5 Caspar Wire Works. Incorporated
Shiner/Lavaca County
Fabricated Metal Products
08/04/87
Permit Conditions No Permit
S
Universal Tubular Services
Pipe Facility
Incorporated
aka ICO. Incorporated
Corpus Chrlsti/Nueces County
03/11/87
No Permit
COMMENT
The company was cited for a relief valve release oi vinyl chloride. A formal enforcement conference wa held on July 7, 1987. At th* company's request, t'1 violation circumstances were reevaluated. A Board Order with an agreed administrative penalty of $2,700.00 will be presented to the Board for adopt' if the Order is finalized with the company prior to the Board meeting date.
The company was cited for an Increase in production without obtaining a permit amendment. A formal enforcement conference was held on September 10, 1987. The Regional Director has recommended a Boar Order with an administrative penalty which is hein-., developed.
The company was cited for increasing production without a Board permit. A formal enforcement conference was held on March 20, 1987. Th-> company will provide additional Information on the propose' abatement equipment and has requested that the penalty amount be reconsidered. A Board Order with an agreed administrative penalty of $3,800.00 wi11 presented to the Board for adoption If the Order is finalized with the company prior to the Board meet' date.
LAM 011849
DPMC-08226
Page 7
table 2 VIOLATIONS
Since September 1, 1985 (That Hill Continue More Than 30 Oays)
TACB REGION
SOURCE
NOTIFICATION
eiTY/COUNTV____________________ TYPE OF FACILITY______________DATE
TYPE OF VIOLATION_______________________________ COMMENT
6 Champion Chemicals, Incorporated
Odessa/Ector County
General Chemicals
03/04/87
Nuisance (Odors) Hoard Order
The company was cited for nuisance odors and noncompliance with Board Order No. 86-l)4(d). The company had refused to accept the Board Or.W and administrative penalty which was propose!. Mowevei the company has employed a consultant to develop an effective compliance plan. Ouring a conference hel on October 7, 1987, the company proposed the model ling of four substances handled by the plant for downwind nuisance potential. A settlement will bo negotiated after the plan has been submitted and approved.
6 Farmland Industries,
Incorporated Irion County and
Schleicher County
Natural Gas Processing 07/27/07
No Permit
The company was cited for adding and modifying equipment at each of three plant sites wittiout obtaining a permit or permit amendments. The viola tions were self-reported. A format enforcement conference was held on August 11, 1987. A hoard Order with an agreed administrative penalty of S4.2S0.00 will be presented to the Board for adopts If the Order Is finalized with the company prior to the Board meeting date.
6 Leigh Brothers Coatings Odessa/Ector County
Oilfield Equipment Coatings
08/05/87
No Permit Permit Conditions Permit Representations
The company was cited for conducting sandblasting outdoors instead of in a building as required by t'i. special permit. A formal enforcement conference wa held on August 13, 1987. The Regional Director has recommended a Board Order with an administrative penalty which is being developed.
LAM 011850
DPMC-08227
Page 8
TACB REGION
SOURCE city/county
6 Neleh Gas Systems HcCamey/Crockett County
TYPE OF FACILITY Gas Processing
2Table
VIOLATIONS
Since Septenrter 1, 1985 (That U1M Continue More Than 30 Days)
NOTIFICATION DATE
TYPE OF VIOLATION
09/05/87
No Permit Permit Conditions
7
Alonzo's Concrete Company
Concrete Batch Plant
05/31/87
Pasadena/Harris County
No Permit
7 Amoco Chemicals Company
Petrochemical
Texas Ctty/Galveston County
Manufacturing
04/14/86
Permit Conditions NESHAP (Benzene)
COMMENT
The napeuj mas cited for a modification of Us produotien process that resulted In a significant increse ta emissions of sulfur dioxide. A formal enfornmeat conference was held on October 7, 1987. The fUgJonal 01 rector has recommended a hoard Order with w administrative penalty which is being (levelled.
The cp#ny constructed and continues to operate a concrete-batch facility without a Board permit. A Board frder with an agreed administrative penalty of JSOO.flPtvili be presented to the Board for adoption if the Order is finalized with the company prior to the Bom* meeting date.
The fpty reported that 2,400 pounds of benzene were qfeased through a defective relief valve. The company claimed Its process was not subject to the NESHAPimrene regulation. The matter was referred to thegM. A recent determination from the EPA Indicates the release 1$ regulated under the benzene NESHAP standards. A Board Order with an agreed adwinfatratlve penalty of 19,500.00 will be present'* to thekeard for adoption if the Order is final i/ci with Hi company prior to the Hoard meeting dale.
LAM 011851
DPMC-08228
Page 9
Table ?
VIOLATIONS
Since September 1, 1985 (That Will Continue More Than 30 Days)
TACB REGION
SOURCE
NOTIFICATION
CITY/COUNTY____________________ TYPE Of FACILITY______________DATE_________ TYPE OF VIOLATION_______________________________ COMMENT
7 Amoco Oil Company
Petroleum Refining
Texas City/Galveston County
08/17/67
NSPS (Performance Testing) Penalt Conditlons
The company was found operating In violation of the NSPS monitoring requirements for carlton monnnde with regard to the operation of the fluid catalytic cracking unit. A formal enforcement conference was held on Septeafcer 10, 1987. The Regional Oirector has recommended a Board Order with an administrative penalty which Is being developed.
7 ARCO Chemical Company
Chemical Plant
Channel view/Ha mis County
08/08/87
NESHAP (Benzene)
The company was found In violation of several NESHAP benzene fugitive emission control provisions. A formal enforcement conference was held on September 14, 1987. The company failed to install and maintain a flame sensing device on the plant flare In benzene service as required by the NESHAP benzene regulations. The Regional Director has recommended a Board Order with an administrative penalty which Is being developed.
7 Ashland Chemical Company Houston/Harris County
Petrochemical Manufacturing
05/17/87
Permit Conditions
The company was operating a bulk chemical storage facility without the required emission controls. A formal enforcement conference was held on June 9, 1987. A Board Order with an agreed administrative penalty of $4,200.00 will be presented to the Board for adoption If the Order is finalized with the company prior to the Board meeting date.
LAM 011852
DPMC-08229
Page in
fACB REGION
SOURCE CiTT/COUNTY
7 Crown Cork and Seal Company. Incorporated
Galena Park/Harris County
TYPE OF FACILITY
Fabricated Metal Products
Table 2 VIOLATIONS
Since September I, 1985 (That Will Continue More Than 30 Days)
NOTIFICATION
DATE
TYPE OF VIOLATION
02/26/87
No Permit NSPS
7 0 and R Metal Finishing Houston/Harris County
Sandblasting,
04/01/87
Painting and Plating
No Permit
7 Doty Landfill Houston/Harris County
Landfill
03/16/87
Nuisance (Odors)
COMMENT
The company Increased production and added additional capacity to its beverage can manufacturing facility without a Board permit and in violation of the Federal NSPS. The Legal Oivision completed a review of the matter for viability. The facility is cur rently shut down. The Board Order with an admnistrative penalty is being revised to reflect an accelerated compliance date.
The company constructed and continues to operate a metal finishing facility without a Hoard permit. Three attempts were made to deliver the violation letter before it was accepted. A formal enforcement conference was held on July 30, 1987. A Board Order with an administrative penalty of 11,500.00 will be presented to the Board for adoption if the Order Is finalized with the company prior to the Board me*tln< date.
The company operates a landfill which has been the subject of numerous citizen complaints. The file ha been under review by the Director of Enforcement to determine the appropriate enforcement action. A Board Order with an administrative penalty has been proposed to the company. The canpany responded with a letter dated Septea&er 18. 1987 indicating addi tional information will be submitted and asipn that the penalty be reconsidered.
LAM 011853
DPMC-08230
Page H
TAC8 REGION
SOURCE CITY/COUNTY
7 Enon Chemical Americas Baytown/Harris County
TYPE Of FACILITY
Petrochemical Manufacturing
Table 2
VIOLATIONS
Since September l, 1985 (That Will Continue More Than 30 Days)
NOTIFICATION DATE
TYPE OF VIOLATION
08/29/87
NESHAP (Benzene)
7
fifty Four 0 One Oashwood,
Office Complex
Incorporated
Bel 1aire/Harrls County
07/27/87
NESHAP (Asbestos)
7 Fusion, Incorporated Houston/Harris County
Chrome Plating
08/26/87
No Remit
7 GuW States Asphalt Company, Incorporated
Deer Park/Harrts County
Asphalt Products (With Asbestos)
07/26/87
NESHAP (Asbestos)
COMMENT
The company failed to Install and maintain flame sensing devices on the plant flares in benzene service as required by the NESHAP-Benzeno regula tions. A formal enforcement conference was held o September 21, 1987. The Regional Director has recommended a Board Order with an administrative penalty which Is being developed.
The company operated the building complex and Has responsible for a renovation project in winch asbestos was Improperly removed. A Board Order hi an administrative penalty has been proposed to the company; however, an additional analysis of the asbestos samples Is being conducted before the Ord Is finalized.
The company constructed and continues to operate a chrome plating facility without a Board permit. A permit application has been submitted and is under review, A Board Order with an administrative pen.i has been proposed to the company.
The company was cited for visible emissions emanat from a process where asphalt containing a^h-*stos i manufactured. The matter Is under review in the Legal Division to determine the NESHAP applicahili
LAM 011854
DPMC-08231
Page 1?
Table 2
VIOLATIONS
Since September 1, 198S {That Will Continue More Than 30 days)
IAC8 REGION
SOURCE
NOTIFICATION
CITT/COUNTV____________________ TTPE OF FACILtTT_____________ OATE
TYPE OF VIOLATION_______________________________ COMMENT
7 Monsanto Company Alvi n/Brazorta County
Petrochemical Hanufacturing
08/10/87
NESHAP (Benzene)
The company was found in violation of the NESHAP* Benzene regulation regarding leak testing and cali bration of the leak test equipment. A formal enforce ment conference was held on September 28, I9H7. The Regional Director t$ reviewing the matter and will submit a recommendation for appropriate enforcement action.
7 Occidental Chemical Corporat ion
Pasadena/Harris County
PVC Manufacturing
03/04/87
NESHAP (Vinyl Chloride) Perm!t Conditions
The company reported a vinyl chloride release in violation of the NESHAP regulations. A Board Order with an agreed administrative penalty was to be presented to the Board for adoption; however, additional violations have been cited and will be included in a revised fioard Order.
7 Olshan Demolition Houston/Harris County
Landfill
03/16/87
Nuisance (Odors)
The company operates a landfill which has been the subject of numerous odor complaints, The file has been under review by the Deputy Executive Director. A 8oard Order with an administrative penalty has been proposed to the company; however, the comply has not agreed to the penalty and negotiations are continu ing. Additional formal enforcement action will he recommended if an agreed Board Order cannot i>e developed.
LAM 011855
DPMC-08232
Page 13
TACB REGION
SOURCE CITY/COUNTY
7 Pektank Corporation Deer Park/Harris County
7 Rigs R Us Nouston/Harris County
7 Shell Oil Co^any/ Shell Chemical Company Deer Park/Harris County
Table 2
VIOLATIONS
Since September 1, 1985 {That Will Continue More Than SO Oays)
TYPE OP FACILITY Storage Terminal
Drilling Structures Organic Chemicals
NOTIFICATION OATE
07/15/87
TYPE OF VIOLATION
NESHAP (Benzene) Board Order No. 86-114(1) Permit Conditions
03/30/87
No Permit
04/19/87
NESHAP (Vinyl Chloride)
COMMENT
The company's terminal and storage facility Mere found to be In violation of permit conditions an<1 NESHAP (Benzene) monitoring and recordkeeping requirements regarding pumps in benzene service. Tt company was also cited for violating a Hoard Order which requires compliance with NESHAP regulations, formal enforcement conference was held on August 3, 1987. The Regional Director has recommend.*! a Hoar Order with an administrative penalty which is being developed.
The company constructed and continues to operate a sandblasting and painting facility without a Board permit. A Board Order with an agreed administratis penalty of 12,000.00 will be presented to the Board for adoption If the Order is finalized with the company prior to the Board meeting date.
The company reported vinyl chloride releases in vio latton of the NESHAP regulations. A formal enforce ment conference was held on May 12, 1987. A Hoard Order with an agreed administrative penalty of 56,000.00 will be presented to the Roard for adoptr if the Order Is finalized with the company prior to the Board meeting date.
LAM 011856
DPMC-08233
Page 14
TACB REGION
SOURCE CITT/COUNTY
7 Shintech, Incorporated Freeport/Brazoria County
7 Texas Tx T* Karine
Transportation,
1
Incorporated
Houston/Harris County
7 Troy Pipe Supply, Incorporated
Willis/Montgomery County
7 United States Postal Service
8*ilai re/Narri $ County
TYPE OF FACILITY
Chemicals Manufacturing
Table 2
VIOLATIONS
Since September 1, 198S (That Will Continue More Than 30 Oays)
NOTIFICATION OATE
TYPE OF VIOLATION
07/08/87
NESHAP (Vinyl Chloride) Permit Conditions
Petroleum Coke Terminal
Pipe Recycling
01/28/87
Permit Representations Perm! t Condi dons
03/16/87
No Permit
U. S. Post Office
07/27/87
NESHAP (Asbestos)
COMMENT
The conpany reported a vinyl chloride release in violation of the NESHAP standard. A Board Order wit an agreed administrative penalty of $2,000.00 will h> presented to the Board for adoption if the Order is finalized with the company prior to the Board meet in' dare.
The company was operating a coke storage and loading facility in a manner not authorized by the Board per mi?.. Additional violations have been issued to the company and mill be incorporated into a revised Hoar Order with an administrative penalty.
The conpany constructed and continues to operate an oilfield pipe coating facility without a Board permit. A permit application has been received and is under review. A Board Order with an agreed administrative penalty of $4,000.00 will be presente to the Board for adoption if the Order is finalized with the company prior to the Board meeting date.
The Postal Service owns an office complex which was the site of an Improper asbestos renovation project. A Board Order with an administrative penalty has bee1 proposed to the Postal Service; however an addition* analysis of the asbestos samples Is being conducted before the Order is finalized.
LAM 011857
DPMC-08234
Page 15
Table 2 VIOLATIONS
Since September 1, 1965 (That Will Continue More Than 30 Days)
TACB REGION
SOURCE
NOTIFICATION
CITV/COUNTV____________________ TYPE Of FACILITY______________OATE_________ TYPE Of VIOLATION_______________________________ COMMENT
Rollins Environmental Services, Incorporated
Deer Park/Harris County
Hazardous Waste Incinerator
09/29/87
Upset Report!ng Perm!t Conditions NSPS (Storage Tanks} NESHAP (Benzene)
The company failed to properly report major upset
conditions which resulted in fugitive emissions m violation of the conditions of the permit. In addi tion, there were violations of the NSPS regulation
with regard to volatile organic compound storage
facilities and of the NESHAP-Benjene lea* detection and reporting requirements. A formal enforcement conference was held on October 13, 1987. A Board Order with an agreed administrative penalty of S13.000.00 will be presented to the Board for adop tion if the Order is finalized with the company pno< to the Board meeting date.
U. R. Grace and Coi^iahy Dee? 'ark/Harris County
Petrochemical Manufacturing
06/30/87
Permit Conditions
Stack sampling results Indicate that the company's formaldehyde emissions exceed the permit allowable. The company has retested the process. The Regional Director has recommended a Board Order with an administrative penalty which is being developed.
Wood Water)al aka Barbee Enterprise,
Incorporated Conroe/Montgomery County
Asphaltic Concrete Plant
05/14/86
Opacl ty Perm!t Conditions NSPS (Opacity)
The company was found in violation of NSi'S. opacity and permit conditions at th* asphaltic concrete plant. Additional odor complaints have been received and a meeting was held with the cwipany. A Board Order with ah administrative penalty was pro posed to the company; however, the company did not agree to the Board Order. The file is being prpparo for referral to the Attorney General's Office for lawsuit.
lam 011858
DPMC-08235
Page
Table 2
VIOLATIONS
Since September 1, 1985 (That Will Continue (tore Than 30 Days)
TACB REGION
SOURCE
NOTIFICATION
C1TV/C0UNTT____________________ TYPE OF FACILITY______________DATE_________ TYPE OF VIOLATION_______________________________ COHHENT
8 Acme Bag Manufacturing, Incorporated
DaUas/Oallas County
Flexographic Printing 04/29/87
No Permit
The company installed a printing press without a Board permit. A permit application has been sub mitted and is under review. A Board Order with an agreed administrative penalty of $1,925.00 will be presented to the Board for adoption if the Order is finalized with the company prior to the Board meet in. dat*.
8 Alcon Laboratories, Incorporated
Pharmaceuticals/
05/13/87
Ophthalmic Medication
Fort Worth/Tarrant County
No Permit
The company constructed and continues to operate five ethylene oxide sterilization units without a Board permit. A permit application has been sub mitted and is under review. A Board Order with an agreed administrative penalty of $475.00 will be presented to the Board for adoption If the Order is finalized with the company prior to the Roard meetm
date.
8 AMF Ben Hogan Company
Golf Clubs and Balls
05/04/87
Fort North/Tarrant County
Manufacturing
No Permit
The company constructed and continues to operate a controlled pyrolysis furnace witiiout a Board permit. A permit application has been submitted and is under review. A Board Order with an agreed administrative penalty of $750.00 will be presented to the Board fo> adoption if the Order is finalized with tfie company prior to the Board meeting date.
LAM 011859
DPMC-08236
Page 17
TACB REGION
SOURCE CITY/COUNTY
8 City Wide Fuels Distributors, Incorporated
Southlake/Tarrant County
Table 2 VIOLATIONS
Since September 1, 1985 (That Ul11 Continue More Than 30 Days)
TYPE Of FACILITY
Gasoline Bulk Terminal Blending Facility
NOTIFICATION DATE
TYPE OF VIOLATION
09/19/87
No Permit
8 Dext Company Oallas/Dallas County
Waste Food Processing 03/10/87
Permit Representations Opaclty
8
OHS Refining, Incorporated
Silver Recovery
Oa)las/Dallas County
07/21/87
No Permit
COMMENT
The conpany constructed and continues to operate a gasoline terminal and blending facility witliout a Board permit. A permit application has been sub mitted and is under review. The Regional Director is reviewing the matter to determine the appropriate enforcement action.
The company was cited for Increasing the hours of operation In violation of permit representations. It appears however that this situation may be* resolved through permit amendment <4iich was submitted on March 31, 1987. A subsequent Investigation on April 30, 1987 revealed excessive opacity from the dryer stack. Opacity levels have now been reduced as confirmed by Inspection on July 29, 1987. The com pany hired a consultant to develop a compliance plan which has been submitted. The Director of Enforcement Is reviewing the matter to determine the appropriate enforcement action.
The company relocated its silver reclamation facility without a Board permit. A permit application has been submitted and is under review. The Region*! Director has recommended a Board Order with an administrative penalty which is being developed.
LAM 011860
DPMC-0823'.
Page IB
Table 2
VIOLATIONS
Since September 1, 1985 (That Mill Continue More than 30 Days)
IACB REGION
SOURCE
NOTIFICATION
CITY/COUNTY____________________ TYPE OF FACILITY______________DATE
TYPE OF VIOLATION_______________________________ COWCNT
Farris Concrete Company Helissa/Collin County
Ready HI x Concrete Plant
04/05/87
Exemption Conditions
The coqpny was cited for failure to Install water sprinklers on aggregate stockpiles as required by the Standard Exertion. A Board Order with an agreed administrative penalty of $500.00 will be presented to the Baard for adoption If the Order is finalized with the company prior to the Board Meeting dal e.
Flexible Foam Products TerreH/Kaufman County
Foam Rubber Manufacturing
05/05/87
No Permit
The cot^any constructed and continues to operate a foam and carpet pad Manufacturing facility without a Board permit. A permit application has been submit ted and Us under review. A Board Order with an agreed aMntstrati ve penalty of $5,250.00 will he presented to the Board for adoption If the Order is flnaUzedwith the company prior to the Board meeting date.
larry Jones, Incorporated Arilngton/Tarrant County
Cabinet Shop
12/12/85
No Penal t
The compcmy constructed a custom wooden cabinet Manufacturing facility without a Board permit. A public luring was held on Hay 26, 1987; however, no opposition attended. The Board Order on the con tested case hearing was entered at the July 17, 19*47 Board mealing and a permit was issued to the com pany. A Board Order with an administrative penalty has been proposed to the company.
LAM 011861
DPMC-08238
Ptge 19
Table 2
VIOLATIONS
Since September l, 1985 (That Mill Continue More Than 30 Clays)
TACB REGION
SOURCE
NOTIFICATION
CITY/COUNTY____________________ TYPE Of FACILITY______________ DATE_________ TYPE OF VIOLATION_______________________________ COMMENT
Lattlaore Materials Company Greenville/Hunt County
Wet Batch Concrete Plant
07/06/87
Permit Condition1
The company was cited for several provisions of Us
permit including heavy dust emissions ami inadequate abatement equipment. The Regional Director lias recommended a Board Order with an administrative penalty which Is being developed.
North Teus Aggregates, Incorporated
Chtco/Wtse County
Portable Rock Crushing Plant
08/17/87
Permit Exemption Conditions
The company was cited for violation of the condi tions of the exemptions dich included the failure to keep In-plant roads watered and inadequate water sprays. The company initiated repairs on the water spray system and the violation was thought to he resolved. Subsequent Investigation revealed that th water sprays were still inadequate. The Regional Director has recommended a Board Order with an administrative penalty which is being developed.
Overwraps, Incorporated Oallas/Dallas County
Flexographic Printing OS/25/87
No Permit
The company constructed and continues to operate a printing facility without a Board permit. A consul tant has been hired to identify appropriate controls and prepare a permit application. A Board Or.ler wit' an agreed administrative penalty of J5.9uu.00 will b. presented to the Board for adoption if the Order is finalized with the company prior to the Board meetm. date.
LAM 011862
DPMC-08239
Page
Table 2 VIOLATIONS
Since September l, 1985 (That Will Continue More Than 30 Days)
TACB REGION
SOURCE
NOTIFICATION
CtTY/COUNTY____________________ TYPE OF FACILITY______________ DATE_________ TYPE OF VIOLATION________________________________COMMENT
8 Pamarco, Incorporated Oallas/Dallas County
Printing Press Repair
06/1A/B7
No Permit
The company constructed and continues to operate a printing press roller refurbishing facility without Board permit. The company has agreed to submit a permit application. Additional Information has be>>n requested from the company and will be reviewed to determine If the company qualifies as a s>ial 1 source
8 Presbyterian Hospital Kaufman/Kaufman County
Pathological End nerator
04/11/87
Exemption Conditions
The hospital was cited for visible emissions from th incinerator In violation of the conditions of the Standard Exemption. A Board Order with an agreed administrative penalty of S2.7UO.OO wi11 be presente to the Board for adoption if the Order is finalized with tile company prior to the Board meeting date.
8 Rushing Paving CcMfiany, Incorporated
Sherman/Grayson County
Asphaltic Concrete Batch Plant
08/30/87
Opacity Permit Conditions
The facility has a history of violations of opacity limits and permit conditions. It mas again found to
be In violation for excess opacity from the scrubber Stack and dust emissions from in-plant traffic. The company has shut down the facility until corrections are completed. The Regional Director has recommends a Board Order with an administrative penalty which i being developed.
LAM 011863
DPMC-08240
Pag* 2\
race REGION
SOURCE CITY/COUNTY
8 Southwest Neat Exchanger Fort North/Tarrant County
TYPE Of FACILITY
Air Conditioning Condensers
Table 2
VIOLATIONS
Since September 1, 1985 (That Will Continue More than 30 Oays)
NOTIFICATION DATE
08/17/87
TYPE OF VIOLATION No Permit
9 The Palis Corporation Junction/Kimble County
General Chemicals
06/01/87
Nuisance (Sawdust) Optd ty
9 Powerwall, Incorporated Poteet/Atascosa County
Fiber Reinforced Stucco
06/29/87
No Permit
9 Texarome, Incorporated Leakey/Real County
Cedar Oil Hill
04/11/87
Permit Representations Excessive Visible
Emissions
COHHENT
The company constructed and continues to operate a vapor degreaser without a hoard permit. A permit application has been submitted and is under review. The Regional Oirector is reviewing the matter to determine the appropriate enforcement action.
The company was cited for excessive opacity from tin* air pollution control equipment (cyclone) and for nuisance conditions created by burning sawdust. After a review of the company's compliance plan, the Regional DlrectorwfM complete the recommendation for a Board Order with an administrative penalty.
The company constructed and continues to operate the facility without a Board permit. A formal enforce ment conference was held on July 14, 1987. The development of Board Order with an administrative penalty has been delayed due to the company owner being In the hospital and unable to submit the additional information on capital costs needel to complete the review.
The company was cited for not constructing the plant as represented in the permit application and for excessive visible emissions. A formal enforcement conference was held on April 28. 1987. A Board flrdei with an administrative penalty has been proposed to the company.
LAM 011864
DPMC-08241
Pag*
TACB REGION
SOURCE CITY/COUNTY
9 USG Industries, Incorporated
New Braunfels/Comal County
Table 2
VIOLATIONS
Since September 1, 1985 (That Will Continue More Than 30 Hays)
TYPE OF FACILITY
Limestone Quarry and line Products
NOTIFICATION DATE
06/25/87
TYPE OF VIOLATION Permit Conditions
10 American Petrofina
Bulk Hydrocarbon
Pipeline Company
Termi nal
Port Arthur/Jefferson County
07/17/87
Nuisance (Odors)
10 Bright Coop, Incorporated Nacogdoches/Nacogdoches County
Wood Pallet Manufacturing
07/21/86
No Remit
COMMENT
The company was cited for dust emissions from t fines unloading area. A formal enforcement con ence was held on June 30, 1987, A Board Order an agreed administrative penalty of 51,000.On w presented to the Board for adoption if the Orde finalized with the conpany prior to the Board n> date.
The company was cited for creating nuisance (oil conditions when a gasoline storage tank ovprfil and 1,600 barrels of gasoline were spilled. A.i health effects were confirmed. A satisfactory compliance plan has been submitted to prevent f incidents. A Board Order with an agreed admin i trative penalty of 16,000.00 will be presented Board for adoption if the Order is finalized wi company prior to the Board meeting date.
The company has Increased Its production rate a added manufacturing equipment over the past sev years without permit authorization. A request permit amendment has been submitted and is un.ie review. The regional office staff has conducte sampling to evaluate emissions from the source assist in the development of a control plan. A Order with specific control requirements will b developed when agreement is reached on Use perm amendment.
LAM 011865
DPMC-08242
Page 23
Table 2 VIOLATIONS
Since September l, 1985 (That Mill Continue More Than 30 Days)
HCB REGION
SOURCE C1TY/C0UNTT________________
NOTIFICATION TYPE OF FACILITY______________DATE_________ TYPE OF VIOLATION_______________________________ COMMENT
10 Chevron U.S.A.,
Petroleum Refining
Incorporated
Port Arthur/Jefferson County
09/01/87
Nuisance (Odors) Adverse Health Impact
10 Chevron U.S.A.,
Incorporated Beaumont/Jefferson County
s
Petroleum Refining
07/15/87
Perm!t Conditions Regulation V (VOC***) NSPS
Process upsets at the Chevron refinery caused excess emissions of uncoabusted hydrocarbons and hydrogen sulfide which resulted in an air pollution episode, including nuisance conditions and adverse health impacts. Corrections were made at the ti* of the incident and an acceptable plan to prevent future occurrences of this nature has been submitted. The Regional Director has recommended a Board Order with an administrative penalty which is being do/elopcd.
The company was cited for failure to conduct the annual Inspections of secondary seals on the storage tanks and other violations of state and federal rule regarding secondary seals on petroleum storage tanks The Regional Oirector has recommended a Board Order with an administrative penalty which is being developed.
10 Temple Caste*, Incorporated Pine Plywood PIneland/Sahine County
04/20/87
Permit Representations
The company exceeded the plywood production rate specified in permit provisions. The Regional Director has recommended a Board Order with an administrative penalty. The Oirector of Enforcement is reviewing the matter to determine the appropriate enforcement action.
Volatile Organic Compounds
LAM 011866
DPMC-08243
Page 24
Table 2
VIOLATIONS
Since September 1, 198S (That Will Continue More Than 30 De/s}
MC6 REGION
SOURCE
NOTIFICATION
CITY/COUNTY____________________ TYPE OF FACILITY______________DATE_________ TYPE OF VIOLATION_______________________________ COWENT
U Baltimore Spice Conran/ Nestway/El Paso County
Processing/Peckaging Spices
06/03/87
No Permit
The conpany was cited for construction and operation of an ethylene oxide sterilisation unit witiiout a Board permit. A permit application has been sub mitted and is under review. A Board Order with an administrative penalty has been proposed to the company. If the initial review indicates a waiver can he granted, this matter will he resolved for this report.
11 Carpenter Motors El Paso/El Paso County
Used Car Sales
08/08/87
Regulation IV (Motor Vehicle Tampering)
The company was cited for offering for sal*, vehicles with inoperative emission control devices. A formal enforcement conference was held on SepteuPer 23, 1987. The Regional Director has recommended a Board Order with an administrative penalty which is being developed.
11 Chaparral Motors, Incorporated
El Paso/El Paso County
Used Car Sales
08/22/87
Regulation IV (Motor Vehicle Tampering 1
The company was cited for offering for sale, vehicles with inoperative emission control devices. A formal enforcement conference was held on Octoher 7, 1987. The Regional Director has recommended a Board Order with an administrative penalty which Is being developed.
LAM 011867
DPMC-08244
Page ?S
TACB REGION
SOURCE CfTY/COUNTY
11 Department of Defense, U. S. Army
fort Bliss/El Paso County
Table ?
VIOLATIONS Since September 1, 1985 (That Will Continue More Than 30 Days)
TYPE OF FACILITY Building Renovation
NOTIFICATION DATE
07/18/87
TYPE OF VIOLATION NESHAP (Asbestos)
11 floor Corporation Van Horn/Culberson County
Abandoned Sulfur Plant 04/19/87
NESHAP (Asbestos)
11 El Paso Refining Company, Ltd.
El Paso/El Paso County
Petroleum Refining
06/30/87
Opacity
COMMENT
The Department of Defense was cited for improper removal of asbestos at the Fort Rliss facility. A formal enforcement conference Is being scheduled. The Regional Director has recommended a Hoard Order with an administrative penalty whtch is being reviewed by the Legal Division and the Director of Enforcement.
The company was cited for improper removal of asbestos during the dismantling of buildings and equipment at a closed sulfur production facility, formal enforcement conference was held on June 2, 1987, The compliance plan has been reviewed by the Texas Water Commission. A Board Order without an administrative penalty has been proposed to the company.
The company was cited -on two occasions for excessiv visible emissions. A formal enforcemeni conference was held on August 18, 1987. The Regional Director has recommended a Board Order with an adnmstrativ penalty irtilch Is being developed.
LAM 011868
DPMC-08245
Page
Table 2 VIOLATIONS
Since September 1, 198S (That Will Continue More Than 30 Days)
TAC8 REGION
SOURCE
NOTIFICATION
CITY/COUNTY____________________ TYPE OF FACILITY______________OATE_________TYPE Of VIOLATION_______________________________ COMMENT
11 Horizon Retread Center El Paso/E) Paso County
Tire Retreading
08/03/87
No Permit
The company was cited for construction an<l operation of a tire retreading facility without a Roard permit. A permit application has been submitted and is under review. The Regional Director has recommended a Board Order with an administrative penalty winch is being developed.
12 Pabco Insulation Tucker/Anderson County
Fiberglass Insulation 03/30/87
Permit Conditions NSPS (Monitoring)
The company was cited for excessive stack emissions above permit allowables on particulates, phenol and aldehydes. Corrective measures have been completed. A formal enforcement conference was held on August 25, 1987. The Regional Director Is preparing
a recommendation for formal enforcement action.
12 Pilgrim's Pride Corporation Chicken Manure
07/15/87
Mt. Pleasant/TItus County
Fertilizing Operation
Nuisance (Odors)
The coajiany was cited for two Instances of nuisance conditions (odors) from the spreading of chicken manure on a 120 acre tract near the community of Ripley. A formal enforcement conference was held on August 4, 1967. A Board Order with an administrative penalty of $2,000.00 will be presented to the* Board for adoption if the Order is finalized with the company prior to the Board meeting date.
LAM 011869
DPMC-08246
Page 27
TACB REGION
SOURCE CITY/COUNTY
12 Prengler Iron and Metal Athens/Henderson County
TYPE OP FACILITY Metal Salvage
Table 2
VIOLATIONS Since September 1, 198S (That Will Continue More Than 30 Days)
NOTIFICATION DATE
TYPE OF VIOLATION
09/04/87
Outdoor Burning
COMMENT
The company conducted outdoor burning of wire insulation, plastic pipe and debris. A formal enforcement conference was held on September 11, 1987. The Regional Director has recommemb'cl a Board Order with an administrative penalty which is being developed.
LAM 011870
DPMC-08247
Page 1
Tabid 3
VIOLATIONS
Since September 1, 1985 (Approved for Referral to Attorney General's Office)
TACB REGION
SOURCE
NOTIFICATION
CITY/COUNTV____________________ TYPE Of FACILITY______________ DATE_________ TYPE OF VIOLATION_______________________________ COMMENT*
1 Bean Hog Farm Brownwood/Brown County
Confined Animal Feedlot
11/21/85
Nuisance (Odors) Board Order (8S-1?)
The file on this company was referred to the Attorn General's Office on May 21, 1986. The company vio lated a Board Order issued in Octoher, 1985 which required a reduction in the nunber of animals in th feedlot and prohibited the creation of an/ further nuisance conditions. It is projected that this law suit can be resolved within 2 months through agrees action.
2 Texland Petroleum Lubbock/Lubbock County
Petroleum Storage
09/23/85
No Permi t Nuisance (Odors) Opacity
The file on this company was referred to the Attorn General's Office on December 17. 1985 fur violation which occurred prior to September 1, 1985. Addi tional violations have been periodically referred t the Attorney General's Office for Inclusion in the lawsuit. On Septeeber 14, 1987, an agreed final ju ment was entered assessing a penalty of 565,000.00,
attorney's fees of 515,000.00 and investigative cos of 510.000.00.
3 Pool Production Services Company
Kervin/Freestone County
Oil Separation and Injection Hell Fad Hty
03/23/87
Permit Conditions
The file on this company was referred to the Attorn General's Office on Octoher 29, 1985 for violations which occurred prior to September l, 1985. Addi tional violations were forwarded on April 14, 198/ for inclusion in the lawsuit. This lawsuit is not expected to reach agreed settlement. Trial on the merits is scheduled for December 7. 1987.
If settlement cannot be reached and additional court action 1$ necessary, then it may take 2 years to resolve these lawsuits.
LAM 011871
DPMC-08248
Page 2
TACB REGION
SOURCE CITY/COUNTY
3 Gerald Company, Incorporated
HamiIton County
5
Oceanside Asphalt,
>
Incorporated
Robstown/Nueces County
6 Bryson Tank Company Odessa/Ector County
Table 3 VIOLATIONS
Sloe* September 1, 1985 (Approved for Referral to Attorney General's Office)
TYPE OF FACILITY Grain Handling
Portable Asphalt Plant
Tank Manufacturing (Spray Painting)
NOT IFICA TION
DATE
TYPE OF VIOLATION
COMMENT*
04/17/87
Nuisance (Odor)
The file on this company was referred to the Attorm General's Office on Septeter 3, 1987. The company operates a feed mill which has been the subject of several odor complaints and has failed t initiate corrective actions, it is not projected that this suit can be resolved through an agreed settlement.
06/26/86
Permit Conditions Nuisance (Oust)
The company was cited for failure to water the stockpiles and roads as required in the Board permit and for creating a nuisance dust condition. The fii on this company was referred to the Attorney General's Office on May 28, 1987. It is projected that this lawsuit can be resolved within 9 months if an agreed settlement Is reached.
10/08/85
Nuisance (Paint Overspray)
The co^iany Is continuing to operate without the needed controls and the tulsanee problem remains. The file on this company was referred to the Attorn< General's Office on January 31, 1986, The petition was filed on August 13, 1986. Cause was dismissed because of Inability to serve the defendant. The case may be reflled.
If settlement cannot be reached and additional court action is necessary, then It may take 2 years to resolve these lawsuits.
LAM 011872
DPMC-08249
Page 3
Tahle 3 VIOLATIONS
Since September I, 1985 (Approved fnr Referral to Attorney General's Office)
TAC8 REGION
SOURCE
NOTIFICATION
C1TT/COUHTT____________________ TYPE Of FACILITY______________ DATE_________ TYPE OF VIOLATION_______________________________ COMMENT*
CAN Enterprises Mldland/Hidtand County
Sandblasting
10/24/85
Nuisance (Dust) Mo Permit
The company has a history of violations which tndud nuisance (dust) conditions. The file on this compau was referred to the Attorney General's Office on January 31, 1986. The Attorney General's Office filed suit against the wrong company. The lawsuit was rented on Soptomfcer 24, 1987, it is projected
that the lawsuit can be resolved within 6 months if an agreed settlement Is reached.
Penaian Chemical Company, Incorporated
Odessa/Ector County
Fertilizer Plant
10/22/85
Permit Representations Permit Conditions
Nuisance (Acid Emissions)
The file on this company was referred to the Attorns General's Office on October 22, 1985 for violations occurring prior to September l, 1985. Adhtional vt lations were forwarded on January 29, 19HI for inclu slon in the lawsuit. The lawsuit is not expected to reach agreed settlement. An agreed temporary injunc tion was signed by the company and sent to the Court on June 22, 1987. It requires compliance with Sections 3.27(a) and 4.01(a) of the Act and Rules 101.7 and 111.21. Trial on the merits was continued indefinitely and a modified teiaporary injunction was entered on October 13, 1987 requiring the company to cease production until further order of the court.
Keeshan and 6ost Chemical Company
Manvel/Brazoria County
Waste Chemical Processing
02/26/86
Nuisance (Odors) Court Order
A judgment was entered against this company on July 12, 1985 prohibiting future odor nuismces. Additional violations have since been documented. The file was referred to the Attorney General's Office on May 15, 1986. On October 19, 19;}?, a Firs Amended Agreed Final Judgment was mailed tu the cour assessing a contempt fine of 11,250.00
If settlenmnt cannot be reached and additional court action Is necessary, then it may take 2 years to resolve these lawsuits.
LAM 011873
DPMC-08250
Page 4
Table 3
VIOLATIONS
Since September 1, 1985 (Approved for Referral to Attorney General's Office)
TAC0 REGION
SOURCE CITY/COUNTY
7 Cuyahoga Wrecking
and Corporation S Galveston County San Patricio County
TYPE OF FACILITY Asbestos Contractor
NOTIFICATION
OATE
TYPE OF VIOLATION
07/30/86
NESHAP (Asbestos)
7 La Porte Chemicals
Vinyl Chloride
01/28/86
Corporation,
Monomer Production
Olanond Shamrock Corporation,
Otanond Shamrock Plastics
Corporation
Deer Park/Harris County
NESHAP (Vinyl Chloride) Permit Conditions
COMMENT'
The file on this company was referred to the Attorn General's Office on May 8, 1987. The company con ducted asbestos removal projects at Amoco Productw Company (Galveston County) and Sun Exploration (Sa<; Patricio County) in violation of the NESUAf'-Ashest' standards. The company has filed for bankruptcy. is projected that the lawsuit can be resolved withi 3 months if an agreed settlement is reached.
On June 2, 1986, the file on this company was referred to the Attorney General's Office liec-nise o the hazardous substance Involved. Additional viola tions have been periodically referred to the Attor' General's Office for Inclusion In the lawsuit. It projected that this lawsuit can be resolvei within months If an agreed settlement is reached. A sett) ment with La Porte Chemicals has been reached. Set tlement negotiations-with Diamond Shamrock (now ria> Energy) are continuing.
If settlement cannot be reached and additional court action Is necessary, then it may take 2 years to resolve these lawsuits.
LAM 011874
DPMC-08251
Page 6
Table 3
VIOLATIONS
Since September 1, 1985 (Approved for Referral to Attorney General's Office)
TACB REGION
SOURCE
NOTIFICATION
CITT/COUNTY____________________ TYPE OF FACUITY_____________ DATE_________ TYPE OF VIOLATION_______________________________ COMMENT*
7 Root Company
Trench Burner
Shenandoah/Hontgomery County
Operation
10/09/85
No Permit Outdoor Burning
The company Mas cued on six occasions for operating without a permit and conducting outdoor burning. Th file on this company was referred to the Attorney General's Office on January 29, 1986. An agreed final judgment Mas entered on September 8, 1987 assessing a S20,000.00 penalty with injunctive relie requiring defendants to apply a final cover on the Root landfill and enjoining defendants from operatm the landfill and conducting outdoor burning. The penalty Mill be abated if defendants meet the dead lines for applying a final cover on the Root Larvlf ill.
7 Tenneco Polymers, Incorporated
Pasadena/Harris County
Chemical Manufacturing 10/24/85 (Vinyl Chloride)
NESHAP (Vinyl Chloride) Perrnit Conditions
On Decenfcer 31, 198S, the file on this company was referred to the Attorney General's Office because of the hazardous substance Involved. The company sold its vinyl chloride plant In April, 1986. Further settlement negotiations took place on July 1, 1987. A tentative settlement was reached on July l, 1987. An agreed final judgment Is being drafted.
7 Texas City Refining,
Refinery
Incorporated
Texas Clty/Galveston County
06/26/86
Permit Provisions NSPS (High Sulfur Crude)
The file on this copany was referred to tin; Attorne General's Office on July 12, 1983. Subsequent vio lations have been periodically forwarded to the Attorney General's Office for inclusion in the lawsuit. It is projected that this lawsuit can he resolved within 2 months if an agreed settlement is reached.
If settlement cannot be reached and additional court action is necessary, then It may take 2 years to resolve these lawsuits.
LAM 011875
DPMC-08252
Page 6
Table 3
VIOLATIONS
Since September 1, 1905 (Approved for Referral to Attorney General's Office)
TACB REGION
SOURCE
NOTIFICATION
CITY/COUNTY____________________ TYPE Of FACILITY______________OATE_________TYPE Of VIOLATION_______________________________ COMMENT*
7 Union Carbide Corporation Chemical Manufacturing 02/16/86 Texas City/Galveston County
NESHAP (Vinyl Chloride and Benzene)
The file on this company was referred to the Attorney General's Office on March 18, 1986. Additional vio lations have been periodically included in th< law suit. The parties have agreed to settle this matter. A proposed agreed final Judgment is being drafted. It is projected that a judgment can be entered within 1 month. The company has signed and returned the proposed final judgment with a check for civil
penalties. The judgment is to he filed.
8 Brandywilde Development Corporation
Valley View/Cooke County
Rock Crushing Plant
09/18/85
Permit Conditions
The company has a history of violations beginning in 1983 when it constructed without a Board permit. The file on this company was referred to the Attorney General's Office on February 4, 1986. It is pro jected that this lawsuit can be resolved within 2 months if an agreed settlement is reached. An agreed judgment was mailed to the defendant for signature in early February by certified mail but was apparently lost in the mail. Another agreed judgment was mailed to the defendant on March 16, 19U7. Settlement nego tiations have not achieved an agreement. Interrog atories were sent to the company and answered in June, 1987. The company Is no longer operating at
the site.
if settlement cannot be reached and additional court action is necessary, then It may take 2 years to resolve these lawsuits.
LAM 011876
DPMC-08253
Page 7
Table 3 VIOLATIONS
Since September 1, 1985 (Approved Tor Referral to Attorney General's Office)
TACB REGION
SOURCE
NOTIFICATION
C1TT/COUNTT____________________ TYPE OF FACILITY______________DATE_________ TYPE OF VIOLATION_______________________________ COMMENT*
B Nil Me Grant Tarrant County
Individual
02/21/86
Outdoor Burning Court Order
A Judgment was entered against this Individual on May 31, 1985 prohibiting future violations of Regulation i. An additional violation of unautho rized burning has since been documented. The file was referred to the Attorney General's Office on Hay IS, 1986. It <s projected that this contempt action cannot be resolved by agreement.
10 Great Lakes Carbon
Carbon Plant
Corporation
Port Arthur/Jefferson County
09/27/85
Opacity Excessive Particulate
Emissions Penalt Conditlons
The file on this company was referred to the Attorney General's Office on September 27, 1985 for violations occurring prior to Septenfcer 1, 1985. Subsequent violations were forwarded to the Attorney General for inclusion in the lawsuit. Sampling is needed before Injunctive relief can be drafted. The strike at the plant has recently ended. Resampling was conducted on Much 9, 1987. The resampling indicated continu ing violations which were forwarded to the Attorney General on June 18, 1987. It Is projected that this lawsuit can be resolved within 7 months if an agreed settlement is reached.
If settlement cannot be reached and additional court action is necessary, then it may take 2 years to resolve these lawsuits.
LAM 011877
DPMC-08254
Page 8
Table 3 VIOLATIONS
Since September l, 1985 (Approved for Referral to Attorney General's Office)
TAC6 REGION
SOURCE CITY/COUNTY
TYPE OF FACILITY
n Department of Defense,
Building Renovation
U, S. Army
Katyear Construction Company
Pioneer Sheet Metal Works,
Incorporated
fort Bliss/El Paso County
NOTIFICATION DATE
09/17/85
TYPE OF VIOLATION
NESHAP (Asbestos Removal)
12 Dallas Demolition and Excavating Company
Tyler/Smith County
building Demolition
09/16/85
NESHAP (Asbestos Removal)
COMMENT*
The file on the Army and the two companies was referred to the Attorney General's Office on April 7 1986 for legal action because of the hazardous sub stance Involved. On July 17, 1987, an agre<Hj final judgment was entered hy the court resolving the vio lations against Katyear and Pioneer. Civil penal tie of 15,000.00 were assessed and the companies were prohibltorlly enjoined from violating Rule 101.20(2) In the future. Notice of intent tu sue the depart ment of Defense Is being drafted. The lawsuit against the Department of Defense will be filed in federal court. It Is not projected that the suit ca< be resolved through an agreed settlement.
The excavating company was In the process of readyin a building for Implosion without proper notification and handling of asbestos. This lawsuit is not expected to reach agreed settlement. Interrogators were sent to the company In June. 1987 and answers tInterrogatories were received on June 20. 1987.
If settlement cannot be reached and additional court action Is necessary, then It may take 2 years to resolve these lawsuits.
LAM 011878
DPMC-08255
Page 9
Table 3 VIOLATIONS
Since September 1, 1985 (Approved for Referral to Attorney General's Office)
TACB REGION
SOURCE
NOTIFICATION
CITY/COUNTY____________________ TYPE OF FACILITY______________DATE
TYPE OF VIOLATION_______________________________ COMMENT*
12 Poly Cycle Industries. Incorporated
Tecula/Cherokee County
Battery Case Recyclt ng
02/19/86
Permit Conditions Permit Representations
Poor maintenance and cleaning practices at th* com' party's battery case recycling facility have result*in high lead concentrations In the soil near the grinding process. Additional samples taken confirm, the high lead levels In the soil. The file on this company was referred to the Attorney General's Offu on October 22, 1986. Settlement negotiations took place In March, 1987. Another settlement meeting w.i held on July 1, 1987. It Is projected that this la.suit can be resolved within 3 months If an agreixi settlement Is reached. A proposed closure plan has been submitted to the agency for review of clean-up plans.
12 Southwest Railroad
Railcar Salvage
Car Parts
Jacfcsonville/Cherokee County
03/18/86
Outdoor Burning Nuisance (Smoke)
The file on this company was referred to the Attorney General's Office on July 12, 1985 for violations occurring prior to Septerfier I, 198S at two different sites. Subsequent violations have been forwarded to the Attorney General for inclusion In the lawsuit. Since the defendant's attorney <s <state legislator, settlement may not he possible until the fall of 1987. The Attorney General has requested a settlement meeting with the company m November, 1987.
If settlenmnt cannot be reached and additional court action is necessary, then It may take 2 years to resolve these lawsuits.
LAM 011879
DPMC-08256
Page 10
TACB REGION
SOURCE CITY/COUNTY
1? Texas Basic Resources Overton/Rusk County
Table 3 VIOLATIONS
Since September 1, 198b (Approved for Referral to Attorney General's Office)
TYPE Of FACILITY Grain Transfer
NOTIFICATION OATE
TYPE OF VIOLATION
04/04/86
No Permit Nuisance (Oust)
,
COMMENT*
The file on this company was referred to the Attorney General's Office on March 6, 19^7 lor constructing and operating a grain transfer facility without a Board permit. It is projected that this lawsuit can be resolved within 9 months if an agreed settlement is reached. The lawsuit was filed on June 17, 1987 and the defendant was served on June 29, 1987.
If settlenent cannot be reached and additional court action is necessary, then it nay take 2 years to resolve these lawsuits.
LPM 01188
DPMC-08257
Page 1
Table 4 VIOLATIONS On Small Sources With No Permit
The following companies constructed and operated small facilities without Hoard permits or exemptions. The coajianles Indicated no prior knowledge of the permitting requirements and had no previous permit violations. Applications have been submitted. Hoard Orders without administrative penalties will be presented to the Board for adoption If the Order Is finalized prior to the Board meeting date. The Board Orders require the companies to obtain permits or exemptions.
REGION 1 2 7 7 7 7 7
SOURCE CITY/COUNTY
Bethanla Hospital Wichita Falls/Wlchlta County
Hast Harble AmarlHo/Potter County
Blacks Millworfc Houston/Harris County
Houston Steel Products, Incorporated Houston/Harris County
Hydrotex Dynamics, Incorporated Harris County
Intermedics, Incorporated Bra2oria County
Modern Machining and Hydraulics, incorporated
Pasadena/Harns County
TYPE OF FACILITY Incinerator Cultured Marble Mlliwork Hotel Interiors Oil Field Equipment Manufacturing Pump Rebuilding Medical Equipment Remanufactured Cylinder Valves
MOTIFICAT10 DATE
07/27/B7
09AQ3/R6 05/25/87 06/16/87 06/16/07 06/24/87 05/10/87
LAM 011881 DPMC-08258
Page 2
Table 4 VIOLATIONS On Small Sources With No Permit
The following coajianles constructed and operated snail facilities without Board permits or exemptions. The companies Indicated no prior knowledge of the permitting requirements and had no previous permit violations. Applications have been submitted. Board Orders without administrative penalties will be presented to the Board for adoption If the Order Is finalized prior to the Board meeting date. The Board Orders require the companies to obtain permits or exemptions.
REGION 7 8
fi
9 9 l? 1?
SOURCE CITY/COUNTY
Western Packing Company Bel 1v1 Me/Austin County
Augat Elfab Lewlsvllle/Oenton County
BASE Corporation Carrollton/Oallas County
0e tos Santos Ready Mix Eagle Pass/Maverick County
Ray Ellison Industries San Antonio/Bexar County
Mid State Tile Company Mt. Vernon/Franklin County
Wells Marble Company Smith County
TYPE OF FACILITY Dog Food Manufacturing Printed Circuit Board Manufacturing Urethane Blending Plant Ready Mix Concrete Cultured Marble Tile Manufacturing Cultured Marble
NOTIFICATION OATE
07/26/87 06/73/87 07/31/87 04/22/87 06/08/87 07/11/87 08/12/86
LAM 011882
DPMC-08259
fT
ADMINISTRATIVE PENALTIES AND ORDERS OP THE TEXAS AIR CONTROL BOARD
PERMIT NO. 87-10(a)
87-10(b) 87-10 Ic) 87-10 (d)
RESPONDENT
Acme Bag Manufacturing, Inc.
9141 Premier Row Dallas, TX
Alcon Laboratories, Inc. 6201 S. Freeway Port Worth, TX
Alonzo's Concrete Co. 2540 Jana Lane Pasadena, TX
Amarillo By-Products 8415 East 1st Avenue Amarillo, TX
87-10ie)
Amerada Hess Corp. 1802 Poth Lane Corpus Christi, TX
DATE ENTERED 11/13/87
PENALTY AMOUNT $1,925
11/13/87 11/13/87 11/13/87
$475 $500 $13,000
11/13/87
$7,000
VIOLATIONS/REMEDIAL ACTION
Failure to obtain a permit for the construction and operation of a flexographic printing press and an adhesive laminator.
Failure to obtain a permit for the construction and operation of four ethylene oxide sterilizers.
Failure to obtain a permit for the construction and operation of a concrete batch plant.
Violated a permit by stockpiling 2,000,000 pounds of rendering raw material outdoors on the ground) caused emission of odors in violation of the Texas Clean Air Act) failed to obtain a permit to modify its rendering plant by installing a new cooker and press.
Violation of National Mission Standards for hazardous air pollutants (asbestos): Failure to timely provide written notification, to utilize required procedures, and to utilize required procedures for the handling of asbestoscontaining waste material.
MHOO1AJ/155E0 1
LAM 011883
DPMC-08260
ORDER NO. 8 7-10 ( f1 87-10(g) 87-10 |h)
87-10 <il 87-10 (j1
87-10 (lc
87-10(1J
RESPONDENT
AMF Ben Hogan Co. 2912 West Pafford Fort Worth, TX
Ashland Chemical Co. 8900 Galveston Road Houston, TX
Farmland Industries, Inc. Irion & Schleicher County, TX
DATE ENTERED 11/13/87
11/13/87
11/13/87
PENALTY AMOUNT 8750
84,200
84,250
Farris Concrete Co. Melissa Collin County, TX
Formosa Plastics Corp. Texas
Point Comfort Calhoun County, TX
Houston Steel Products, Inc.
6100 Romona Blvd. Houston, TX
Kydrotex Dynamics, Inc. 6320 Cunningham Road Houston, TX
11/13/87 11/13/87 11/13/87 11/23/87
8500
82,700
80
If substantial additional controls necessary 8500
VIOLATIONS/REMEDIAL ACTION
Failure to obtain a permit for the construction and operation of a paint burn off oven.
Operation of volatile organic compound storage tanka without abatement equipment
Failure to obtain a permit for the construction and operation of two natural gas compressor stations and one natural gas plant.
Failure to install and use water sprinklers to control emissions in a concrete batch plant.
Accidental discharge of 565 pounds of vinyl chloride into the atmosphere.
Failure to obtain a permit for the construction and operation of a sandblasting end painting facility.
Failure to obtain a permit for the construction end operation of a sandblasting facility.
MH001JU/155E01
-2-
LAM 011884
DPMC-08261
07-10(ml 07-lOln) 67-10(o) 07-10(pi
8 7-20(q) 87-10 |r) 87-10 (s)
RESPONDENT
Ico, Inc. 401 Saratoga Road Corpus Christi, TX
Intermedics, Inc. 240 Tarpon Inn Village Freeport, TX
Kast Marble 3012 Amarillo Blvd. Potter County, TX
XG Gas Processors, Ltd. Runnels County Winters, TX
Mid-State Tile Co. Franklin County Mt. Vernon, TX
Modern Machining fc Hydraulics, Inc.
504 North Richey Pasadena, TX
Perryton Equity Exchange Armstrong County, TX
DATE ENTERED 11/13/67
PENALTY AMOUNT 83,000
11/13/87
81,150
11/13/87
80
11/13/87
8500
11/13/87 11/13/87
11/13/87
80
8500 if substantial additional controls necessary
83,175
VIOLATIONS/REMEDIAL ACTION
Failure to obtain a permit for the construction and operation of pipe coating facilities.
Failure to obtain a permit for the construction and operation of three ethylene oxide sterilization chastoers.
Failure to obtain a permit for the construction and operation of a synthetic marble manufacturing facility.
Texas Clean Air Act violationst Processing gas containing more than 8,000 parts per million by volume of hydrogen sulfide (H-S) and failing to provide semi-annual reports on fugitive volatile organic compound leaks/Submittal of an application for an amendment of a permit; monitoring of B-S content of the inlet gas daily
Failure to obtain a permit to construct and operate a tile sunufacturing plant.
Failure to obtain a permit to construct and operate a chrome plating unit.
Failure to obtain a permit for the construction and operation of a grain elevator.
MH001AJ/J55E01
-3
LAM 011885
DPMC-08262
ORDER HO. 67-10 <t>
RESPONDENT
Phillips 66 Co. Hutchinson County Borger, TX
87-10lu)
Pilgrin's Pride Corp.
Titus County Mount Pleasant, TX
87-10(v) 87-10(w)
Presbyterian Hospital West Highway 243 Kaufman, TX
Shell Oil Co./ Shell Chemical Co.
Harris County Deer Park, TX
87-10 (x)
Shintech, Inc. 5618 State Highway 332 Freeport, TX
MH001AJ/155E01
DATE ENTERED 11/13/87
PENALTY AMOUNT 1175,000
11/13/67
82,000
11/13/87 11/13/87
$2,700 $6,000
11/13/07
$2,000
VIOLATIONS/REMEDIAL ACTION
Violation of National Emission Standards for a hazardous air pollutant (asbestos): Failed to utilize required procedures for the demolition and removal of friable asbestos s^terials, and to utilize required procedures for the handling and transportation of asbestos containing waste material.
Violation of the Texas Clean Air Act: Caused, suffered, allowed or permitted the emission of an air contaminant (odor from manure)/Disposing only broiler house manure at the siter disking all manure into the soil on the same day it is spread.
Failure to obtain a permit for the operation of a pathological incinerator.
Violation of National Scission Standards for a hazardous pollutant (vinyl chloride): Discharged exhaust gases containing concentrations of vinyl chloride in excess of 10 parts per million into the atmosphere from equipment used in ethylene dichloride purification and vinyl chloride formation.
Allowed a non-emergency discharge of vinyl chloride monomer (VCMI from a relief valve on equipment in vinyl chloride service at its polyvinyl chloride manufacturing plant.
LAM 011886
DPMC-08263
ORDER NO. 87-10<y)
67-10(z t
87-10(aa) 87-10(bb) 87-10(cc)
RESPONDENT
Troy Pipe Supply, Inc. 5080 1-45 North Millis, TX
USG Industries, Inc. Comal County Nev Braunfels, TX
Wells Marble Co. Smith County Flint, TX
Western Packing Co. 470 Nelius Road Austin County, TX
Henry Whited 015 Jacqueline Lane Kennedy Estates
Subdivision Manor, TX
DATE ENTERED 11/13/87
PENALTY AMOUNT 84,000
11/13/07
f1,000
11/13/B7 11/13/87 11/13/87
$0
80
8250 In installments
VIOLATIONS/REMEDIAL ACTION
Failure to obtain a permit for the operation and construction of a pipe recycling facility/cessation of cleaning pipe by applying heat.
Unloaded fines from an electrostatic precipitator into a storage hopper by a free-fall method instead of using the approved method (use of a collapsible loading spout vented to a baghouse).
Failure to obtain a permit for the construction and operation of a synthetic marble plant.
Failure to obtain a permit for the construction and operation of a dog food production facility.
Caused, suffered, allowed, or permitted outdoor burning of wire insulation.
MH001AJ/155E01
LAM 011887
DPMC-08264
ORDER NO. 87-10 (dd)
RESPONDENT
Rollins Environmental Services (Tx), Inc.
Battleground Road Deer Park, TX
DATE ENTERED 11/13/87
PENALTY AMOUNT $13,000
VIQLATIONS/REMEDJAL ACTION
Failed to notify the Execu1 of a major upset condition or may have caused excessi' failed to comply with Stan> Performance for New Statloi Sources (NSPS) for VolatllLiquid Storage Vessels; fa with NCSHAPS; and failed tnegative draft sufficient 1 fugitive emissions from th< afterburners of the liquid incinerator/maintenance of time and duration of each g that occurs; notification < whenever fugitive emission: and maintenance of a contii monitoring, recording, and
MH001AJ/155E01
LAM 011888
DPMC-08265
-2T
AGENDA ITEM V
ENFORCEMENT REPORT July 1987
Introduction
In accordance with the amended Texas Clean Air Act (Act), this report has been prepared and describes the status of enforcement actions initiated by the agency. Recommendations for Board Orders with administrative penalties are included on the agenda and are reflected in this report.
Enforcement Summary
Since the September 1, 1985 effective date of the amended Act, ..Notices of Violation have been issued to 2,204 companies, individuals or govern mental agencies. Of these violations, 1,906 have been resolved. A total of 124 violation situations currently remain unresolved for more than 30 days and will require formal enforcement action. Specific details for each of the unresolved situations are contained in the attached Tables. Table 4 contains a listing of 18 companies in violation which constructed small facilities without a Board permit or exemption and for which Board Orders without administrative penalties are being developed or recommended. The cases for which Board Orders were approved at the May Board meeting have been removed from the report.
The following summarizes administrative penalty actions by the Board from September 1, 1986.
Agreed Administrative Board Orders Entered: 148 Total of Administrative Penalties Assessed: $577,150.00
The following summarizes legal actions resolved through court orders entered after September 1,-1986.
Cases SettTed by Attorney General: 12 Total Civil Penalties Assessed: $611,844.00
Administrative Penalty Orders
Pursuant to Sections 3.20 and 4.041 of the Act and in accordance with the Guidelines for Assessing Administrative Penalties, the -staff will be presenting 25 cases for consideration and action by the Board. Although Table 2 includes brief reference to those situations for which penalties .are .being recommended,, these-cases yi 11 bey^conrsidered.'sepa-. ys. rately during the Board meeting.
LAM 011909
DPHC-08 28F-.
Page 1
`'NVa
tional
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Standards
Compounds
fo r
Hazardous
A ir
P ollutants
Table 1
VIOLATIONS
From th e Hay Enforcem ent Report (That Have Been C o rre c ted )
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LAM 011910
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DPMC-08286
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DPMC-08287
70
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LAM 011912
I
I I DPMC-08288
Page 2
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Table 2
VIOLATIONS
Since September 1, 1985
(That H i l l C ontinue More Than 30 Days)
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DPMC-08289
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LAM 011914
DPMC-08290
t iV
Page 4
c*> >
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O' "5 fi> --
Table 2
VIOLATIONS Since September 1, 1985
(That W ill C ontinue More Than 30 Days)
> sJt-.rJK'.v
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DPMC-08291
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DPMC-08292
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3 a X ftD
CL
--v* -- O3 nO -- n
f o*o 3 rf o
*ft -- ff -- 3* 3
-- 030
< ft
"ft ft
o o-- n ..3 Z O C VL
fto ,O X
03# O W ft
3frp
a is>
3
o
-- O r# a o
ft ^ on -- 3 "3
*< ft --- C -) ft
na
O ft
ft pp
ft ft H-
*3
30
.C. 0 3
--O
Vi CL
LAM 011917
r> o
DPMC-08293
-.Vt- _
r> o rr re a -- --1 3 3 <-* 3 r. o ft o -- - n <*0 3 --O O re n -- Sa3
3 O
o
*<
2: ;
c 3O
X! O> -- r> O 00
--' o o ft O 323 ft,
N. -- CW "33 Cu O 3.
"C GW to re
.......
"j " rfr'w; *
, -* '
- S-'fSrPtti*.
*^ > <*^v*
. ^
O *> * ft
3 T?
-- it
3 T? C rr
It ft
--^ bn -H
IA K
7
3 ft e 3 0. 3 -- - n
O. rr --* O
ft 1/1 1
r* o
n >--3 ft 3 *<
< *O.LO
. -- it
o
it "> a> o S 3 3 3 . -- Cl 4A
rr rr
ca
T7 -
ft "1 HO< Cv C
-- a. sr*o -- o
3 ft *3 3 rr
40 -- <-r ft
n -- -- e.
a CL -- 03
it re "I b (fi fr
< -1 ft rr
3
ft -- O &
-- c r* O ^
o --O 3 O
rr "7
1
It 3
7ft 5
Cl O CW rr rr
O3
m3 3 c
3 It
It
CL <t S v> -
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o <a 3 O
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ft = r "3
3-
r.
r rr ft ",
r" cl
--C C rr
la 3. O It
T -> ft < --
-h
ft ft X -- 3 O' O'
3 O ft O
O ft
ft Q 3 -- o --
-- 5 o c -- n
--g
3 0 0 -J *<
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S' ft
-- Cl O' O
T3 -*>*0 rr
oc c - LA O It It i rr r
33 1 It 3 Cl
4/3
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a ft
re -- -- 3
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rr ft
t 3 -V
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Cl --
o--
3 _ ctlo 3 3 re re
& o o -- 3 rr
CL -- CL 3 0 --
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oo
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it O
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O 3C Cl O ft rr re --<
-- *0 C. O O
< 3 ft
3 rr
ft ft 1 -1 ft C
IA 5 3 O 3 --- 40 --
23
3o --> 3 LA *< -- -1 3 O rr O -- O 3 3* It 3 O LC 3
O S3 n re a
t 0--0 *000 *0 3 3 -- re *7 or -+i rr CL o --1 re T3 "> -lore -- -- 3 fir "> O e+ re re re 0
re O la r* rr --
30
- 03 -re o. -la .
re LA IA I 3c n rr 3- 31
Or m -n -rn X r> -H
t 3 ft fl>
ft 7
*o - O CL. rr n 0 re re 3 o
o n-- o o n
^ < ft! cC ---- O"""
"S-S" n ft ft -- rr rr
It -3 3
-1 re c n< s
*'0 00.0 *< o O) -- --
n r3
C. la 0
0. "o 3 re a re re o
-7 < LA s re re
-- -1 CL rr fi<
LC
o re
"3
O
cl n cl
fir C
-- 30
13
rr
<O0
-- 30 rr 3 o o e t re r* -- -A ft
7 -- 003 o o r 0 a. -- *
- 0.c'"0 `
re 30- n.-Q.
CL O O
-- C.
ft rrLA o 3 r-
rr
-alC Cl
ft "1 3 O ft rr -A, ft. = ft 3 O Cl
-- -r. 3 ft O C-
LAM 011918
DPMC-08294
Page 8
-o > o> o I/O "V o &/ -- 3.
&< *< ft 3 ft 3 r & CL
l/i
O cl ~i 7C
m ~
O D --^ vi r -i
or m r\ ;
*< 2 o <
= m*o --h
o* o o rc 2n
-1 Or 7 -- -* 3 i/> ft
-n o *> o ft x o -n o o zr ft ft <- 3
CD O -> oC/ -- rsi r> -, o
90
C9 > -- r> O 03
Table 2
VIOLATIONS
Since September 1, 198S
(That W ill C ontinue More Than 30 Days)
*-.<! r---I $
oO C* ro tn w
CO
m <s\ >
09 ft H
n
3 ft
o
o
3 CT --<
ft 7
< O. 03 -*> 3 ft
ft fC
O*
--' ft
- ft o
go
X ft -- -H
so ."g
Q. rr 2 ^ &
7 ft ft "1 3
3 *<
Q.
C -ft
ft &-
O r --
ft -- --
2. 2 8"Oft 3
3
Oi O r> o
=S
-- r* ft r* --
< O ft << rr ft T ft
3 ft- ft
0 7 /*
ft 0> 'ft At
3 4rt
ft
a X ft -ft wiftrXJ --
f*ft
C ft
*< n
-- ft
o 7 ^ ft.
!>c '9 .ft ft 3- S '--.--.
-- ft Q. *
r> 3
c
7 a. O 3 a-
> ft -- r* ** 2 /i
. -** a> -*>
-- ft 3 O'
ft 3 ft
ft Q, t/* ftl -*
^ ft I -- -- 3 ft -- H r* ft <- ft ft ft < . .a. i
z< t no, -
-- ' . " T
r* -g 7 < 7 rt -- O
73 C -
rf ft -- rr c
7 * ft CD r* Q/
o ft o cw a> 03
S*1 r* Cl --- O' < ft
< : J ft
& -% ft Cl <
3
(
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ft ft <
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r * yXQ I
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r+ O ft < CD 7 C. <
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ft O
ft
ft x
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ft I r -- 7 --
-- ft* ft <
V CL 7 05*1 (
. Son
o -- 30
X
--I ft ^
CL rf 7 3 **> O*
7 ft -*v
3
f-f *<
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in ft
<t
oi --- 3 2 ft m o
3 3 3 cn ft
3 C V* --H
--3 C 7 3 a. 7 ft rt> ft
ft ft ft ft
7 ft 3 ft ft
O
ft ft
X
S
o
<
ft
ft ft ft -- r*- O CL
ft ft 3 <
ft ft ^< -- rr ft -- 3
03
*<
ft ft O --
ft 3
7 -- ft
& XO7 L & ft --
V --
ft a. ft ft 7 ft --
ft ft
a.
-- IA ft 3
ft -- Of ft * , fp -- -- ft N fc
ft 3 0 3. ft
ft --
2.1 =
0> 3 B 7 ft -- -- r* 3 o .--.ft r+ 7 ft -V>. .. 3 Vt . 7.
-- ro 3 am ft *
< --
ft ft
-*
Cl -- ft ft 7 - ft ft -- ft w*
LAM 011919
DPMC-08295
ST IT ne
3 O rr O
*< "5
O 5 --. O
O C=
3 3C O' O TO
a c w h TO 3 C 3^
rfi.O'ffi it (t u.
Sinn
no
-mo
-- -j rr I ifi o --
3'TO /
rr.no*
ft < O ^ -- -* 3
rr (T
<<
^ .3
ft CO
O' 5 *0
ti *< it It
c -j n ^ r* o ft -1 3" C rr
o it w n X> Vi -J ^ o -- -- o. ft
ft n o r it i -
*c n a. o a o -> 5 3 2^ 6 3 rn to --' TO CO O. rr 3 x
<< CL > ft
<t n
a
*-*0 3
ft o cl
-- O' It 3 O t <
3* 09 C --
O--
to m 3
3 3 r* 3ft --* t* -- 3 o r>
rr -i o
=r
ftl'ffi
r> 3 3" o*
r+ TO TO <S>
--3
O n -* a
3 --ft
> r -- TO
O ft 3
ft O 3 -J -- ~J V> -*
3 CL * CL
AO <0.-0
3
. Cl
--4 -j
TO 3* ft
< -- TO -TO rr O
-- 3- 50 ft
O TO to 13 a ic c
TO 3 --
ft -- -% 3" --I 3 -- i/> a* < 3
-- err TO C
in -- n c 3 i-- =8 O^o ^3 3 AO
-- TO -- -- i o n (t r i 3 -<
rr r o m "i n --* 3" O' C rr TO " " It It r ft. T! 3
Cl 09 ft O. ft. -- Cl O O 3 ft d rr O
8'- ol'
i- TO O " 3 *< i id r>
I --O .O 3 r 3 TO
3& tn 3 . VC O -**
ft ft t/>
i/ c
C TO
Q. TO
3 CL
d n n, *D
rr O ft
-- n
o 3* 3
3 -- ft
r> -- -- n
ST < o
O TO TO 3
n rr 3
ft. TO O 3 3
CL C
tO 50 O
TO
n to to .8 '* 05 3 -X) -- TO rr rr
no3 OO
-- 3 rr
a< a
C
r> - n T T
TO TO
03 = 3
*r. ft ft
T C 21 O
*i ^X O
' TO ft TO 73 3____tO_3 TO r -* n
O v* -- <
rr 3 l/< TO ft C O
=--
LAM 011920
DPMC-08296
--1 -- i --C
5 t: re -- s*
o oo O2 C -O
H o "1 O ff 1 O' IA *3 3 3 O lA --H ^1^ X xo O' <-* -> --| *1 rr X
Cl C.
<A
"3 *o re
o re re "j
3
re -- re n 3C < o 2 n
O O 3 X" lO re
O tc O
o
re
a tre
cr? 5 r>
O 05
i/' > -- --I o m>
O 30" o re 3 *0 CL 1 --- re
VIOLATIONS
Since September 1, 1985
(That W ill C ontinue More Than 30 Daysj
* . -Jj
o i -- re
0 13 O O. -- -- n
O "* re o
S-8 o
O1
O Q.
8?
X
re -
> -3*-V3<
.----* x re
*o .re
r>
o
r> 3
o
re r* Oi r
O f "5
^ 3 ft
C
-> * 3 n ' re o to <*
i/v (A --- re
re i -- * o.
s re r> . r+ re
re rr
CL --
Oo
r*CL 3 f n
o a *< o -* s- 3
f3ft X *+
* x -- a
re a
rr X
r> o i re ore
' 1 > -o re ci = s-i * .V* 3 .rr.
*o -i re --
s< a-a-re
--> --4
ft ft ft H l/i -H
2T o
i ^ re 3 re re re -- .
so a- o
_ o re --* o re ftMicfi a . 3r 3 ft -***
re re -*
1 Q. 3 O 3 *<
re o) -- o '
< rr
f
-*-* O O o
LAM 011921
n id -i
O Wft ft c n /to - o
O 1 3 r*
0o 3a -* --rt- rae
*0 41 VI 3 1 --> ID
O Q.1
3
-re re - n.
~i m < ^o
x --n n
aw re -*
*3X - s AV --
P3 *
re ---to *< 3
3C
C
res re t rt
;'"'jjjri'&S ^'v3
; .*-** -'Jr rr.
re an o o
2 oc
<X = r* O
3 --*3
*3
"* --' o o re
o V o ft V - re r r* C ia --. ft -- ex =
. a . -* Oj ' '
DPMC-08297
v.
i'-pi
*> 1*f'0t
ft
X ft
-j t ft H ft ft -- 3 3
0 ft
O' ft ft ft ft 3
rr -o ft
ft o
"O 3 ft I
*c rr O > /
ft -- ftk -- (
-- . o>. --:
O
O ft rr i
-i <r o ft -- -- -i ft o t
p w & r
1-1
> -- Ot rr 3 < -- ft rr X -- a cl o a^
0/3 3 ---' > ft b
X . --X
ft -- O
< rr
oc
ft -- -- 0 3 3
SO 3 aA a --*U3 *D ft*
-- rr X
ft -- rr O I/*
-- 3 3 vi =r to ft
--- 3
bs s
3 ft-
< ft X
VO -- ft ft ft
-- to a< 3
3 ft -- rr
M rr O ft .3" 3* rr
ft/ ft
^ *6
ft -- ^
lift sS 3 rr <-n
a. ft
-- ft
*3E
s ft ft
n co
rr ft
o *c
< o ft 3 CO.
o--o ft ft 3 ft
? *5
ft O
a ft O' 3
-- VC
<-- X> ft ft
n
CL --
ft <
ft
*- > n --<
VO 3
S 1 00 * ft ft ft
ft & ft -- -J -- ft
g-* -ft
3O
3 OO --
10
to ft ft 3 --<i -- *
X ft ft
8-!
3
--4 ft O
X 3* ft " t^ ft
* -- ft --
ft rr
r n O o
3 ft ft vn
ft O ft r* ft 3 ft ft to ft
m% ft C
at rr
n
ft trr
-- ft ft ft won.
ft O -- --
s --* V>CL 3
-ft --' r+
-- ft -- 3"
rr o ft a/ ft
ft 3 C .Tft o *ft rr-ft
- n 03X: -- c-- C ft *c
033
a> * ft rr O ft --* CD * . -- n n
..ft O n o
o ft `-3 5 ft rr ft x?
-- X ft
ft
3
ft 3 *< R ft --
X 33 --
-- a- ft va -/ ft
3 tf1 O
3 3*0
ft! ft -- ft
.3ft ft ^ ft
fit b Vi
a/
r --< ft Ot
X rr
ft -- 3 l ft -- -- n r ft ft 3 3
ft ft ft n 3 to CL Cl ft ft
-- C f* r < ry
O' ft
ft
>r 5-- O' 03 -*
30^ -- 0/ ft 3 t/> ft
i -- n ft v .
> A/. . roA . . rr rr *
-- 3`ft --
v< 5 3
O' < -H
3 rr.. i-O -- 3 > ft
ft < 3 *0
rr rr 3<
a> "ft -- n 3 r giok -- Or C -- O rr -- rr a n
LAM 011922
--
o
n
ft T --
X ft ft at v< ft ft
3 .
ft 3 a
o
-- a< >--
ft r r a 3 --
. -*< Z. -ft rr
3 ft *< '
030
=
5C I
I
DPMC-08298
^VfV.
-- -- ft m n
-- a<o --
ft o
.c
i* o c x> E. -> c o
0*0 v> ->. o_
ft --' c.
-- n "< r* O
-- ft-
--
ft rt 2 O
ft o r o. c
o --
O' O
ft ft 2 "5 -i rs ft o
5
f> c-- -i -- r. r* -
O o 2
cl <5 5
C3 > --. o O 05
O 30 oo c= n
O --< P" ft > =r --f w r.
O z no 00
S Sr4
cd -> O ft > ft O'
n > -h ft a*
--*- a< .
O ft
-- ft < *o a
O' ft
anc
to & ft 3 S
ft r* 9 n n f> iso
--3 -an n rt o
LAM 011923
a ft 3 rt 3 n
fr<
?-*
.rtag *
< Q. Cl. ft >
ft ft
ft ft o. a
CL 2 ft
--- n
Q. ft
a**o *<
o .* o x --f
O *o
^ *o --<<<
n
ft -- ST
ft -- 30 -- n
Cl rf c
CL r (5003 Lp ft -- L/1
so a ft a n
r* *< rt
ft ft ft *** re ft 3fi -- --- t c*
-- O ft -* 3 --' Cl 3
3 > rr n ) ft ft
ft CL
cl
o
cl a* -*
3 O ft C Cl
-- --
-
o3a
aft --rt ft
I " cs
* O'
t a ft a
> a * cl i -*
an ao* -- o ft a vi o n o a ft ft O) (5 n a o
frtt nC/t O-* a
CL * -t- I
O' n
/ r t c a- --
> e a
-7C ftft
< ft O' 3" -- Vl303
r* t *
i?
3 Cl i ft o
--c c O n rt rr
- r.-. .* .
v.
i ft
<9-'rt-A4
,;it .
> 2. C ft ca
- ft ft c
ft D. r+ -- 3 CD O
6 a ft c
. 3 X--
M n a. a. ft
-- c
2-3 CL rt t
a3 . -* cu <t
DPMC-08299
<x
cc ur
O' = C. "3 -- 0/ --' 3 D- *<
cp
T fD U1
*Tfh "
O'
re
c
x
o Cl ~ c
o c 3 r>
c "5
r> o c -re
o n
o
ft rr
re /i
t
jO ro CJ
.o
-- cc cc
ro (S5
cc oc cn
rr KT,
-- fD 3 "C C rr fD ft
It ro
r> c
3 O.
C 3 l/)
--i 3 3" 3- 3-'
' 3
ft (t ft
i fit VI Di
>- re ia c o n
-- 3 "re /> o O
N nre re 3 J
.ft ft ft
Cl ^
Cl Cl Cl o -- o<
-r rr 3 < a> --*<
x-* o C & .0
rr B 3
zr r* --- a. v a
S' 3 C
/>
ry o -tfl vr*on _ CD <-r
O -> n Cl Cl g *re r
o < t / -*
o rt o s o do --1 a. ->
< -> *P
CL
<t y -re t) ft 3 *< CL*
t aft vi
-- -- -<
o t rre x ft -re rrv< s re r
r* O O
s-- *D D
3- -*<E CP 3 3
<t O O f+ ft! <
P 7* -> 3- -- o <t o o --- c o r--
^O
O 3* O'
o - d. -- = --c o
*c a. ^ rr - ifl o *
o -re c *a : . rr Cl oaf5(
s a. 3 m -re
-re c/>
it o* <
a < rr x> rr <
-rre ye --j
so-rereoi
ft O 3 3 <
= Cl r+ :
-- ft -re
-**
-n O' *< -- s
. rr ft 3
-r n -re < < i
c C
ft -- *
-re -- 3 wi n
rr rr rr <-- --- f
S' S --' Cj -. cl
- C pm
re rft >fft
3- 3 rr O I
-*> O g 3-
-*
a --1
ft i o 3 n < re :
!? 121!
> * -- -- i ^ ft Hft ft rr (
3 S' 3 CL
I
, CL ft *<
-I
* : t r tjx ti
* S' ft -- o -i > 40 -re #t ft- <
f ---it. *i: n o avi re i
*0 3 i 3 O O- < r- --
(/i --
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rr -- -- -- </> -- ->
rr O *-*<
- 3
>
rr -- *C a> CD CL -} -H
rr -* ft c ft O S
ft 3 rr n * O ft
rr Cl S' a<
B3-
-- on
r -j m n
74
`*d CL
a__.__--____c__.__s_ _-} o
3
i ? =rt --- it 3
3T O O
o> -- O w </i -s ; tri --'3
3 c
i -*reT? O O
-- -> -re 3
Q. 3 ft CL^
O' ft VI
3O
r - O On
-- rr
-- 3 -re g v r re N rr CL 5 c =* a.
3 cr o
o. -re -- 3 c cl
r+ -- rr 3
rr r* rr Ok
O -- rr ^
rr -CL O
^ 3*
CL 00*3
S' O 3
O
C o o -re
rr
rr
3CL
-re O.
O' rr
r ft s o -*- Cl
O -J
cn
- 3 &. CL o
-re ,o*
o -JS.T5 c 3
ft ^3 ^ 3--0
< - 3 3
-j r* r- ^ C
rr 5 rr -re --^
-- -re O -- 3"
3 O O' O ^3
C 3 *re C "J
-- O CL -- O
5 vi
a> v> O
(O o rr 3
-Cl -j 3 ^ CL rr a
rr O 3 O -j 3 rr <
/ O O
</> 3 T5 -- i/i
-Ti rr D. -re s. -- *< 3
S' -- 30 ^rr --&. CL -- rr U3 rr rr o -- O --o s o rr < --
<"> o 3 3 rr
z
LAM 011924
I
i
-- o -S' . ^O. 3 Xt . - n
* 3 or -re '-O . ' wre -rre 3. r O vC a ft ^ -- U` --
re r C- --
a
c-
o \r
r~ -
O O cn
3 S' >
i
-ca.
Cl 3
3 "I CL I
, \ ,
DPMC-08300
i\
Page- H
V!
ft- re i>*> ire
1/
n> n re o m C CO o no <T>
CO
*< u r. n \a O `S' C r-
c -c 3O -f "1 V: o>
re CL
> C>/>
a> a. t/i rt> O' o> m O cn ro *-. cr
--
an m
e tr> o cn
Tahle 2
VIOLATIONS
S iiu fi September 1, 198S
(That U iI i L u n tin u e More Than 30 Pays)
> X O' T3 ^
* S
D. -- rt TO -- ft re -- S -- a
. n r* n cr a r> --
-- re a o> a 3
i/) *D
Of
fto *6 -- o>
-*> tc 0^3
-- re -r a n*<
a / re
ft
a> re r
-- a c.
rf -- oa o
cr c <t CT fB 1 3 ft 3 O a rt </> os O -- c r> & < (TOO
C ^ -hT3 rr -c a
o a re re c a n o. . re
- 3 a*.
x fi."< _ r+ r*
no
>
-**0 0
o r nC C
o
c >-i a. re
sore re o "5
O' <-- to -h n si/i re -- s <* c -re -- c 3 re 0 33 -*- O 3 0> Q. ** Of O. * <*re as
rr -j &X) re o> ' r* a
re of *<
3--`E3 m3
3 a * O' O -- re n <-* a --* f-- re re vo -- co.
re o r* <re Bi -- Of s -- r* 3 3 re o --fO &
o> -O } aftf c--i a!- m --' --
r* O -*> --t re o o s
a. Of &> re
"> 3
ft Cl
O
a 0)0 c. "C a b
re a. "o
^ ma* tm-si 3 n a -- o> *<'
C r* "l : * *c rv o re o re r* a >
O r> -i -o o -: re re o. c < <
re -- or re . r a a.
O r* re -- c < o o' n o re a -- a o. oa irce -iaa r*
--o a Of . 3 .- c
-- a cv re
</ o- a. re to "5 O'
. cr co re ^ a re o > *< -- a, re o a o ft, m
re r* tc re ft, Q.
d. a 3
re re m
: r-t' Of '.O ;
m a
r. < rr a Cf re -- re S re o. co re rex
o/ re a % *.
-- c </'
< n c -- <~
re cr c r:
sr = c C. -- <-* Cn
i o<
re -- --
a/ n --rn- rne ' "<
LAM 011925
i
DPMC-08301
"* **
oo
ft 3<
-r, Cl.
C < rr -- -- ftc~ c~ <x> --I ft C ft -- re
r-j c
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I
DPMC-08302
r, -rrrrmimmii . o
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f ft. ft
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DPMC-08303
Page 17
W*
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Table 2
VIOLATIONS
S ince September 1, 1985
(That W ill C ontinue More Than 30 Days)
m a> -*<0 ** X" *H cl - ->*--'
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DPMC-08304
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LAM 011929
C -- O
3 DPMC-08305
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LAM 011930
DPMC-08306
~s~mrv\-r'r--
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LAM 011931
C c.
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DPMC-08307
* - ..v-'.V-.V.*.--- -"Vf
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(si o ore
o (SI ft
ft CO"3^
o 3 -
Cl-O --.3
3--0
O O<
ft C 3 -- -- ft
ft 3 re *o Lr c
c -- L> o
re -- ft
> ro< O
--- -- s. -- O' o s re sr irt
LAM 011932
o o
DPMC-08308
mr..tifv win rff~~
r-*--- '**
4*'>J r
.f*
a --
<>r>
o 3=
rr *< 3
j r\
I-< o
-o
Oj ft
IV ft
^ ZH t3 t o -
^r-r qj f"> I --
-- UD *-- -- Cl. "
-n J* -- n-. >
o T3 ft "
ZT Cl --' to
r *o C rr
r~
ft* ft >
i f ft <
rC `ft
Cu 3
ft *
--* n
* o
3 ft
3
.<
r* -. *< *D
r tu *o O n rr
&
) 3 ft
-->*3
*< D *- > 3 --*^<
* t. r o /6 r - rr -- <n r ifi rr io
O =T .
-- S = > CL
v CO 3 Cl *C
rr !
Cl iff C, T3
cr
3 ft b
**ift d'C < "J
'
n-ft l
i
- ft
i Q. V)
-v 1 <" ft CD Oft 3*&0
3 -J
ft c -j o
ft 3 3 2"
*1 & 6i
&3
r* o
SO.--rf3nft( - T T r ft -* o c* D ft
- n o "j
LAM 011933
ft O CL ft ft < --
<-* 3. ft
--3
0"Of3 = 3-Hc/r*
ft < -*
ft (t --
r 3 ft r ' X Q. 3
3* I -j --
&>
ft 0 -Lft
J
DPMC-08309
Page 1
TC
rsj c~. >
-- {ft O C= ft
o o> 3 C
TO
ft o o
CL o> Cl <
O' Cl Cl
c &
OC C.
w o.
i-< tr
p cf
I ft. JC to IO m
r> o
sc
o
v o ID
ro ro U)
ct os tr w
Xo mn 3 ft -o -* in ft
Ifl VI T VI - 3 -* < --
O ft ft
cl a<
Oo
Table 3 VIOLATIONS Since September 1, 1985
(Approved fo r R efe rral to A ttorney G eneral's O ffic e )
-L>^
O' ft > ft C> -H ft cl -- ft 3
ft a. c ft -? -- rp ft --*ft V -5 -t*
Vi O' -*
O' -*
o os --- ifl * ft
*< c ft O. ft
o> --v* n 70s
<
-*
. -- ft -- on---
O ft -*
ft a- c ft v
o -- -- ft o n v ft 3
v> o"c ft O'
6 o -J ft 3 3 t-. ft -- ft *< ft ft -V O 3 3* o ft -> c
ft o
Oo
f3t
X 01
<ft/>-
fftt
* - "ot-* ft
ft Cl ft US "1 ft ft co n
ft U 3 V(t
7 O' CL
ft. ft ft.
A - T ft
' -*
- =
vi n *-- ft o
ft ft D --<
ft- * ft
n S ft o -- ft
ft VI
Oft
ft c > O' 3* -} ft.
Q. -- ft -ft o> -*
ft --* --
o < r>
ft
-*- t> vi
oc
ft "i < 01 n ft.
.ft ft ft. ft
o ft- Cl -
ft O
ft --
ft VI
ft V -ft -1 -- ft
O'
-- o> *1
a
-<
o*
VI ft ft ft o<
ft
O
ft Sc
ft. ft Vi 3
ft ft ft
ft- ^ ft o* O ft "> Vl
ft ft ft i ft* -1
ft. n ft O ft- ft ft
-> o ">
ft
CL ft* 1 t -1
CO ft
2.
--
0> LTi ft ft
CL
,, ft L ft ft 1/1 *< `TD'O
` ft ' CL
.--> O' ft
ft ft
--
ftiy'DftT-'OI-H
necftfto'ft
ft -- -* ft JO ft ft
ft- ft vi o. c ft ft
O
O' --
Cl -> ft
ft O 1
O' ft-
O' ft ft ft Oi ""* *`
ft
CL
-ft
- O' 09 VI
ft OI
o
ft C Cl O'O
ft "5 ft
-1 ft . ft'ft
ft
"1 CL
--
V> ft O C O ft -*
O -* ft ft ft I/I
ft ftft < -- ft O ft
ft VI -- ft
a. ft
_s
ft ft 2T5
a-- vi l d<
-- -- VI K
ft ft ft c
*<
ft ft ro
-- ft a. -
VI
ft O'
n -*
vi
ft --
ft ft C
s
CL s o 00 l-. <-5r o i
ft ft ft
ft ft ft
ft Ci o ft O
ft
ft V> ft ft
ft ft
CL O ft ft CL ft . ft . -ft
.ft - Of ft'
' *1 *> * ri *' O O' -- L O
C r* Sc s X a ft
lo c v" r
r* -h -- O' ft
C v ft --
LANI 011934
DPMC-08310
C ft > ft) <- lA o it r
(t C. -
C= X c --' ft
2$ o oc
3-3-3 -- Cl- ft
-n 3 ft *< O.
r
i w5'
ft 2 -- ft
ViOLAHONS
S iiic.i September l , 1985
(Approved fo r R eferral to A tto rn e y G eneral's O ffic e )
-- *
--. 3 O Cl C --
<<
c> ^ ia --^ (t 3 3 ft?
I3
a O fD
'ft f*
o
ft S *ft ** O i b >*07 o .
a n ft a>
os 1/15
ft ^fit1 ft Cw
ft -* ft
S1$ *c* n
3
<_>. O ft cn
C 3 ft Cl a "3 --1 o ID ZW^ --- c 3 O ft -- < -) CO < Q. ft
3ft
3
<f S ft 3
3 *7 LC
n ft ft ft .ft
CD --< ft S' 3 ft
- ft ' lA
O O3
- r-f O
O ft a- --- d. rr *A ft
lA ->
ft X
o
PsJ ft 3 ft ft
S' ft 03 ft ft
ft ft ft ft C -ft
IX *A
a c ft
O *-
CL
VD rr C
0)0 w
ft 3 r* --3 r r > o.'-rf
l-*C 3 3
ft --> if) ft r* CA
3
3
O' re s lc ft a ru i a. ft -- 6- r> :
a: a3 > ft ft * O' ft v ft. r* ft *< r* -- r* er s
er e> ft !-* ft
C -- ft ft 3
ft
*< ft a ft < lD *
< & ft
O-
w ft O- ft O tn
-- ft
lC ft
C ft
,*>**/*
4
CD 'ft --< '
nj ft r* S'
- ** Cl
o
cr
-- i-r
o, r: ft c c O S -- ft Cl
r- >
x o -- 3- ft cr
ft ft 3T ft -%
rt 3 w
ft --
ft ft
----
Cl -- < ft -ft
C -- ft tA
r+ V) O C
O
O -- -- ft
O ft ft
r* ft -* r*
-- a -- 3* ft --
ft 3 3 ft ia
CL. 3- 3 iO ft ft ft
o *<
V
ft ft ft * X *D ft ft rft ft r* tA
<r* -ft ft sj CL 3
ft KJ' *, CL ft
*o> p--
ifl Z. C. >
C <~ 3 ft- Cl A -j
ft
LAM 011935
DPMC-08311
Paye 3
Talile 3
VIOLATIONS .
Since September 1, 1985
(Approved, fo r K c fe rra l to A ttorney G eneral's O ffic e )
I f s e ttle m e n t cannot be reached and a d d itio n a l c o u rt a c tio n Is necessary, then I t may ta ke 2 years to re s o lv e these la w s u its .
CTi
. re ft -- n v> 3 =
*m*."- 3
nO O
O n&
c3
*<
o
O3<f
IN re
O3f
OS
3: o cT 3 2l pV. 3
2 <-
-- o C.
o
*<
CP> O c. Cf s/s
o--
>r> c
n&o. <c-5=
V> t/n
O
OS
C *3
^3
?i 2
rDOo XJ 3 "O
>a i --a
pr t/*>
O- -- f3t)
1O -- re
n vi - o oh ft 3 -- re -- o. o ft =r
3*
-- 3 "5 Of -*
O 3
t3 TO
XvVi
0> *3
VI
3
- ft
Gu ro -> n j to in
u> ro vi ft S' ft
o.
*m+ * N *> ft -ft "5 X> 0 3
MN tO -- WJ -- 3
. ft -->
"1 --
-*
r+
ft --* sO ft t/i
NJ Of CD O.
OSf
-o*,- -* s--'
p* t/> -> ft if
P* C * PI -- -- Of O ft
3 3ft -* -> 3 0 Cn cn
ft ft ft o * 3 Q.V O O* pi -H d n 3
S2 8 S' O ft O *< 3 S cr
-1
M
O'ft ^ -- C- ft -
c Of
--W a> 3 ft* b *1
if
o wft 5y
fti
S3 l/i C
ro
n
r* O rr 3 re
t C Of * - ft
-> -*,n
d
ft d *< -- ft
ft UDifin Cl. ro oo co "i
<0 V> U"| ft
n O3f O ft
E5
*- 3 O -- Or*
*C rt ^ >*1 o to ccc.
i -> ft -j < rr
ox
-- -- 3*
-5 -o --'
C ft
rVrtio--
n -i o- > -< r* 3 r* ~
>3 ft --O' -- pi
> t-- -- 3 -- o
C 3-|
i -3 <* -- < V 3
f C -- -ft
I I o <
3 Cm X 3 -H ft o* o ft C 7
Vi -- ft
1d c or Of
in Of
-t*f*.ft *n<
f-t*
3
O -2
n ft ft ^
1 fti
Of
ft .if r> --^ 3
ot ~ ft -.VC
n --< o. c
rr < i-- v> s* ft c so <* r+ o a a cco wtfi
d ft 3 S' S' -- O. -** * ft 3* - t/i 3 ftpipi
--- d -- O
IN> tf n O3 *-<
" 3 Vi "1 ft * O
3 O *<
-%
pi- Ow.
s' re o --h <
v> re s* --
d 3 ft O
-- ft ft
--
+> a. n -- Of
.Of -- pi
O' ri --- ---
3 'S'*' -tft -
' Of tf
3
eu r*
q t/>
C3 s ft zr
UOH3 -H ft ft S' ft S'
3 f> 3 ft ft ft
n rt ft
O.
syn ft-'On *H*;ft. r>
-r* - ft "
-h7y>
o
O' 0.3 3
Of n O 3 f^ *<
hk> -- /~i -W-
------iA
n vi ft v*
re o>
fOt. --o 3o O 3- 3f~
X= v vi C-.
-* 3
ft C Of Of S' C
n- -- 3 3ft *
p n C
3
--- Of
3 to
rge oik ox --c f*
< n3 O
1 re ft
-re- o i re. - ft.
.Of*<---.a. -o . --^
S' ft
n re
ft CL -- = r-
a t/i n - n C cn 7
ft Of on---
3 3 r* 3 3
LAM 011936
DPMC-08312
Page 4
ft. -- -- fe <~> O' Cj <"
-j O = = C -5 5 5 -e
a-D-cr os. as o*c
O' c rnr
21 -- 0/ O' -- S' a c = = o re -1 2 1 -V 3 =
-i O O --
--O
a> -i %r T3
vir si
yi Q O' O'
O c
3 -- *< < o o
-o re -i rr
a> is> "3 o
rt rt O C
j O *e o<
o c re
re s
a> -- re o
s- LTM/
. <~v s^'
jC 1
3--
Table 3
VIOLATIONS
Since September 1, 1985
'(Approved, fo r R e ferra l to A ttorney G eneral s O ffic e )
ey Or re e (t -? 3 3 C => O <3
r* t--. <e 3
(t C
7(t e in ?e c
v> n o/
o> n 3
rt.--j s' n -re re
O' rt.
' S S'-**! O' o> * fe
O' rt -- re
--*
VO S' CO
Ift It Oi
c
S' > it rt (*
q. v o n r rr 3 -- O' o re
t/i -- O 3 -e
re o- -- c. O S -tv
rt S -- re re -*
r w n ft *< --
--* c -- o> -- re
re -- c --' 3
s ~ -cr < re o 03 9
300
-- re
rt o> 3 O < o rt
re noy
Cl --* --
l/i CT3 ft
(ft
re *e 01
o re
n
d e J it > o o
O tr S' O
*34
r*
re -- o/ O
C. < <t <s> r*
CL Z S' DSC
-- re O' 3 O'
-- n la
Ci-Vi TO a. -- /> fT o> o c re 3*
I o< r 3 ft e a
> T3 3 n ^5
fD
e a * [v fs e r
rt O b ft 2 Q-ft
yu
--><
v> re . O
O' - re
vr vr
-- rt O cy
o
.re o 3
-Ol
H3 < rt
t
3 r7!
o--
S' re *
o--
O' o>
re /*
ic rri -- 3 re o r>
3 30
o _3
< 3*0
U
---<<
O
3
--O'1<o<>
o> 3
re o/
-- rt
V<
rt s* Or *< ^ 00 rt i/i b rr^. *e
-C l *
O
Or
re -- o cy U. M</
a rt 3 3 re vo
?e -- o. ft COft
rt -j re
i vr ^
re
o- i rt ^ -e
i S'.re re ..
i-l ft r & re o* i ft i/i b l/i O S- O 3 "> i o -- ** > o 2. < " -o rt . re c
o.*c
> --< > C. > . S' CL C > re cl --c*.
-- << c -e rt Q. -- -- --vo
-- O ro3
re 3 fe
O' 3
-- - rt
: o -vo.
i/ < CD -- 171 O'
-5 O
Li
re i^ib e it
re rt o 3 -e -- zr rt n o -- <e
>d 3 ere 5 q. vr re i rt cl
rt y --
O O' 3 O'
<0(0
rt re
O'
S'
" --
It VI C 3
--rt ui
> 3 C rt
rt o n rt ie ft (t
O
S'
-- o e O' o --
rt i--*. 3 re o. */
3" re it it o
*?
rt-*< .
3
71 . -
. f.
ce cl s s
re o c -c
3 ft
b
It C VI 3
e =- -i = o `-c
O' C 3 -- 3 r> c
re i/i rt i/i d i/i
LAM 011937
----c ,3 rt e
S -- 0 3 0
- 'IT
Vi DPMC-08313
*o --. r* 'C -> *< *** a, C** rr
o rt ft -- a. -*.
O' *c
o -c x -> o o c. -- - <-T -*<
Cft 3 -- o C 03
- rt c. c o= O "O
-< c
-- la
c or *C
Z "O
LA ft "O -J LSI 3
a *3 o ft on
>= or 3or <t
X n3
3 o
3 rft
< C
o r~> 3 3* iA --
* '
*> "I -- > --1 O -H
(6 (t fr r*
ft --
r^r 3 ft
o -- r&
n o -i
3 3 O --* ft
*< wit 3* A
1 O
O
ft < 03 3 *rt -*
ft nr' . -J CT-?
o ft o -- ~ ft ft irt
^D . 2 ia o
3 O *0 2 0
e -- O <V
3
t-*o
-r. -- C O --0--3
n . ft --
O --
-* o r\> o o --' v*
O ft O or 3 -*i 03 ">
W ft
-- "1 .(/I'Q, o a. c
aA-X .20 O' o*
<t v or c
Q. O
S ^ or cfl n>
-- < X -? <
or O ft --ft T (
x^- 5 3 M ft t
IA ft ft < D O- j
3--
(
r or
C. O* <
i o *
1.3.XC-
rtj -- r* i
o X. r O n v> ft .
--C _ r -- c. x > i
&> ft tf> o* i
r r
o* c+ (
r-- *O O' C <
- O-- 3 -l*
13 0-03 Vi 3 ft ft
ft -- or a-
< X
r* X 0--30
O 3 < ft -
7T 0 3-
3 --- ft ^ *o < n <
-- oo o --a--i
o -- -:
ft
<a or
c. -- -h O :X c-- ---CCJft -Wt
O *< 'Ol '
3 u. O -t
OOftX -- 3 3 <t or
or or
X
=T ft> "5 -T> O
4/ Cl o -- O
-ft -* X 1/)
O O3
-> X `--X o .o --
ft Cfi
ft--OOO -- CL O 3 O 3 or
ft c o o o 3 3*0 O
rM C *< 3 3
O . -i X c a
ft ifit c v 1 m El o- -
ft O OMT O. o &>.--- 0.>0 3
=o ft o 33
--O oo
< -- c a ft Cl'
ft i i t o *
C. d r -<
*<
X i-
ft V ^
-- O O ft
37 -- Cl O
r- t/i ft 3 C
LAM 011938
DPMC-0B314
Page 6
Table 3
VIOLATIONS
Since September 1, 1985
(Approved fo r R eferral to Attorney General's O ffice )
I f settlem ent cannot be reached and a d d itio n a l court a ctio n Is necessary, then i t may take 2 years to resolve these la w s u its .
c c? f--t' o -a}
-- 3 rt -v .
O
it r* a
\ o-- rt
nr c
rt
r> T3 5a
O>
--o ro>?
jr*cCn- Or--oo6.cc3r--aii-'iaj it 2 o & w i as n 3
(D *j rt ft pt --*vO rt rt It It W
t* *-*-* 3* v< 3 s' rt ->
r>
-- (tore-** ft'/'C.&oso
rt. ---V'. 3
3 ^13
--S 3*3
It i
1/10.
rt? t-- ----- r-^ -
rt ^
CCS
It ft ^
7 I/I rt 3 a
Silt J-t, 3" ->
ftp 3" 3
1ft It (t C fr ft rro--- *<
rt < ,3 a> v> o -*v>. r*
a. 3 n
r+ -tt
3*
--i i/i
ao,<3a<3' --
3" rt 3 3 -- & U3 -* P< O C vf>
rt 3 rt -- 7
T v It 2 3
rt *< -- a
w IP Or
rt rt --
3 3> r-e>O rt ft 3
Cl Cl. & 1 ft m 0 `
k O ft
sr rt rt <
1n
yf *
n ^ at
rt =r rt -- o a. "3 rt
c < 0/ -J X
O. rt
-i rt -- o y tl ft t
rt 3 -t, r cr
O<
-- rt -- rt
rt -
vooo
rot.
-->
3-- an1
n
*-J ST 0/
rt
rct -- o> at
v-- c 3 T If
.ea..rt- rt rt.O
o03 --.
6V> ,--r </><> c 3 rt it 3 tk 1
ftt' 3 '
r* rt ts>
-- rt i
-) rt -- r^ fcrt
r*
ft *3 -- rt T3 --
ifi -1 r
= 3ca C 3 Cf ft T O vo rt -- -- rt ^
tl 1 - 3
8 -33 3 if O
3- S' rt a
.rt < rt T3" rt
-- 3" o-- rt w
rt
at
&<rr>tr
-r-*tj
k*. c at o us
G. -- n
rSt'
S;
X
n 3 n> -- (
r3t rCtl--< *
rt
rt O
-* 3
tvf-fi
rr-*tti
at rt CTi "J
3 tft -rt c . rt
' 'js\.r* . - .ex
rt
rt rt-- O. Ct.rt 0.0 3 --. --
- rt 3 r* *"
rt 3 -- 3
C rt
rt tr -- 3a >
rt ft < r r j - "
3 rt l O 3
LAM 011939
DPMC-08315
v-r
-c---
.v >>1
JO O 3> oo 09 -- o tA O a? re
-s o r*
rr -i o 3- 6, r
C !-* C --, -- tA
-n 3: &
<> I --CA [ ^O
ft 3 c-
CO o 3 (-) tA o c 3
Hi c.
r> ts
fic. O' 3 c ->
cr
o
oc
a- *o
C3
2g
> a> o o *D
--> o o 3 ft
Cl
tA O ro ro
3 ft ro ro o 70
a: ft t/*.
/> cc 09
to
tr> \
o3
CL n o
*1 n ft
V: ft
re-- to C
S'
o mo
oo
rr*o O -t O rr r- fiy
ft
< x
Oc
> O'
3 ^ m o & B 3 ft o
-
ft
rr O
O
rt v w r to ---*<
O O -J
z CJ to
3 o--<
ft
frtr ft o
3 ro to
V: ft a yh a ft
I/)
O 02 ft CO 3 LT ft *1 ft
tA
o
--' O -- ^> -*--< o C"> --<
ft ft ft 3 3
rr
ft (-. <"> O O 3 ft
r* tA
3C 3 c -- -- C ft
-- C
&,r*3Cftnn^>
ft -- I
o w rt t a --
f* ho rv. cr rr
.
r ft 3 f \fl
3 . --- "T
-- 'c-
ft
m cr c 3 -<">
ft 3 a vO ft
" ft 00 93
ft n
>^t cr
0.0 3 S n --* ft -- rr i o - y
< --* o o n
7 -Ut I
o
Cl <
sr 3 :
ft to ft X
Cl cc re
< <
o -> n Q. f
r 4
Cw ft CA*0
-t *3 r a>
Cl rt*o 3
< f rr *<
Q. 3 r
tA O' 3 ft (t 7 ft
-- O 3 _9 ft /t O *i it m HTO (t
c -- tA rt 3
-- ft -* ft I *3
tA -1 3 3 Cl -- <
^
0.t0 *3
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*o ft
--
i > US
~i
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' rr Co -- n
O 33 W--C* &.* re -- ..
o
r cntOft ' 09 Cl<i
l "Pi - CTr 3 rr
IA r+ r+ & 3T rr t/1-
C- It ft . a. o
tA
I It WHO
. *< c o
Cr n r*
. rt tA
D-
t r&
I ft C. 3 -O --
ft C C > ft -- r*
3 ft- rt-
r r o
rr-O
. 3T -v
ft ft
o- zn 30 3C >
p ft ft * ft ft -T < trt ft 3 *< u
ft c . e
O -- - a. -- W Gi
3 U! ft
ft --to
3 tA c ft =r to in as it
ft tO ft 4A g 7 ^ A ft
6* -t O
3 to n 3 3
.3 -CD f -* O 'CL- 3
W3 to rr
3 rr - ft VO tA
O 4 tft 03
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>C It rt r* ^ 3 O' 3
-5 3-
ft ft tn o cr ft
tn m
-- CL --
^ >3 Cl rr ft
rr n -- -- a.
rr f rr 3
f.. wO O
-- 40 *
C- "> cr O 40
ft 3 It 3 -h* ft-
O' n < r ft- C -- < rr t< 3 -- rr 3
a C 4A
a o. o o. < n
(O ft o -- ft n rr 3 n O rr I 71 c -- < =r
It ft P = ft- -- -- rr ft- ft r o tA
--1 3
,3 Ct- Oto -- m .gr tA -1 . 3.,rT- 3 '.
--~
cc
--&
tA O O O --
rr -- O
a ft,
ft z 3 ft
-r --C NOT O ft - CC ft -- *n rr ca -n
O E.: r.& vi
n t
o a 3 -rt
tA < tC O tA rc ft
ro C
ft 1 Cl ft 3
m> ft 3
LAM 011940
DPMC-08316
Page 8
-V* -J 4< o*o n 7 ->`
O r*- >--
a. a.
736 to --
o-- o o rr
C C -- 330 rr "C 3
*< ft* 3 O. < 3
n ft *< <2 o 'c
o> -- f> CD
Tf -0 3 C5
O --& ft -j -- C m C~
m 3 3 *< a
ft ff ft
~i
O O II ft 1/1 1"
---- 3Q
tn O Cft O > 3
V. n 3o 1 m Nti ft 3 3 m m n> 's* '-c o
-- ft< m m
-*
C. n
-c 3= C5
a> it ft ft
tft
rrm
m
o a-- o
--O
3
*" 3 tft *o
'
Table 3
VIOLATIONS
Since September 1, 1985
(Approved fo r R efe rral to A ttorney G eneral's O ffic e )
mm
O ft O *7 7 1 O. ft -- v> T+ n> --
< ft
> rr. tft CO 73 ft 3
o o rr to -- *C5 ^ 7 0 7 - 3 O' O
3 n> -- 3 0
ft pt o n O*o _ 3 7< "!
--
ft ft o
<t
0 0/7 Q. -- m3 -- --to v g
3 o> js -- O *< <C 3 J7 .O/
O' .7 <3 ' 7 --
*r
--* O' 3
rr o' c 3 *
*3 ft rr rr
ft -- d
"j O/ m ft
-- *< n i
O .Q. ft 7
tft --j
o rv)-) ^. O no/
ft -- 7 - ft
ft o k 3
- (ft * *
m --< tft O
n
(tO
i-- ft ft 4ft 3 O ft
o> ----- -- to n < 0 0/
ft < to tO 05 0 ft
ft 4ft O'
7 ft ot oo at ft --
3 ft 3
ft O w </ Q. if y> rr
Cl
^I
m--
a. n &fr
n ft
ft
--* 1/10 3 --rr n --
rr -- J> ft 3* ft 3 ft
ft
ft
ft -- < --o o
ft o-
0 3--3
3 " -- --
O/ 7 7
3 ft
rr O
-- --40 (fi 7
3 rr *-> tft
-**D
D O V) ft O - o/ m o n
7 t* ft
n * 3700.
rr ft rr 3 3
o ft -- r>
It ft
-- -- rr
tO ^ -m ft 4ft --* --
&*f
O tt
7 4ft Pft
O rr i< ftft
-
... -- 4ft
rr 3
* O' *7
rrgoo.ftoao
40 rr ft tft tft 7
Or
{ ft O' fr H
ft X 7
7
VO OC7ft
a ft c O 7 -- ft
(ft rr O -- X
a ft 3 a ft
O O' 3 to
O3
o n <0 -*>
-> n
o> 3 o 4ft ^ = 7 --T5 It O 0/ 4ft 4ft 3 rr -- v<
OO (ft 3
-- (ft
*
7 ft
"1 ft O *o r * 1 *7 (ft o n .e-7 o -* ft r ^ n a`
-- *< . o -- 77
g-- 7 7 7
(ft ft ft O
o/ tft 40 rr 40 ft
-- rr 3 O/ O' CO "**
n n 3 -- rr -- 3 7 ft
ft ft-,to
7 7 r
o (ft <t (ft ft
oo
7 rr
O$--
7 -- n o ft -- n o. ft
2..
< ft
-o T.
"t*
n O'
rr 3 7<
o. C ft o ft O 3
(ft -- 40
It ft< o> m m
ft -- 7 7
O' o o. ft ft
3 O/
n n>
3
Of o
m rr ^
40 3 -- -- m3
7*
it ft O O *<
(ft (ft ft O'
3n
i C It 3 - 3 o. * ft Cu -- (ft 7 ft 7
3 ft ft < a.
ft c ^ (ft tr ^
yuy rt
n o/7m
(ft it ft ft n o C ft 7 0 rr 0/ <-* 4ft 7 ft
-- mo -- 3 ft ft ft
-* ft ft o-*o
ft a
7
n rr
O
nO'
C -
fv ft ft
7m 3
O.
71
oo3
to rr ft _3- tft 7 ft 0 3
n .it m
"i.^p . m`3 f nffiftiA.
`9a. =r O
7f1
O' --1 7 m -m o --
ft f
ft
C7 J
e. o
o3
c
C 3 O --
"C
-- tft r> 3 tft tft n
rr a 7
C C--
ft >-- -- .7 --
r -- a. m
LAM 011941
.-y.
jt
DPMC-06317
Paye 9
Table 3
VIOLATIONS
Since September 1, 1985
(Approved fo r R e ferra l to AttQrney G eneral's O ffic e )
I f settlem ent cannot be reached and a d d itio n a l court action is necessary, then I t may take 2 years to resolve these la w s u its .
30
o>
--o o CD
g --< < re
t. r* l/> C
75 tS> V- o
o re C .A Cc
sc o wft>)
&c.
L/1
C
ng
^ Ov
v- -i
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3 *0 re
< & i/i
-- t/. S3 re &>
o
c
s:
naa
3 O& O i
lo -h C- >
t
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Cl
a3roe. a-s--> r*
o
co
o
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G -n >-- --i r> m>
zo CC *A 'G a- o 3O r> ^ re
CD w-- C CO -1
o
z
ft Ci rf X
run -- c re -- 3 ft re 3o ct &<
3
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ft
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rf 3 r fti
y ifl O on c n s -- <tc ft -*
n *<. re
a, ft ---GO
CD 3 fD 3
O fcO 3 |b -f f* 1 3
ft (T ^ o ia re o S' O - *D ft -- 3 it
3 tA <3 3 "J
n & re
ft *n -*i
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3
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r re 3
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r - < 3> --i i t - ft y
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i --o
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re o' X 3 , - GO
re res
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ft a. n -v =r
l/l C b --1 n --' ia
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lA
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vd re : 03 <"* i
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c a l/l 1 ---3
c -- r vc
3 3- rt o' o re
3 -re re o <a *n
x
re o
ft p 3 ^ ft 3 tn
3 re re c o
re g n
s Uic ft
> re --' --*\
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3 ft, 3 < fft
*5
3 re
re -- *7
ft -5 o 3 fort
- ft -- c o.
t - *o o o *- ce
-so:
* ft n t
-sc --C f -W- l/>
4A
O'
LAM 011942
DPMC-GS316
70
m C*--P
O z
7* --1
O' 3 <3 Oj << o
in ~T~ Oj rp 3 CT in 23
O o3 cO 3o <3 3
3 o 3
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fP 3
31
3O
Oc
3 tO
3o
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3 03 3 CO O
3 El Oj
<3
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33
3
c
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CL
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3
Oj fP CL 10
oM
o o3 co 3O ft 3
*< "3
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CO CL
CC 3 o3 cO in n rt O in 3 -j*
O z3 OJ 3 31 3 OJ
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on
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3O
<3 3
< to
3
n
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o
CO Cl
2
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33
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3
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3
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X*J X^J CP XJ XJ cr
30
cr fP
3
--) 3-
Cl fp Cl fp
fD 3
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to to OJ O
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3 cr fp --'
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rt rt
3 O
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3 fP
fp CL
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to
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3" O
fD fP O
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Oj O --j
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CL CL
fP fP to
to 3 fP
to
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fP 3 Oj -3 C.
HO Q. a
fp 3 3. c 3 -* <3 *3
rr (D
<3 to 3 OJ tO <3 to rr
3 rp
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O<3j
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CL
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<P < c 3 .
X fD
OJ
fP ' -3 TP
3 CO
--* --*
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<3 O 3
3 OJ <3
'f<3p3
to
-3 Oj O-u.
<0 --
fP Oj to 3 <3
Cl --
fD or to
--- Oj --' Cl
cr 3 rt fD O 3"
O 3 *C C
1 T ft
fP fp to < OP fP -* O 3 0 0)
t<p3 (Ca a3 CL
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33 rt --** --
3" rt <1* fp to
< CP --o
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3 Oj fP
Cl rt x.
--*< fp ' -3 O 3
0 33 3 cr> c-r
OJ CL O 33
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cr 3 3 CP trt 3
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3O
CO oj --J
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c *--
03
O -H r* Oj
CD > cr to --4
fD
s: O
Z <3 co
3"
3 fp
LAM 011943
DPMC-08319
Beaumont Marble Company Beaumont/Jefferson County
Cultured Marble
VO vD VO
CO CO
TO
CD 00
O
CO CO CL CL 33
>> 33 rt rt OO 33
--4*
Oo
DO 2 CD a X3 a* O' 1
fD O o c 3 ct
m ^5 CL fD CO -- rfD o
to -u a> co CO CL to 3 **%* rt*
so CL tO < fD TO 3 CD -4. ry
n d. 7C^<
o3 o -* CX
rt O
<< O 3 n -j fD ct fD
CO O CL *0 3 fD
CL > rt 3 rt- <
O fD 3 -* 2 O& \ -5 03 cr (D --X fD &>
"3
r>
o c 3 rt
sa CO j- r+
to O L (D o n
3 0-3 O CL C3
3 VC rt
--i a3 7C
<< CL
3 CL
--H 3
CL 4<
fD n
2 Cl 3 C -t, CL o c rt c J
> TO no --n -* 7T
3 << VC rr 3 OO 3e ^3 --I rt a> & 1 -* "3 3 CL 3 03 ft- L
3 O 7C O cz 3O
rt rt
*< fD
O =3 "O CL
3 Vc
3 . . tC
TO o. s: o 3" & CL a> --* 33 O I-- CL
(D to *s%. CD a-- fD 3 3 05 O rt o o O &> -o 3 rf
to o O3 o O &> c --h rt 3 fD ct -H Ot< fD
X CL to
o
CO
o
CD c
o DO
o
m
-<
o TO c rD
a> rt
C *< "3
fD CL
X
2 ao
"3 o cr 3
o fD *3
fD rt
fD
O C
rt c 3 fD Q.
2 CL "3 tr
fD
"H O --4. rr Or fD fD n "3 7*r to
a "J to
(O 3 rt
"O -j. -3 3 O to CL C
n rt
to
-n --H -<
cr "O fD rn -> to O --* -n
CL
to -n
to > o
05 o rCL rt -H to -<
O
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oo ro LO --* --*
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ro --< D m>
CD
05
05
cc 05
05 -H
cn "nJ
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` *' ` .1
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o cr -J. -H -j fD 3 3CL fD CL fD fD 3 --t.
3 n -t
to to CL O
C rt --j
n cr fD -4
fD 3 CL o
-O
C. _i.
rt rt
3 O
3
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to
fD
CL
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o
rt c
3* O Z3 fD 03 3 -c
O CL O CL rr 3 o "3 3 w
CL O fD -o % to CL O M< 3 "3 fD r
Cl Q. o
CD fD to 3 to "3 fD to
to rt
rt O O
m*. O rt
c o
CT 3" 3" 0) rt o fD Do> c
"O CL 3 fD 3
CL "3 CL
ua,
fD 5 -J- o
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rr to 3 cl to rt tO rt
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3 rt ---O to
.fD <, C -3 X --* CL
"3 --1 B -o --* -o 3 rt 3 -t>
-* CL 3 CL O --< rt O 3 rt a> --i.
to --* --i
CL --* to 3 <-t CL -*
X. -j-
3-
to
CL
-- CL S. --*
^3 rt O ZT
O "O ro C
-> 1 rt
to < co
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-o -o rt fp fD
o -> n
33
fD to
oo <- o
O "3 &> ~3 CL an x
--* fD V -t o B O 3 X3 *1 l/i rt
CL O Cl 3 O > w> T3 "O rt "D
O --I
3 o rr Q? CD
n -HOC =r 3 3 to =
'** tD 3-3 O O' -- CL < fD "3 to
Of
to
ro
O 3 in s CL --J m o < c N4
n o --i
o r~ a > cr to --! Mi
--< O 2 -C^ rt CO 3" 2 O o
"3
3 rt
LAM 011944
07/30/86
DPMC-08320
Wintermute In d u s trie s ,
Incorporated Paris/Lainar County
Wooden Plaques
7m0
C7>
o
Z
n
tOn
,t<oor
70
O
o>
o -n
> *-- --f o m>
Ow
"5 0 0 3"
CL re CL 0)
(D 3
5 O
(A (/) fij o
C rt --'
rt>
cr rD --1 3 Cl o
JO --
S
c
n* o 3
no
CO
fD 0_"0
/ -5 O
rr -- O 3" O 5
ro o
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oo
o ft> 7T 3
O "5 3 --
Q. O fD
o --"&3O
-i
fD
<S> r.
0.0.0
fD fD cC 3
i/i T (D to to rt
rt O "J
O -h O -* o
O rt- c+ rt
O' 3* 3* fD
a- cft o n o.
--< rt*u CL
3 fD 3
Bi ^ D-
*3 O. sJ
fD = -- C
--' rr "C 2 3 rt fD
<-t CO 3 CL
to rt <0 rr
fD
o-3
*L -5 rr CD
O.
jo w
fD < c 3 X fD -J. QJ
3 -ofD -J --1 fD --'
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rr 3 fD --tv
-O
3
C--L
rt
3
rint
Q>
O-*
in
fD & -*
to 3 rt*
O. -*
fD
&3" CO
O. X
C* 3 rr
(D O 3"
O
-o -o. c -J n rt
(D fD to < CO
fD -* O
3rt Oc
ft> -
fD .cn O-
O.
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OPi- 1fD f"D
rt -*
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<
D3 O
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O. rt x
fD
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3 *0
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o> O Cl 3 O 3> co
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rt-O
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rt -< o -H O O 3* 3 3
fD co "O
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&; < rr "5 fD C
Table 4
VIOLATIONS
CL CO
fD
3OO '
CL
oc-C5O
r>
fD
CO
OZ
"O fD
lam 011945
02/02/87
DPMC-08321
8 7 -0 6 (g)
CD xj
00
xj
CD ao xj xj
CO xj
co
xj
O
50
I O
as
1
o
o
o
as On 9v
I
o as
oI
as
O
W 50
toHi
aO
O'
fit Z
o
E l Paso P ro d u cts Company 7 /1 7 /8 7 2400 S. G randview
$ 3 ,5 0 0
s HW K in pi H- Olfi
k
to to
aS to 50
-3 CD ft ft ft
xa
(0 H- |
hz
KXT
h*
X
o
03 0h
0
(T
0
xj \ H> xj \ 00
o
<A CD o o
no sr*o
H ft 0H C ft a ft N HC9 a -ft
o 00 Hi 9
o OM 3* ft M ft 0 ft c a cr
ft rt 0 tr
o H* ft
3 ft
' H-
ft XT 0
c
ft
ft
Hn
XT VO O M
H- 0 0
h3
ft HD 9
3 0
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n
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ft - h
3 9* X* 0H
X O 3 0)
pi HO 9
(D fit CL o X* cn ft &
x4 \ M x4 \ao xj
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9 tn to
to CD
> ft 3 > HftH< 0 CD ft 93
H-0 Z
0 ft
0 XT *-3 h* ft 9 ft X to ft tt HO
ft
M
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xj \ x-j \ x00j
x * n
0 CD 0 C to 3 n wft ft 3 O CO 0 9 ft XT - ft ft
Hi
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tt Ht-1 0 ft ft 9' ft M
9
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ft C *0 H* H* O 3
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9
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3 33
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xj \ H* xj \ CxDj
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ft H O ft ft H- ft O H* ft H- O
ft ft .crK ft
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ft tt 3H CC Hi O
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LAM 011946
DPMC-08322
F a ilu re to m o n ito r fla r e p ilo t flam es
w ith a th e rm o co u p le /u se o f therm ocouples
ORDER NO.
RESPONDENT
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PENALTY AMOUNT
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LAM 011947
DPMC-08323
CD
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DPMC-08324
003M HCI/155E01
LAM 011949
RESPONDENT
W indsor P la s tic s , In c .
00 I
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ON
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DATE ENTERED
7 /1 7 /8 7
PENALTY AMOUNT
$ 1 ,7 2 5
VIO LATIO NS/REM EDIAL ACTION
F a ilu re to .o b ta in p e rm it to c o n s tru c t and operate p a in t Bpray b o o th s /o b ta in m e n t o f p e rm it ai)d
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DPMC-08325
ORDER NO.
8 7 -0 6 (x )