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/I f2 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. 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O' r* fD fD ---O tn <C 3 CO fD 0 o n --- a> ^ fD n fD 3 a s id Oi 3 & O --1 cr O T ft W a. -- --j fD fD a> -- T W 3 rr fD n - o' to fD --- Oi Xi --* Q. t c -- O' 3 rr n fD o 3" fD O "O -o c rt -5 -J rt1 or fD <D (D to < 03 fD -- O 0 3 0 a> O 0" C n 3 fD tn Cl XJ OJ O T3 "33_ rt fD --O f-D3 CD 3 3 </> r+ O' rt fD O CD OO -3cr a> Ot fD Qi O. ft X -- fD 3 O3 O 3 T3 -O -) t/> rt fD "3 Oi O 3a 3 -- o ^ tn *or+ *o -O </> rr O O -- --4 ->3 0 3" CL fD <D -- rt x -h -- r> fD O O 3 <"* 3 3 "O O' 10 -O rr fD & -- 3" 3 o o a* -- 3 n < fD to Cl fD cn fD "O & <o fD ro o 3 to 3 a> --^ to o< c O O --I o r- & fD > O' to -1 -- fD s: o rt* 3* Z O -o fD n 3. rt 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-. 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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 -- - -- O o c - 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 ft "O co A ft z. ere rc *c ft < re &- -- r> f-r C sa r-- re *< lA f I I O v 1m LT O r\> "O z o -o ft 30 ft *o re re ft 3 s3 va <25 re u> cn O O' o ft <: o 4A 3 l/i f cu ^ O' 2 G. -> C 1 g it i a> 3 T HO > ft ft ftp 3O r* *C < -5 _ ip m ft ft 3 O it f^ rt o -* a. 3 > 4A ^ ft* CO ro 50 -- -> o o ft QO A C co z . re -- 3 o O & ft ftp re o. o -i C 3 c ch -} -- 3* a --* G. 3 .#3 -- 1 r* -- O' -- w - _ e* 3 r* ZI O -*i -3 O' ft O n 3 C G. 3 ft ^ ^ ft- ft fZ --> 3 C. IT C **Z -t> 3 -*> f~r z*3 ft --I S 50<t*tCftC3T0-- 3 3 O. *1 f' *1 (5 ft fA *o ft 3 ft Q. f--t*-j3ftO3ft0f3t 3r-Z->r> rr n O < O O t "O T -- O 3 OJyni re rt --* ft 3 r -h re *3 ;o 3* 3 a. ft 3 l 3 0--* *1 O O 3 . 3 3 3 ~1 f--t1*fDt ID A C "5 "1 *3 ft- 3 -- n 3 ft ft . a*- c n re -- re re re A Cl 3 Af ft CD re 3 O O. -- *< ft re re re --< rr --j ytfl n a ft *w ft -- AT ft ft 40 r* 3 (A a n in o o 11 *3 (PlO 1 3 ft SA re 40 --* O --3 I . M rr | 3 ft *0 G. 3 a. O 3 re , G. r*"- * *.4/1. -Q.-3 rt -* A ! A { A& ao -- -- r* 3 G. r Z r+ -- sa c c. re 3 re *< ^ re c ^ c, re re -.x. x= 3T s: ---- o' ao v* t --1 c -- -* O' --* ft o n- .3 re 2 S' r*- 40 G. -- Z O A C *1 O Q. O A A It 5 re re re < 3. a ft re -3 c:re < o re * -- ft v re -- z (/ ft 3. <-- IT C- .T "A 2 ft o -- -- G, G. 3 r* r s > IA - o 3 0*1 -- O > -vi -a3 -a r*- re 4A *i re ft re a n 3a n 3 i/ a at at -* --^ < -j -- re c re -- o S' a- 3 <a ^ ft fA <A -c ) - re a re *< ft LAM 011926 I DPMC-08302 r, -rrrrmimmii . o 00 00 r> n o o t; ft -- O CL -- - *< W; 31 C *"<? 3C it ft '-c X r> o 3 r> (T> ro or C* x ft - rr O 3 O O Cl O 3 V) Vc o c r+ ft aa. --1 3- ~V o o cn CD -J cc <r 3 c. c. 3 >> n r* c. ~ 3C -- CO a.' --o ft "5 </> 7" </ o o << c: o Cl *< LT o u> r\j CO 3^ -r Cc 3- 3 -- -- r> rr n*c o 3a -- *< ft I 3> rt ro > -- -- <r> CC rr, > CT> C Z z c 3 3 .Cm rr o' r~ > -- (t O z ro t/i *>"3 fr> rf rt H ft b b 0o 1 in o o I (V 3 3 CL*0 . -* ft ft 3 -- Vc L ft o 3 Q. in ft 1C m CL SCO It It ft fifl n <t -- 3 -10 -- 3 O .* -i * ft 2. <5 O O' -- O ft c-- O ID ' 3 ia a 3 a- rr rr * < ) fi ft -% rt 0 3 0 3O -a^ ^8 IA ft -> o 0 ft 3 < Cl 1 a b in ft -- o -- rr CD -1 O *3 rr it X b -j rr < 3 <t r* O3 . rr lO "03 3 3-- C r-> -- O ~ Q- Cl -. Cl -- --O -- t -* rr a> 3m V" rr i m ft CL I X. -- o -* ft J rr - 3 3 Cl --3 O 3 #o c n to ft rr o 3 ft, rr > * : 03 3 roc I Ci -ft * ->v* f CL " * rr > -C O ft > ft >n o oo w3 3' rr-D CL>ft3'3ft --I <t -- C3 < ro r -< rt ro ia It <t o r *_ rf - <* -- o '. It ft' o o .--CO rs '* 11 *c a. I I Cl -> 3 O I 'O. s ft -6 LAM 011927 f ft. ft : 3 -o o o< * --.5 ft *< an o s . -j o.^ -- 5 re jia ---3 r> '3l o It 1 o o 'X: C C5 ft *0 -- ft CL C O C rr *3 O -- ft ^< O3 3 tO t/> rr t rr 3 >-- 3 --O 3 9^ L -- ft -- 1 , rr 3 ft -- rt n & ft it re > c m c !-" c --o --^o "12 0 3 3* X 'S' "'2 1 w ft b r 330 3 <-- 3-- ft in 3 o r> n o C Cl c 3 r 3 3 It o -- --tD C CL'S \-ra *C1; -%tn ft o ia y y n r+ 3 -< ft ft O ft tr r* a -- :3 C 3 dC -i 3 c. 5 -- r I I I I I DPMC-08303 Page 17 W* 3 cr cc .o -r c -*> --o CO Tt *C ft 1 C fD a re c yi OX o-- C r+ ft <- -- << 00 a > o o cr v< C '--. ") _.< O --O 5 in H OX & rv^c o Table 2 VIOLATIONS S ince September 1, 1985 (That W ill C ontinue More Than 30 Days) m a> -*<0 ** X" *H cl - ->*--' -> o. < ft *P *- re TO fO o - *9 *> it O * re o -* s 3 fD to Of ft C C7 fr u ---Oft -*rre k- 3 v: < v -i -- r* x 2cr->a- o a> o Cl re < o << n X -- -- o * 3 --* -- n t/i 40 O' S o rf 3 1 o o * o to i > (A 9 i t3 x i ft -- * I r -- H J re n roe ,r<e, r7', -' -- O I -> I o. re < i/i r. re c : r r fr O' (t o ^ n -i re re = C--- : -- -*> re xra` 03 -i wx ^ S' -* ft n o --* re *5 *< -* cl c n < *> * 3 O. (I ft n ft Hrt X 5 n re -- -* o -* 50 J ft 4A 3 "> X -> -- re 3 c O "1 ft o CL ** --5c3^ --3 - r* f-tt . . . ft - rr 3 | C CL * o a *l n c x. vi --* re c* c *< 3 O C = rr -- X X ft r+ re cr -- - a r: o d o re re rr Clo ft/ irt ft/ ft/ -- ft no. -- * re cl . .. cl ft re -- -5 *7 t* w ft o. ft x <- -- 'CD - r* 0X00/ --* & re --* x o> < i/> re n -- On O/ <f re x x -h -- o. re -- rr o O. ri- re o n ft/ O O' trt o. re -- n re n- --` ft n r* r- O V --c -- LA O x re , xn re re o LS-S-i yi -* &> r i/i r -* *< / O re 5x X Vi re & ns - < 3: X-- c o. < re -- -- v> X <* 40 -- re ft " x ftl ft --* ---f.4re0 On to *< re X o. n =r -- c o ft r* n v> re o. v-- LAM 011928 DPMC-08304 -t--s.--s* 4 so CO cc -n ai C `c -5 ** 3- o- c -c ft o> c C3 la CX yi o --> ci 3 oc rr la -- fc-> ft O' X ft ft o CC CO > o ft o ro cl c. T 3 3 . a. o 3~ r- 3 o u> CO rf o -- --< sO -7 rr O 3 3ft ft c a: 1 ft ft n mo ft -- 3 3 3-1 3 rr X ft -ft n 0 3 0* o ft ft O 3 rr ft 3 c *< cr n ft r* ft ft 3 o> . 3 rr LA O' O' O' ft 4/1 X 3 -- 3 05 ft ft o o --' O' -- 3. -i rr i O ft Cl ft i <t <. O 0. "30 O' o ) ft -ti rr 3 > 2 o -x 3 ft 3 VO < *O w 4 3 r- rr -i < ft 0t ^ Oo' -- > 33 ) <o O' -- o -- VO ft 3 co 3 lo rr 3 ft J O' n 3 ft 3 rr o ft --43ft -- on 3 -ft o s o ft C 3X C ft ft O la On j: 3 ft -- ft c *< ax O r r ft O3 ft x g o ft ft O' O < ft 3 3 --3 C < ft -- -t, ft -- rr t rrft^ rr O < . no O3 O* rr -> .' O *o C1 -- ts-<3 a o no o- o> a. T rt ft c. w. O' vO ft o O r> ft Q. ft OS--ft O' C 8 Is. C. 3 * ft O' ct ft ft 4/* *< ft -- 4/> : 3 ft 3 a * ft -- rr ( VO *ft ft < ft rr 3 3--< o, 3 X O rr O' O' ft 1 V) C VM ct -- ft 3 C rt ft -- la o* O' : iiss fftt o 3 Of -- ft 3 40 0. rr ft ft ft CL ft ft Of O ft -- a. Cl ft 3 4/1 ' rt ft . ;Q.0. ' . .'3*0 -O' 9 o- ft x - O' 1 r, *. r- I rrvio^S -H ft _* -* -- ft O' 4/> rr ft rt *nj ft 3 00 3 PV> ft 3 0 0 o ft cn ft C O O' ft rt 3 ft -- 3 . X a ft rt x O' CL ft* l/> ft 3 3 ft -1 --* O* 3 3-- ft 3 O. 3 *0 ft 3 LA O' ft r -- ft 3 ft Cl ---4/10' Cl -- J ft CL is *C ft 3 3 --Oft Cl rr -- 4ft ft O ft 3 -- a Q. -- c o c -- 4/1 3 3 0 >3 3 3 ft ft ft . ft ft X < ft O' rr CP -- ft ' . *1 ft 3 -- * rt '-g- r 4/i. . < , ft o ' CD *ti O. -*X O' 3 <- 3> LA --1 O; -- ft 3 ft -- *0 3 r* 3 ft 3 O X ft .*C ft0ii/0*^3ft--' s;i rr ft O ft O. CL'Cl ft ft CD 3 rr O' ft 3 X C 1 -- 0 3. ft rr*o --I rr B` .3 ft --1 O' yf* * a -- o 3 3 ft r* ft -- O' O' 3 4/i 5 <-r r* ft r- ft cor fc . . .-03 3 3 40 ft ft - < 3 -ft o* 3 o o < --4/i n c ft -- ft 3. o Cl -J `C O -- o --* 3 O O X! rt O' ft 3 ft rt v< 3 k- ft -- rr ftifiSr- ce 3 3 O' LA O c O C ft rt -- wfftiffrw - 3 -n in 0 0 9ft - - Of-ft -- O' ' _ ct ft 3 rr CL O' rr D3 -ft C ^ C. O' *3 ft o C- ft I_ 3 ft CL ft c. -- LAM 011929 C -- O 3 DPMC-08305 BW --,.4 tO tO 2 C3 O' "5 n r- - C Ll r-> C - CL C"j n c. -- On r* c = -> re u t< re -c sz c 2o O CL rs c -o --, O' CL -- C r"s o re Cl Cl re "5 4< o X Of 4< cr n . .O ccc </ r+ to -- --O O3 3 40 40 o . >-- --4 r? m> Of x re mo n 5 re = o O' -c t< O' ^ o re c. rr 5 -1 o cl re X! &<0'"`rD-- 40Q.O & c* ; : o *< x iB-i l r* O . > re 3- 3 3 --O 3 0 -*.*< o 3 *aac -> h-o 3 <-*- o =r --* * o> re rr O' in -1 r x e 40 CL r* 4 sr : sr re o 3-1 o Cl 40 f o re 1 -5 -i Cl -- re cr * -O re c c re O' 40 re c* -- re s -j -- -- 3 3-X 0. - 3* to % S -`* C -- 3 rr O' ^ ** r+ 40 re -*x 3 3 O' = 0,<04>r-OreO to---re^resso. -- 3 rt Cl C C N f ft r* O Of re re & oi s' rr . rr .^o. s 3 re -- bo., -O I'.t *rL' "T'X 3 -->. o 3 --re Of r* -- \S SJ <S ~~t S" r 3 c r* C* < --> re O -5 "> t Cl 3 CL O' CX -H C rr- O 3" n re -- rr -- re O Cl . re -- 3 jg re o xno >rt g to x ^irtrr fii a -sO O Of 3 O *< -- JO 3- to re -n o < --n "*> re -* -- o re ^ o> re s o cr re x n o o fi X X re 3 x s re SO- O 40 ft c n o x -* 3 w y n o r* rr a, --3 -- -> re Of Of O O 40 X r* -- o s re o re s 40 re o -ti c to re -- re c c to 3I re T rr o 3" OO re to .5 x -- -O. Of -ir -re r> -- Cki -- -- x 40. -- *-r -- re -^ to. - -** r re to <* Of o s' 3 c re cr n re -* O' 3 -- O 3 Cl re o* son -- re r x re ft rta'to X 40 re rr 03 T -3 61 rrit O O ^6 --' 3* Of X 3 3 re " " ~i Of or o -- -- T< Of n -- 40 ^ CO Qi o to o> --- 40 re re re 3 0-5 <-r re C 3n to -- cos ooo* re re & & 3 = -- -- O' to -- o re -- to -- c -i 3 -- re -- o r* cr sore to re o < -- x ft n c- cr 3 ^ & o. n re re rr 5 40 to re O rrto --< 3 n O' O' 3- 3 3- --!0 re n -- n Cl re ct re rr s. re c - 3.T5.-A-X *` re>-- o. Cl o> re c, o > c. s- re re to CL 40 C O r- 3 -- si --i 40 C rr " 3 " -- 40 --f re * re i o re 40 x o -- "> 3 .< re x re 40 O' re s 3 *< -- rr re o re re 3 5-- O S fi. re rr i 4< s- to x -* CL > -- re X 0-5 0 Of ro - CD `>x rv Cl- xe -* -- 3 r- O -- to . so fi. CC re *>w Of rr C n - --< -- rv . O- '- re s -- < -- -H 3 re ^ S' --> t C' n 3 x c. v n LAM 011930 DPMC-08306 ~s~mrv\-r'r-- / x3 O O Cl OO C r cu x o> 3 i/i CO a -C 3 O 3. --3 3 CD O 3 Q. ox o> re . m -. oco d 0/ rr 3 ft --x 3- Oo c a. o o v ro o co 30 cr> X 30 X ci a> - ci c. o o ft o o OX oo Co ^oc o d o 3 lH i oc cn CJ ro O "r ro > -- --i ro 00 m > X -1 3 9 X OO o< -- a. r- 3 d o> co o CO LT ci o o o> o> v> 3 iA *,^^0'*t*0'3'3 0'-H O _ x> q. -) ct n * rt -- d > n n o --* ^ < ft t> r> i rt 3 -- 3 3 r * O. rt -- r o o 3 l -- -J 0< *< rt X o o> . rt < X 3 3 -- < c E O "5 pt m x r- 3" -- O' X 1 3 3 n o> pt o< O' -*i 3 3 o rt --. d 3 X 3 --3 - r* X ft-c O lO f 3 O O -- "5 D. C O 2. S = ^ X rt X -- O' pt o. 3 a.. 3 3 O --d 3 o --ft ft i 3 * -* a* -*i 3*< oco 3 ft a> o rt n < -> 1 -- O' 1 30 ft 5 BX O' ft -> o. -- vo -- x -- < . --* Cl -- n tc -< pt o ci ox o O' O' ft 3 -- X a -j 3 TO O' O 3 Cl n -- O' d UD X 3X d --X o ~j O -* Q. rt rt to - O 3-1 o> i r *0 (3 *< C r- 3 -- d o rt rt O 3* CO O O' or o- 3 -5 a- v< c- O 3. -- pt d x fr Ol/i 5 T -- n 3 0--0 --- rt .o Cl o -- 3 pt i (t> t) "5 .O' O' 7 3 --< -d xn Os 3 5--0. O' 3 rt -- Cl pt 3 x *< OT rt 03 ^ a. -- O' ci X n ---- J 05 O *< O3X -ft tf> o c> n o Cl CL cr o hx -- 030 3 -a. o 'TO CL O 'DD C - CL O X O pt pt o o --33 3 C O' X O --T -- Cl r- l< -- t; 3 ---3 t` *^i X "t r d it h o o --' 3* "i 3 fffty C -- O' o 3 O' 3 I rt g .pt c 3 rt c O O' O' 3 !a X Cl 3r 3 O rt "1 D a *O O X 0 33 o g" a -- -- cn d 'o X X o a* x rt < rt ^ rt c 0 3 1 O Ci ft 3 ft ft 3 3 --> 3 pt o 3 m 05 3 --'1 O' ro cr oc a pt -O'O O' *< oo o OX O. -j X : O. -- WO -H < 1^3 lC0'3 > 33 O r* -- 3 O' X n i t 3 : C- 3 a : ft t & : " 3 r* - O p - C* O O X -H i -J O --'3* as cv n O Cl 3 o -> -rn o rt o X -- -*. 3 3 0 -- 0 --X o rt 3 O' O --3 3 3 > O' --X 3 0 3T CL 3 X oO1 d aT Cl l O' Ol -- a. 3 3 rt rt CL ft ft ft -- 3 O' 33--0 3 O O 03 0-3 `x "to. 3 ot 3 O' O.'X rt. : LAM 011931 C c. - n i- DPMC-08307 * - ..v-'.V-.V.*.--- -"Vf "D 5* S 3 is. oc re -- -5 ft O f O rft c -! O C oG -- S' -j (S> XJ o i ft -- s c fe es r *< -n "O O' cr s re fSt' & re a &3 OO c r> -i s 3 "O o ft --> -- S --' -- v< o Cl m3 r> xo O' E t/. X C ft o rj c 3 *s re re B o o 3' Cl O J --. O 03 -o 3O 0-0 co S' A CL o o -h tr. -c O -- -C * ft re rM -n v> > -- CD m > S' ft n m "C Xm > -o o > IS> O' re /> r* o (SI O -H r" &> > S' A-- S VO CC OJ Cjv G o A *< trt re o ft a ft ft *h s -- s -- cr s m t fetio < o re re re < re o < re =r re n o o -- re *< o re 3 o "v rxe va" o* 3 re re re 3 v> re a S X o *a o 3 o -- -- -- *< O' --os O Sid o ** re --c 0 71/16* 3 3 ft u> o oa a re -- * re -- re o n os -- ft -- s re re S CL (SI c3 re oreo . c- s- o -- C ft c < os < -- re *-* ?o ^re -vi ft Ore* re n re s * -- -- t: ft o vD n s* re s cc o c = *C ft -- 3 3 -- - -- * O i* O -- --^ c re - -- re > o c --. re ft s ft oo.su> o re o. O 0*0 ft Oi -H ft -- re s re s o s re ore re ft uv ft. 3 -- re io o -- 3 re o o .4 O -re S' 3 re re re re *o ft0 0.0 _ ss t O ft o *< -- 00-0 o 3 0* sr o -- i ft s s o, o re -- -- S' tn -> r> re to o -- o re o. o o ft ft re o re o o' o a fe-o < --- o. ft -re re --- o s o re *< re * re re re S V> X ft O o -- ft re o< o ivrt -- -to -- O (/> o cn ft -- sores re O Cl -- re ooc re cre re o o= Oo os o =3 -re -- ft re s s -5 *< re ft re 3 -- -- o n no if re s' < o r> co ft O 3 . l/v O re os c --o -- O ft 3 re ud O CL 3O S' re *C S n g. c- re c re re sg o re -- o -- <o O 3 -- (SI cr -re 9 o- CD ot-r <o re s(0 - s re C O re i < re *: --/ 0*0 -- -re re ft *H ft -- vO O X) U> s O ft 03 cr re --3 * s' > re s u> x> o re o os so re cX ft re;re ^ 40 ft re ft s a- re o ft res -- o o O S' -- (si re o ore re . O O O CL 0 re re o re r> o 3o 01 o o re -S' SCO -- re re n x. re -- o 3 re !=l X ft re (O O O TO (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. 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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. 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' 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. > . 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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. 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