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Compliance Performance & Management

We believe our environmental compliance is excellent overall. But we will always maintain the attitude that there is room for improvement. Our challenge is to maintain compliance and improve performance while our industry is in transformation. We face uncertain fuel markets, aging infrastructure, and pressure to keep costs down for customers during tough times, as well as a regulatory environment that is more stringent and complex.

Compliance is the foundation of our environmental efforts and our goal is to have no significant enforcement actions1. State and federal regulators conducted more than 190 inspections across our system in 2010, scrutinizing everything from physical structures and procedures to recordkeeping practices. We received notice of three significant enforcement actions from regulatory agencies related to operations at our Amos Plant in West Virginia in 2010 and thus failed to meet our goal of zero enforcement actions.

The West Virginia Department of Environmental Protection issued a consent order addressing 11 permit limit exceedances for arsenic and selenium that occurred between Jan. 1, 2009, and Jan. 31, 2010 from the Amos Plant’s fly ash pond discharge. The excess levels were the result of changes in the pond’s chemistry after the plant started operation of a new flue gas desulfurization unit (FGD) and other associated emissions controls. We made temporary adjustments to the FGD system that returned the levels to their permit limits. Our long-term corrective action is to convert from wet to dry ash handling and storage, which has been completed.

In March 2010 the same agency issued a Notice of Violation for opacity exceedances at the Amos Plant between 2007 and 2009. The agency proposed a fine of $234,000; we disputed a large number of the alleged exceedances and continue to discuss a resolution with the agency. Also that month, Region 3 of the U.S. Environmental Protection Agency notified the company of its intent to fine the plant $306,947 for alleged violations of regulations governing the timely reporting of releases of anhydrous ammonia and sulfuric acid from the Amos Plant. We strongly disagree with the EPA’s assessment and have submitted our response and supplemental documentation to the EPA.

Our Environment, Safety and Health Management systems continue to evolve and help us improve our performance. We continue our work to conform to combined ISO 14001 (environmental) and OHSAS 18001 (safety and health) standards in our fossil and hydro plants. We expanded our use of electronic document controls to create a sustainable platform that aligns with the standards, creating consistency while allowing for flexibility. This knowledge capture helps to ensure that policies and procedures and operational controls are centralized and kept current.

Our internal audit process provides checks and balances to help us stay in compliance. We conducted 21 environmental audits in 2010, focusing on procedures and controls in place to assure adherence to environmental regulation and dam inspection and maintenance programs. The audit process also identifies best practices, which are shared across the system to improve self-assessment and overall performance. One such example is the use of a propane cylinder recycling system to safely remove the valve core of near-empty cylinders and assure any remaining gas is vented to an activated charcoal filter to prevent releases to the air.

  • 1 We define a significant enforcement action as one that arises from events that are within our control, has more than a minor environmental impact, and results in a fine greater than $1,000.
  • For more information, please see EN28 of AEP's Global Reporting Initiative G3 questionnaire.