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Whatever
| | Posted on Thursday, December 10, 2009 - 12:53 pm: | 
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Rule and Implementation Information for Equivalent Emission Limitations by Permit 112(j)
Ok, here is the Clean Air Act summary of process concerning the MACT Hammer provision.
http://www.epa.gov/ttn/atw/112j/112jaypg.html
Basically, it is my understanding that the 2002 list of HAPS, Hazardous Air Pollutants was actually mandated by Congress to conform to a deadline that Congress set on EPA. MACT (Maximum Achievable Control Technology) represents the actual standard that an industry must meet.
There is a due diligence process that any agency must follow, including the states, which most often are assigned enforcement authority and tribes, such as Forest County Potawotami in northern Wisconsin, that have won enforcement authority from the Federal Government
So it is not just, hey, the President is making this law unilaterally and then he is enforcing it. Same for EPA, they do not have unilateral power over the executive branch. Contrary to what popular media espouses...
If you look at the MACT HAP Regulation of the Clean Air Act (follow the link above), there is a process... this section of CAA was proposed in 1994, revised and re-proposed in 2002, and in some instances there is still litigation over the actual enforcement provision...
It doesn't happen overnight without any public input. Also if you look at this link there is written response to all public commments that EPA is required by law to respond to.
Please excuse my crude understanding of the Clean Air Act... I only have one year experience dealing with Title V permits from an industrial perspective. My Clean Water Act experience is roughly four years... but you get the gist of how this actually works if you look at that page you can tell it is a long, slow drawn out process.
Also, mentionable is that EVERY permit, wether it is an air or water permit, has room for an application for a variance to be granted.
ie, lets say Company B has power plants that it burns coal for to heat oh, lets say the upper midwest... it has attorneys and accountants do what is called a Cost Benefit Analysis... which would basically be a study that says, if we conform to this standard by, oh lets say 2020, we will face bankruptcy in 2018. Then they submit the study to the regulatory authority (state or federal) and argue that they need a variance on thier permit.
What the variance grants is an exception to the rule, but only following a certain enforcement time line, such as oh... this is our Best Available Technology that we can put in place by 2020.... then the regulating agency says... ok, we do not want you going bankrupt, so we will allow you an enforcement date of 2025 (at 50%) and then 2030 (at 100%). It is not an uncommon negotiation process...
Sorry for such the long post but this is my passion. How these things actually work during implementaion stage is a very complex issue that I have tried to summarize here... I apologize for any incorrect information... I am not an expert by any stretch of the imagination... |
Blake
| | Posted on Thursday, December 10, 2009 - 01:16 pm: |
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Thanks for clarifying Char. I feel better. I certainly appreciate a clean environment and see a need for the gov to see that no one's irresponsible actions threaten the well-being of Americans.
Pushing propaganda and pretending that CO2 is a pollutant is just outrageous. That's what has me outraged. What's next, oxygen (O2), water (H2O)? |
Hootowl
| | Posted on Thursday, December 10, 2009 - 01:21 pm: |
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The EPA is run by ex-hippies who have de facto legislative authority. What do you expect? |
Poppinsexz
| | Posted on Thursday, December 10, 2009 - 01:21 pm: |
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Also, mentionable is that EVERY permit, wether it is an air or water permit, has room for an application for a variance to be granted.
Has room and granted - key words there.
We are fighting this very thing right now in Appachalia.
Legal permits were granted for a surface mine. EPA pulls the permit for review.
Wouldn't be a problem except that this is the 4th review. How many time before it is a defacto denial?
And yes the Exec. branch appoints the head of the EPA and guides what policies it wants enforced, so at some point it is all political agenda. |
Oldog
| | Posted on Thursday, December 10, 2009 - 01:47 pm: |
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actauly I thought that water vapor was on the list,
I think that the CAP and TRADE is a serious NEGATIVE, Poorly thought out, and potentialy takes revinue from businesses, that can be used for polution control equipment and personell,
Localy the Threats that were made about doing away with coal are going to close 3 near by electrical generating facillities,
we have a near by nuke, but what happens when that capacity is tapped? it will take a decade to add another reactor to the plant after the lawsuits and $hit are done,
the coal plants will be closing soon, I want clean air too, but I want to be able to afford electricty,
Al and his bunch of know betters dont think about the costs to most of us, the Administration also has motives too, the answer is reasonable regulation not the GROSS stupidity of things like CAP and TRADE, Face it IF we can come up with a cheaper cleaner energy source WE (the us) will be all over it,
On the linked news piece, any one Remember Buellgirlys pix from China, the thick yellow smoke at street level, and WE are catching UP ?
PLEASE !
I have to agree with Whatever, The EPA has done some good things, The industry that I work in had a terrible track record, with the tighter regulations less ground and water are being poluted, There are outfits out there that just look at the bottom line today, not what are we doing to the world. and untill that is no longer true there will be a reasonable justification for the EPA and its activities. |
Whatever
| | Posted on Thursday, December 10, 2009 - 02:05 pm: |
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The only point I was trying to make is that any rule proposal, public comment (including industry stakeholders), comment response, revision, implementation, litigation and enforcement... and permit approvals, with possible variances... is a very long process, with plenty of room for public participation.
There are many consultants and lawyers defending industries "rights" concerning the economic cost of any policy... it is not a unilateral rule making and never will be.
We are not going to wake up overnight and have an un-enforceable law that will put us all out of work.
If you feel so strongly about the CO2 issue, write your Senators and your Representative. No one here is a helpless victim... |
P_squared
| | Posted on Thursday, December 10, 2009 - 02:24 pm: |
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If you feel so strongly about the CO2 issue, write your Senators and your Representative. No one here is a helpless victim...
I do...quite frequently actually...not sure what the meaning behind that court order about keeping a minimum of 150' away from them was all about though.  |
Oldog
| | Posted on Thursday, December 10, 2009 - 04:08 pm: |
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There are many consultants and lawyers defending industries "rights" concerning the economic cost of any policy... it is not a unilateral rule making and never will be.
That is an accurate statement.
} |
Ferris_von_bueller
| | Posted on Thursday, December 10, 2009 - 05:52 pm: |
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So what if business is allowed to challenge or help shape policy. It doesn't negate the fact the government/EPA will set the agenda. Businesses don't pay for anything. They pass on their costs or they go out of business. WE will be the ones who carry the burden of increased energy costs. To me, it comes down to the money and I gave at the office. I'm tapped out. |
Ft_bstrd
| | Posted on Thursday, December 10, 2009 - 06:13 pm: |
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Ask the farmers in California if they are being "alarmist" at concerns about a larger, unfettered EPA. |
Ft_bstrd
| | Posted on Thursday, December 10, 2009 - 06:15 pm: |
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We nearly lost the entire children's product market over legislative stupidity. |
Strokizator
| | Posted on Thursday, December 10, 2009 - 06:36 pm: |
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Pushing propaganda and pretending that CO2 is a pollutant is just outrageous. That's what has me outraged. What's next, oxygen (O2), water (H2O)?
Funny you should ask. Water vapor is a "greenhouse gas" and much more effective than CO2 at trapping heat.
Will I be fined by the gov't every time I open a bottle of Coke or Champagne and release CO2? Will dry ice be outlawed? |
Ft_bstrd
| | Posted on Thursday, December 10, 2009 - 06:59 pm: |
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You will also have to pay a C&T tax on pop rocks. |
Crackhead
| | Posted on Thursday, December 10, 2009 - 07:40 pm: |
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We also carry the burden of extinct species.
I think the EPA has not done enough. the Blue Crab population is still dropping and you can't go swimming in sections of the rivers and the bay after the sewer systems over flow. |
Ferris_von_bueller
| | Posted on Thursday, December 10, 2009 - 08:47 pm: |
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Hey Crackhead, I have lived in Maryland for 45 years. The Chesapeake Bay is way cleaner today than it was when I was a teenager and the population has vastly increased. That being said, there is room for improvement but if you think it's EVER going to return to the glory days when the Indians inhabited the region you're mistaken. As to the crab population, that is due to over harvesting. The crab population was higher when the Bay was dirtier so the correlation you're attempting to establish is inaccurate.
Extinction and mass extinction are the rule not the exception. It's highly probable humans will become extinct due to natural forces. That is, unless we can get off this planet, beforehand.
(Message edited by Ferris_von_bueller on December 10, 2009) |
Blake
| | Posted on Friday, December 11, 2009 - 04:23 pm: |
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"We also carry the burden of extinct species."
Didn't I read that more species have gone extinct on the planet than now exist here. Please explain how that is "our" fault.
Survival of the fittest, adapt and change, or DIE. |
Aesquire
| | Posted on Friday, December 11, 2009 - 07:32 pm: |
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Come on, Blake, you know that Global Warming caused by your motorsickles is what killed the Brontosaurus! If you selfish Texans had your way, we'd be drilling for oil on the Capitol steps. 
And gas would be 37 cents a gallon.
This EPA thing is, per the "right wing nutcases", a ploy to get Congress to pass "cap & trade" so that some "market based" incentives will be there, as opposed to the command & control rule making so popular with fascists & communists. I'm not sure it's a ploy. I think it's a simple case of straight forward power grab.
Now, I'm a fan of the EPA, overall. I like to breath air I can't see, or taste. I enjoy swimming in creeks and still having skin, & eyeballs when I dry off. I even enjoy seeing others fish. ( I don't watch for long, it's not that interesting to me, but I like that it's happening )
Back in the day ( dramatic old timey music ) when I had to walk to school ..... hold it.... different story. Used to be eco-aware people were hippie types, readers of "Mother Earth News", scientists, and faddists. Today there is a scary percentage of opportunistic power hungry uberlefties, and they've got a religion that my Wiccan friends think is screwy. I mean, appreciate & protect Mother Earth, that's one thing. Some of the "new greenies" seem to want us to return to the days before machines. ( never mind that most of the people on the planet would die, that's never a concern. The old Greenies liked humans too. Not the new ones. )
I love "disaster week" on Discovery channel, but when they do "Earth is better with us all dead" week, I have to wonder.
Someone else's opinion.
http://article.nationalreview.com/?q=Nzk2ZDYzMmY2N 2VkODEzMjE3YjhmM2IzNjA3MTU1MTA=
(Message edited by aesquire on December 11, 2009) |
M2me
| | Posted on Tuesday, December 15, 2009 - 09:51 pm: |
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Still dont know what all the alarmist paranoia is about...
I don't get it either. I don't get the idea that it's going to lead to economic ruin. I think the opposite is true. I think it's the greatest economic opportunity in history. But powerful oil and coal interests are busy convincing some people that we must not go down this road or it will lead to our economic ruin. Yeah, it will lead to their economic ruin, not ours. We could have jobs, economic opportunity, etc. We pour gasoline into our Hummers and shovel coal into a boiler and say, "Look how free we are!" But we're not free. We're slaves of the fossil fuel industry.
Have you ever been to Duluth and seen the harbor? I have and have seen millions of dollars worth of wind turbines lined up on the docks. Where did these turbines come from? They came from Europe. They were produced in Germany, Denmark, Spain, etc., loaded onto ships, shipped across the Atlantic and through the Great Lakes and unloaded in Duluth to be transported by train or truck to wind farms in the Midwest. I think to myself, "Why don't we produce the wind turbines here?" Think of the jobs that could be created, think of the energy savings by not having to ship them all the way across the Atlantic ocean. Look at the top ten wind turbine manufacturers in the world. Only one (GE) is based in the US. All the rest are European. Why aren't nine out of the top ten based in the US? |
P_squared
| | Posted on Tuesday, December 15, 2009 - 09:57 pm: |
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Remind me again how well Spain's Green economy is doing?
Enough said.
Now as far as having more of the companies involved based here, I'm all for that. I'd be happy to export the mills to other countries. |
Gentleman_jon
| | Posted on Wednesday, December 16, 2009 - 07:10 am: |
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It's pretty simple really.
America now has met its most dangerous enemy, one that has the power to destroy it, and the will to do so.
It is the Obama administration.
Wake up, people. |
Ulyranger
| | Posted on Wednesday, December 16, 2009 - 08:39 am: |
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"Green jobs".....yeah, that's the ticket to the future. Just dump the Dino and go "green" it will fix everything!!
When we kill off all of the actual demand for consumption for this "green" energy......how exactly is this going to work in the long run?
I'm all for protecting our resources, environmental and the people enjoying same, but it really needs a sensible approach. Renewable, alternative energy sources are excellent ideas that should be encouraged to compete and will if unfettered. Just looking at it in the light of day realize change takes time and you can't just throw away the current without a viable, proven replacement.
It is not paranoia to question our Govt's intentions. There are many well intended and qualified professionals working within the EPA and State level EPAs/DNRs. But to think these current power plays in Washington are all about the concern for the air my children breath or the water that they drink is just.........well, shall I say, wishful thinking. And leave it at that.
"Command & Control" says it all for me. That is a top-down scenario, not much room for reasonable solutions there. Having worked in/with these "public comment periods"........I know exactly how that data is used and sometimes discarded/discounted. High power lobbyists rule the day........from both sides of the playing field. In the end they (Agency) will promulgate whatever rule/code/regulation they can get away with, is "paid" for or is "nudged" from above. |
Ferris_von_bueller
| | Posted on Wednesday, December 16, 2009 - 08:47 am: |
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I think to myself, "Why don't we produce the wind turbines here?
And what in hell does this have to do with cap and trade legislation? The proposed legislation doesn't mandate green technologies must be manufactured in the U.S. It's a completely separate issue. Besides, if you think there will suddenly be millions of jobs created from any of this - think again.
I don't get the idea that it's going to lead to economic ruin.
That's because, despite what one might assume, solar and wind is expensive !!!( http://greenecon.net/understanding-the-cost-of-sol ar-energy/energy_economics.html ) The financial ruination comes into play when we try to compete with countries that are using cheaper forms of energy. |
Aesquire
| | Posted on Wednesday, December 16, 2009 - 07:28 pm: |
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I've been looking into solar & wind. It's hard to get over the numbers. For a single house installation of either solar hot water heat, solar house heat, solar electric, or wind turbine, it keeps coming out to a 10 year payback at 2008 energy costs. Usually with a 10-50K $$ capital investment.
Pity, because I love some of the solar stuff, and they will not let me put in a windmill. If I get a pool, it's getting solar heat. Passive solar on the garage I hope to put in next year.
For $5k, I can foam the walls and get a much faster payback. House will be more comfortable too.
For the grid?? Nuclear & Fusion. Garbage into fuel, methane from feces. Wind don't always blow, sun goes down & it's cloudy here.
Collecting diffuse energy is a fools errand. Co-generation, waste to fuel, all great ideas.
Thrift, Conserve, freedom from Despot's oil, less mega-corperate greed, all good. ( the freedom from mega-corp greed is a pipe dream, but enjoy it anyway. If it's not GE, it's the State....today it's the State working with GE.....best or worst of all worlds?? )
One simple question.
If you suck 50 gigawatts of power out of the wind, what does that do to climate? 50 Terawatts? |
Oldog
| | Posted on Wednesday, December 16, 2009 - 10:47 pm: |
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If you suck 50 gigawatts of power out of the wind, what does that do to climate? 50 Terawatts?
so how many Terawatts does a forrest consume by blocking the wind??,
the only 2 wind issues I see
the noise , yes Noise the blades of the tower turbines make a deep pervasive swaoooooooof in a light breeze can be heard for several hundred yards, and the towers while gracefull to a degree are quite imposing up close, and become the dominant feature of the land scape, The wind farm that I have seen in Illinois was about 1/2 mile deep and 2 to 3 miles long with towers in long rows, these were tied to a sub station and tied into an existing grid, the farm is outside of Bloomington Il... I was told that a tower can generate usefull power at about 3 mph wind speed, and can be run up to about 60 mph, they are shut down for high wind and lightning
the tops rotate following a local weather vane, the ones I saw were about 250' high
with a rotor span of better than 250 feet
they can generate 2MW if I understood the
man I spoke to. |
Whatever
| | Posted on Wednesday, December 16, 2009 - 11:33 pm: |
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I think I prefer this to eating Mercury laden fish... wtf? |
Aesquire
| | Posted on Wednesday, December 16, 2009 - 11:43 pm: |
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Nice pic. Does kind of loom, doesn't it? We haven't even mentioned the nimby factor...that's why they couldn't put them up near the Kennedy's beach.
The fish comment. I agree. What IS the effect of all these (crappy Chinese ) CFL's getting tossed in the trash by careless people? Let us not pursue false goals while ignoring the important ones. Mercury hurts the Children.
I'd like to see a well engineered combo windmill and high tension tower. Huge swaths of the Dakotas & other plains states would be suitable, if you could tie them into the grid that way.
I know the question of the environmental impact seems facetious.
After all, what harm can producing terawatts of power do with existing systems?
What you must understand is there are 2 aspects to the hubris of the AGW cultist ideology.
First is the social engineering issue. To create a planetary government to ensure that they can impose the economic/industrial system to suit their ideology, ( One I don't recall working well for the people thus ruled ) and impose the second thing.
Planetary environmental engineering. A committee of the kind of people that run the U.N....or the Post Office....NOT scientists or engineers, will attempt to change the Earth's Climate. Oh, they'll invoke holy science if it suits them, but the guys running the IPPC right now, are not scientists, they are bureaucrats. U.N. ones. That's even worse than OUR Congress! Bet you!
Imagine that painting all our roofs white, and other mass ideas are put into effect, and it works? Scary.
I really liked the idea of putting billions of mirrors in orbit to focus or deflect the Sun, to affect the weather & climate. Can I order warm weather for the Toy Run? Or will the Secretary General set fire to Texas, ( or Baghdad ) when they defy him?
One more thought. Watch the coverage from Copenhagen. Are these the people you want to run an ecosystem?
(Message edited by aesquire on December 16, 2009)
(Message edited by aesquire on December 16, 2009) |
Poppinsexz
| | Posted on Thursday, December 17, 2009 - 10:07 am: |
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anyone know how many Turbins to equal 1 coal/gas/nuc plant? |
Hootowl
| | Posted on Thursday, December 17, 2009 - 01:51 pm: |
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No idea. Texas has an installed wind base of over 2 GW. I don't know how many wind turbines that is.
We had a governor once that stuck his head inside his energy secretary's door and said "We like wind. Get on it." 10 years later, Texas leads the US in wind energy production. That governor was George W. Bush. |
Oldog
| | Posted on Thursday, December 17, 2009 - 02:33 pm: |
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The local Nuke over in south port,
unit one produces 821 Mw of electrical power, unit 2 is the same
Hoot I would guess that state wide the installed base will cover about the 1 nuke plant here,
I like to think about a solar farm on a small scale could generate and store enough energy to cover night and cloudy weather.
I dont know enough about the math to determine how big, my idea is to have a high temperature heat sink material
( liquid ) that can be pumped through an OVEN area to cool it this heat would be dumped in to a heat sink and held used to make steam.
(Message edited by oldog on December 17, 2009) |
Hootowl
| | Posted on Thursday, December 17, 2009 - 02:51 pm: |
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Solar storage is intriguing. I saw a show recently that covered efforts to store liquid sodium in a vacuum insulated container (like a thermos bottle) for use during non daylight hours. The sodium lost an insignificant amount of heat overnight, and since the temperature of liquid sodium is sufficient to instantly flash water to steam, it could be a feasible solution. This was a thermal solar plant of the power tower variety, not a PV plant. |
Cityxslicker
| | Posted on Thursday, December 17, 2009 - 05:10 pm: |
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I think I first knew environmentalists were idiots when we were logging our back fourty. county came out and said we couldnt cut down the trees cuz they wouldnt grow back and they would deteriourate the river bed......
um trees grow... duh. the nearest, creek, stream, river was 4 miles away from our 'gulley' damn idiots environazis with nothing better to do and they have a budget to back them up. |
Sifo
| | Posted on Thursday, December 17, 2009 - 07:13 pm: |
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anyone know how many Turbins to equal 1 coal/gas/nuc plant?
The number is is huge. The problem is that you can't count on the wind, or solar. You still need 100% conventional power on hand. You also can't just power up the nuke, coal, or oil plant on a few hours notice. You need the boilers hot to spin the turbines. Basically you just create a lot of waste electricity when you have wind and sun, then fall back on 100% conventional power when the 'green' power is down. |
Cityxslicker
| | Posted on Thursday, December 17, 2009 - 08:25 pm: |
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The other portion of this shell game going on in 'climate' debacle is that there a push to have developed nations pay underdeveloped nations their 'carbon dues'
And I hate to say it, but damn the entertainment segment is trumping the news again. Hannity had a professor from Columbia on the show yesterday that is promoting we dump BILLIONS into Africa to help with our carbon debt ....
looking for the link
wtf? where do these people come from, and how do they not get locked up or put on meds? |
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