Monday, September 9, 2013

West Virginia DEP Schedules Training For Electronic DMR Submissions

The state Division of Water and Waste Management has free training scheduled for the following dates for the regulated community and consultants who are required to submit certain water resources permit applications and discharge monitoring reporting (DMR) electronically to the DWWM. The training will be conducted at the state Department of Environmental Protection headquarters, located at 601 57th St, SE, Charleston, WV   25304.

The dates are:

September 26, 2013 Thursday
ePermitting  10:00 am to 12:00 pm

September 26, 2013 Thursday
eReporting 1:00 pm to 3:00 pm

October 7, 2013 Monday
ePermitting  10:00 am to 12:00 pm

October 7, 2013
Monday                                                               
eReporting 1:00 pm to 3:00 pm

October 31, 2013 Thursday
ePermitting 10:00 am to 12:00 pm

October 31, 2013 Thursday
eReporting 1:00 pm to 3:00 pm

To reserve a spot for the above training, contact either Mavis Layton at Mavis.L.Layton@wv.gov, (304) 926-0499, ext. 1025; or Megan Smith at Megan.D.Smith@wv.gov, (304) 926-0499, ext. 1281. E-mail is preferable.
                                                          
The WV Environmental Training Center is hosting DEP Training in the Bridgeport area around the end of November/early December 2013 instead of Morgantown as previously mentioned.  Check the wvetc.org website calendar in a month or so for actual date and sign up with them.  

  

Saturday, September 7, 2013

District Court Interprets NPDES Permit Shield

Judge Chambers of the USDC for the Southern Dist of WV recently ruled, in a case pertaining to discharges from a surface coal mine, that the mine (owned by Marfork Coal Co.) was in violation of its NPDES permit if it discharged selenium in excess of the state water quality criteria, even though it had no permit limit for selenium.  As part of the permit application process, the mine had tested for selenium and found it at a level too low to qualify for an effluent limit, based on a reasonable potential analysis.  Sampling done by environmental groups at a later time allegedly revealed selenium discharges in excess of state criteria, and the environmentalists brought a citizen suit under the Clean Water Act, claiming that Marfork had violated its permit.

Marfork relied upon the permit shield that is found in the federal (CWA Section 402(k)) and state (W. Va. Code 22-11-6(2)) acts. The Court ruled that the permit shield provided no protection against a citizen suit alleging a violation of water quality standards, even where the agency had been provided selenium data at the time of the permit application, and had rejected effluent limits for selenium.  The Court decided that the permit required compliance with water quality standards, and the presence of any pollutant in excess of water quality criteria  (numeric or narrative, presumably) was a violation of the permit, even if no numeric permit limit had been placed in the permit. 

One  crucial difference between coal permits and other NPDES permits is that the  coal NPDES regulations have a provision that requires dischargers to comply with water quality standards, and the industrial NPDES regulations do not.  That may provide industrial facilities with a more expansive permit shield. 

The case is Ohio Valley Environmental Coalition v. Marfork Coal Company, Case 5:12-CV-01464 (Aug 23, 2103).  Thanks to Bob McLusky for bringing this to my attention.


Great Kanawha River Cleanup September 14, 2013

The 24th annual Great Kanawha River Cleanup, sponsored by the West Virginia Department of Environmental Protection, is scheduled from 9 a.m. to noon on Saturday, Sept. 14.

Cleanup sites include Kanawha Falls at Glen Ferris; Magic Island in Charleston; Winfield Beach/Locks; Daniel Boone Park in Charleston; and Roadside Park in St. Albans.

Those wishing to volunteer are urged to register with the DEP so enough supplies can be obtained for each cleanup location. The DEP’s REAP program (Rehabilitation Environmental Action Plan) will supply bags and gloves for volunteers and will arrange for trash to be hauled away.
All volunteers also will receive a T-shirt.

Last year, local citizens collected two tons of debris and trash from the Kanawha River’s banks. Over the last five years, volunteers have removed more than 30 tons of trash from the river and around 400 discarded tires.

For more information or to register to volunteer, contact Travis Cooper at 304-926-0499 ext. 1117 or email:


Friday, August 23, 2013

Today's Number - 60 GWs

Sixty gigawatts (GW) is the total amount of installed wind power capacity in America as of the end of 2012.  It is also the amount of coal-fired generating capacity that will be retired over the next five years in the eastern US.  The Department of Energy reports that 
Last year, over 13 gigawatts (GW) of new wind power capacity were added to the U.S. grid – nearly double the wind capacity deployed in 2011. This tremendous growth helped America’s total wind power capacity surpass 60 GW at the end of 2012 – representing enough capacity to power more than 15 million homes each year, or as many homes as in California and Washington state combined. The country’s cumulative installed wind energy capacity has increased more than 22-fold since 2000.
E & E Publishing, in an article  passed along by  Midwest Energy News,  reports that 60 GW of coal-powered electricity generating capacity will be retired over the next 5 years.  This will present issues for the regional power transmission organizations to deal with.
The reliability of the U.S. electric grid has been a key concern among regulators and utilities in response to impending emissions control regulations by U.S. EPA, including greenhouse gas regulations and tighter control on so-called conventional pollutants such as nitrogen oxide and sulfur oxides. 
Nearly 85 percent of the nation’s coal-fired power plants are in the Eastern Interconnection, a part of the grid comprising 39 states along the East Coast and across to the Midwest. By 2015, about half of those coal plants will be 50 years old or older, but they represent about 25 percent of the region’s total capacity, the report says. 
The report says that the region contains 269 gigawatts of coal capacity, with one-third of that in five states: Indiana, Illinois, Ohio, Pennsylvania and West Virginia.

The news about increased power generation from wind is a good thing - it's helpful to have a mix of power generation sources, and the technology behind wind turbines will likely continue to improve.  But one can't compare 60 GW of  base load, reliable generation from coal plants with 60 GW of intermittent generation from wind turbines.  And the unsubsidized cost of wind generation will have to come down significantly to be comparable to fossil fuel or nuclear.   In some ways, wind may be a victim of its own success - having spent the last few years proclaiming that its costs are on a par with fossil fuels, there may be less support among politicians for continuing subsidies.

Thursday, August 22, 2013

Office of Oil and Gas Says No Further Air Pollution Regulation Needed

A provision in the Natural Gas Horizontal Well Control Act directed the  DEP Office of Oil and Gas to study the need for further regulation of  air  pollutants from oil and gas drilling sites.  The OOG finished its report in late June and presented it to an interim committee of the West Virginia Legislature yesterday.  

The important conclusion from the report was that 
Based on a review of several completed air studies to date, including the results from the well pad development monitoring conducted in West Virginia's Brooke, Marion and Wetzel Counties, no additional legislative rules establishing special requirements need to be promulgated at this time.  The existing regulatory framework provides a basis for implementation of requirements to minimize and mitigate human health and environmental impacts. 

The report can be found here, and the cover letter summarizing the conclusions can be found here

The report contains three appendices, listing location restrictions, existing air pollution control requirements, and a list of state and federal investigations, completed and ongoing, investigating the effects of  oil and gas drilling.  They could be a useful resource.  

A story about the legislative meeting from Fuel FIx  is found here

The Energy Cost of Raising the World's Standard of Living

Poverty means  energy poverty for most of the world. Lights, heating and cooling, refrigeration, transportation, pumps, and  labor-saving devices of all kinds require power.  So how much additional energy would be needed to elevate the poor to  the energy usage required to maintain the standard of living of a developed country like Spain? Considering the huge improvement in health and quality of life that would result, the amount of additional energy required is surprisingly little. Willis Eschenbach  explains it here.

Of equal interest is the extended comment on Eschenbach's essay from rgb@duke, a professor of physics at Duke University.  He makes the intriguing case that future sources  of energy are essentially unlimited. Since you  may not scroll down through the comments, I've  reprinted it below.

A few small notes. Looking at the table, there is a difference between “reserves” and “recoverable resources”. We have 81 years of the former, but well over ten times that in recoverable resources. The former has proven to be a rather flexible and hence perhaps pointless number as it keeps changing as new resources are discovered and proven, which is why we haven’t reached “the end of oil” quite yet. In particular, there is a LOT of coal that is recoverable, and nothing prevents us from using a venerable process for converting coal into gasoline but price — the general availability of cheaper gasoline produced directly by refining crude oil.
Second, you deliberately (I imagine) did not address nuclear energy and its reserves. Uranium is problematic — perhaps — because high pressure light water cooled reactors have technical risks of meltdown and associated risks of nuclear proliferation, but nevertheless there are at least hundreds, possibly tens of thousands thousands of years worth of Uranium reserves (the latter if we use breeder reactors and actually burn all of the Uranium instead of a pitifully small fraction of lightly enriched U-235). Of course breeder reactors that are efficient in this regard burn plutonium for most of the energy they produce, and plutonium is bomb material at this point for pretty much any country that gets it as the concept of implosion lenses and critical density is hardly either secret or technically inaccessible any more even to a very poor and backwards country. Still, we have 30,000 years of Uranium WITHOUT using Uranium from seawater from proven reserves if we use breeder reactors. If anyone works out how to economically extract Uranium from seawater we have an effectively infinite supply — humanity would evolve before we ran out, as the 60,000 years in seawater would be amplified by 100 to 6 million years. Admittedly, this is “at current consumption rates” so it would be less if we converted over to using fission reactors on a broad basis, but I think that it makes the 81 years entirely moot.
Third, that doesn’t include Thorium, either. Thorium has a number of advantages over Uranium as a reactor fuel, the principle ones being that it is somewhat (but not decisively) more difficult to use as the basis for a clandestine bomb building program, it produces anywhere from 10 to 10,000 times less nuclear waste depending on the fuel cycle selected, and it is MUCH more difficult to make a thorium reactor “melt down” the way existing solid-fuel LWR Uranium designs can. The most advantage fuel cycle appears to be liquid salt reactor designs, which literally cannot melt down, have reduced (but nonzero) proliferation concerns, and which could literally be used to burn EXISTING nuclear waste and in the process would release a lot of the unburned energy in existing spent nuclear solid fuel (currently only around 1% of the available energy is being recovered in LWR Uranium non-breeder designs). Estimates of thorium reserves and available energy necessarily vary because only prototype reactors have been built of the various kinds and because little effort has been put into developing Thorium reserves (Thorium is currently a radioactive waste byproduct of mining rare earth metals and has only a handful of industrial/commercial applications as things now stand) but it is at LEAST tens of thousands of years. As a side effect of adopting Thorium as an energy fuel, we would completely solve the problems with global shortages of rare earths and hence e.g. rare earth magnets and exotic semiconductors, both essential components in other aspects of efficient energy production and transmission and utilization.
I know that we don’t necessarily agree on the eventual utility of solar power, but IMO there is also no question at all that over the next decade or two solar cell technology and engineering will progress to where the cost per watt at over the counter retail rates drops below fifty US cents (to as low, eventually, as ten cents or even less). This will correspond to wholesale prices that are roughly half of these retail prices. This will push the amortized cost recovery for large and small scale solar energy projects to well under a decade, with an expected plant lifetime of at least twice that, and IMO will make solar a no-brainer energy resource for the entire tropical and subtropical band. Although without efficient energy transportation and storage (which are both more speculative and less predictable) solar alone is not a viable single energy resource for a steady state global civilization such as the one you propose, they can easily eke out both nuclear and carbon-based resources and double or triple any of the numbers above for years of available energy.
If (say) high temperature superconducting transmission lines are discovered/invented that facilitate the transport of electrical energy distances on the order of 10,000 miles with minimal loss, and/or high capacity high efficiency multicycle energy storage is ever worked out (say zinc oxide batteries are eventually developed that have charged energy densities that are roughly comparable to gasoline) it would both permit the eking out of “fossile” resources (carbon, Uranium and Thorium) to “indefinitely long” and could even serve as the basis for a truly steady state civilization, which I believe should be our long term goal regardless of greenhouse issues.
Finally, on the speculative front, is low temperature fusion. Fusion in some sense is the holy grail of energy production mechanisms. If economically feasible deuterium-based fusion is ever worked out, we will literally never run out of energy. It would take us tens of millions of years of utilization to BEGIN to deplete deuterium even if you provided energy to every person on Earth at levels equal to or in excess of US consumption per capita, and with that much energy we could cost-effectively mine e.g. Europa, Titan and the gas giants if we should ever actually significantly deplete the Earth’s oceans. A mix of solar and fusion energy production would make the human species secure well past the point where it is no longer recognizably human, time frames longer than the interval from the end of the Cretaceous to the present, geological time scales. The human species might well die off over that sort of time frame, but probably not because we ran out of energy. To ensure survival of the species even beyond that would likely require at least interplanetary if not interstellar colonization, and still more speculative advances in physics and technology for the latter to become even imaginatively possible.
Otherwise, yes, I agree, we have little excuse for not ending energy poverty worldwide. Nor do I think Spain/Italy should be the standard — our goal should be lifting people up to e.g. the rate of energy utilization in the US. Eliminating poverty might actually facilitate a reduction in the rate of population growth or even initiate a period of population decrease, and that too is a way of extending and improving per capita consumption. Finally, there is a world of undeveloped technology that might reduce per capita consumption without impacting quality of life. The past conversion from incandescent to CF light bulbs, the future conversion from CF to LED bulbs (that use still less energy and have far longer lifetimes) are a prime example. Houses that use integrated local solar for local daytime AC are another. Smart houses that deliver e.g. light or AC only when and where it is needed (without loss of comfort or utility) yet another. A lot of this is technically feasible right now; it simply isn’t implemented because the cost-benefit is marginal with energy being as CHEAP as it is, but as energy prices increase over time, the marginal return from these technologies and their broader implementation and economy of scale will greatly reduce the real dollar cost and eke out our energy resources further still.
It would be a whole lot easier to establish a stable and sustainable global civilization with a billion humans than it is or will be with 7+ billion humans. OTOH, I’m not quite ready to go out there and pick 6+ billion humans to be “culled”. Nature — via pandemics, asteroid collisions, ice ages — might do it anyway. Or, we might get there by simply improving the standard of living worldwide to the point where humans (apparently) stop reproducing at rates that lead to population growth, and then gradually ramp it down by having fewer babies than people who die of natural causes for a century or two.
Either way, I won’t be around to watch most of this, probably. Interesting to think about, though.
rgb

Wednesday, August 7, 2013

EPA Updates Oil and Gas Standards for Storage Tnaks


EPA has announced revisions to the 40 CFR Part 60 Subpart OOOO (sometimes referred to as "Quad O") New Source Performance Standards  that apply to oil and gas production storage tanks.  In West Virginia, these changes will presumably be made part of the G-70 general air permit for oil and gas production facilities that we hope will be issued by the Division of Air Quality  fairly soon.

It is worth noting that Chesapeake Operating  appealed a permit condition in a minor source Reg 13 permit  that specified how it was to confirm flashing emission potential, and a resolution of that appeal may affect how companies calculate whether they are going to exceed the 6 ton threshold.

Below is EPA's press release, with  a hyperlink that can eventually get  you to the rule.,

WASHINGTON – Today the U.S. Environmental Protection Agency (EPA) issued updates to its April 2012 oil and natural gas standards for storage tanks, which allow responsible oil and natural gas production while ensuring air emissions are reduced as quickly as possible. The updates will phase in emission control deadlines, starting with higher-emitting tanks first, and will provide the time needed to ramp up the production and installation of controls. EPA is making the changes based on information received after the 2012 standards were issued that shows more storage tanks will come online than the agency originally estimated.

Storage tanks that emit 6 or more tons of volatile organic compounds (VOCs) a year must reduce emissions by 95 percent. Today’s rule establishes two emission control deadlines:
  • tanks that come online after April 12, 2013 are likely to have higher emissions and must control VOC emissions within 60 days or by April 15, 2014, whichever is later; and 
  • tanks that came online before April 12, 2013 are likely to have lower emissions and must control VOC emissions by April 15, 2015.
The updated standards also establish an alternative emissions limit that would allow owners/operators to remove controls from tanks if they can demonstrate that the tanks emit less than 4 tons per year of VOC emissions without controls. In addition, the rule streamlines compliance and monitoring requirements for tanks that have already installed controls.

The oil and natural gas industry uses tanks for temporary storage of crude oil, condensate and other liquids, before those liquids are moved to a pipeline, sold or moved for disposal. These storage tanks can be sources of emissions of ozone-forming VOCs, along with several toxic air pollutants, including benzene. Today’s final action does not affect the April 2012 standards for capturing natural gas from hydraulically fractured wells.
Today’s updates respond to petitions for reconsideration of the 2012 New Source Performance Standards for Oil and Natural Gas Production. Those cost-effective standards rely on proven technologies and best practices to reduce emissions of ozone-forming VOCs and air toxics, including benzene and hexane.

Exposure to ozone is linked a variety of health effects, including aggravated asthma, reduced lung function and increased susceptibility to respiratory infections, in addition to increased risk of premature death from heart or lung disease. Benzene and hexane are air toxics, which can cause cancer and other serious health effects.


More information: http://www.epa.gov/airquality/oilandgas/actions.html