West Virginia DEP To Hold Environmental Seminar November 8

A seminar designed to help West Virginia businesses and organizations better understand state environmental regulations and the consequences of non-compliance with those regulations is scheduled from 9 a.m. to 3:30 p.m., on Nov. 8, at Cabela’s in Charleston. 

The seminar is being conducted in coordination with the state Department of Environmental Protection and the West Virginia Manufacturing Extension Partnership. It will be led by Dr. Terry Polen, Ombudsman for the WVDEP. Polen will cover the following topics:

Required permits; stormwater pollution prevention plans; ground water protection plans; spill pollution control and countermeasures; air quality permits; regulations for used oil; hazardous and solid waste; greenhouse gases; Tier II; and toxic release inventories.

The cost of the seminar is $75 (including lunch) and class size is limited. The registration period ends at noon on Nov. 7. For more information, or to register, contact Michelle Kyker at 304-290-8463 (mkyker@wvmep.wvu.edu) or Bob Bailey at 304-546-3642 (rbailey@wvmep.wvu.edu).

The same seminar will be presented on Dec. 6 in the Eastern Panhandle at the Holiday Inn in Martinsburg, 301 Foxcroft Ave. The registration deadline is noon, Dec. 5. 

West Virginia's Triennial Review - Changing WV's Water Quality Standards

Every three years states are required to review their water quality standards.  West Virginia's next review formally kicks off in June of 2013, when changes will be officially  proposed, but  Kevin Coyne, Manager  of the WV Water Quality Standards program under Division of Water and Waste Management  Director Scott Mandirola, invited interested parties to get a head start and identify the issues that they believe should be considered  in the coming year.

Some of the better comments were provided by the West Virginia Coal Association. Twenty years ago, NPDES permit for coal mines were pretty simple - there were iron and pH limits, and not much else.  Industrial facilities received the tougher scrutiny,but that's no longer the case.   Manganese limits were added to mining NPDES permits (ironically, manganese was being used for water treatment), then selenium became an issue, and now conductivity.    Citizen suits and objections by EPA to mining permits have focused on these and other water quality concerns in order to force additional treatment that provides questionable environmental improvement.

Two issues addressed by the WVCA bear particular mention.  The first is the designation of all state streams as drinking water supplies.  The state maintains the fiction that all streams should be treated as if they are drinking water supplies, even though that is not required by the Clean Water Act, is completely impossible to achieve, and results in unnecessarily stringent permit limits that do not benefit anyone. The fact is, anywhere a public water supply is installed, all other dischargers have to protect it, and NPDES permit  limits would be imposed to do so.  Until there is a drinking water use, though, those protections are meaningless to everyone except the discharger that spends millions to protect a use that does not exist.  The WVCA comments provide  a good history of how we got to this point, and we can hope they will make correcting those historical mistakes a key feature of their efforts next year.

The other comment worth looking at is the suggestion that the DEP reconsider its application of the narrative criteria and  use of the  West Virginia Stream Condition Index.  The WVSCI is a guidance, not a rule, but it has frequently been applied as if it were a rule. Developing a new means of measuring compliance with the narrative water quality standards would be a welcome change.

How Much Coal Is Left In Central Appalachia?

Sometimes forgotten in the battle over mountaintop removal mining is the fact that miners are chasing smaller and smaller seams, making it less and less economical. While it's far from running out, the easily-obtained coal in southern West Virginia and Eastern Kentucky has all been mined.  Ken Ward reports on that phenomenon here, and his analysis is worth a look.

Persons unfamiliar with coal mining would probably be amazed at the amount of coal that  can be left in the mine after mining is complete. Room and pillar mining leaves huge blocks of coal behind, holding up the ceiling and keeping the surface from subsiding.  From diagrams, it would appear that more coal is left than is taken out. .Here is a diagram showing coal removal methods, although it doesn't show longwall mining, which gets much more coal, but allows the roof to collapse behind the longwall miner.  This is another description of the various mining methods.

Global Temperatures Haven't Risen in 15 Years

David Rose  of the UK Daily Mail reports that  UK Meteorology Office data show that the world stopped getting warmer 15 or 16 years ago. During the same time the amount of carbon dioxide in the atmosphere has increased by about 10%.  It looks like it may be time to reformulate all those climate change models.

Horizontal Well Rules Advance

The huge increase in horizontal well drilling that has come with development of the Marcellus Shale play has led state regulators to take a close look at the environmental requirements  for those types of wells.   The Marcellus Shale industry is currently  operating under emergency rules that were adopted by the  West Virginia Department of Environmental Protection last year. The DEP now has to replace those emergency rules, which are only good for a little over a year, with legislative rules that are permanent.  Toward that end, in June the  DEP proposed its Rules Governing Horizontal Well  Development (35 CSR 8), which were similar to, but an expansion of, the emergency rules.  Comments on the proposed rule were accepted, and there were a large number  offered by the oil and gas industry and by the public.  You can see the comments, and the DEP's response, here.  (It may take a while to load, as there are over 700 pages of comments, hearing transcript and DEP response.)  The rule, as it was amended and sent to the Legislative Rule-Making Review Committee on September 14, can be found here.

Legislative rules must be approved by the Legislature in West Virginia.  Come January, the proposed rule will be considered by the LRMRC, which will make a recommendation on adoption to the Legislature.  It will work its way through  several committees, where we will likely be fighting over certain provisions, until it is  passed by the Legislature and final-filed by the DEP.

West Virginia Brine Use Policy For State Roads

Natural gas wells can produce large amounts of brine that  flows back to the surface after well completion activities are finished. This salt water can be  an excellent substitute for the solid salt that is laid down on roadways before anticipated snowfalls, or after snow hits the ground. The brine also contains other substances, though, and not all flow back will qualify as road treatment salt.  The Department of Environmental Protection has specified what can be in the brine that qualifies for road use, and those limits are found  in this agreement between the WV Department of Highways and the DEP.

Subsequent note October 5, 2012  While this blog posting is correct, it could benefit from some additional clarification offered by the DEP.  The brine specifications were developed by the DEP to be used by the DOH in its bidding process, to let potential suppliers know of the quality specifications for brine sold to the State. The agreement should not be interpreted as a  permit for road application of brine by private individuals, even if it meets these quality standards.

Germany Leads The Way In Renewable Energy - And Suffers The Consequences

No other industrialized country has been more aggressive than Germany in developing renewables, in the form of  solar and wind power. The potential up side was demonstrated on September 14, when Germany hit 31 gigawatts of energy from wind power alone.  That's a huge number, lots of free energy, and had to be a large percentage of national electricity usage.  So why aren't more Germans celebrating, and why is Germany investing in so many new coal-fired power plants?

Christopher Booker explains in the (UK) Telegraph why reliance on renewables like wind and solar cause electricity rates to skyrocket and put an economy at risk. As Mr. Booker explains:

The more a country depends on such sources of energy, the more there will arise – as Germany is discovering – two massive technical problems. One is that it becomes incredibly difficult to maintain a consistent supply of power to the grid, when that wildly fluctuating renewable output has to be balanced by input from conventional power stations. The other is that, to keep that back-up constantly available can require fossil-fuel power plants to run much of the time very inefficiently and expensively (incidentally chucking out so much more “carbon” than normal that it negates any supposed CO2 savings from the wind).

 As consumers we are used to hitting the switch and lights coming on.  We have no idea of the complexities that are involved in matching the vagaries of solar and wind-produced electricity to the steady demands of the electrical grid. If our governments insist on more renewables in energy companies' portfolios, we may soon find out.

This was one example of what can happen to manufacturing when electricity is unreliable, which is especially interesting in light  of the possible start up of the aluminum smelter in Ravenswood:

Now the problem for the German grid has become even worse. Thanks to a flood of subsidies unleashed by Angela Merkel’s government, renewable capacity has risen still further (solar, for instance, by 43 per cent). This makes it so difficult to keep the grid balanced that it is permanently at risk of power failures. (When the power to one Hamburg aluminium factory failed recently, for only a fraction of a second, it shut down the plant, causing serious damage.) Energy-intensive industries are having to install their own generators, or are looking to leave Germany altogether.