EPA's Shell game

Maybe the EPA is just trying to help Shell explore for oil off the coast of Alaska — or maybe the agency is simply setting up Shell (and the rest of us) for failure.

In apparent effort to avoid Shell having to comply with greenhouse gas (GHG) emissions regulations, which take effect when a source emits 75,500 tons of carbon dioxide-equivalents per year, the EPA is proposing to permit Shell’s operations with a GHG limit of 70,000 tons per year.

To stay under this cap, the EPA will limit Shell’s operations to 120 days, rather than the 165 days originally granted.

The proposed EPA permit further prescribes that:

6.2. At all times while the Discoverer is an OCS Source, the total amount of fuel combusted in engines and boilers on the Discoverer and Associated Fleet, when within 25 miles of the Discoverer, shall not exceed 6,346,493 gallons during any rolling 12-month period.

6.3. At all times while the Discoverer is an OCS Source, the total amount of waste combusted in incinerators on the Discoverer and Associated Fleet, when within 25 miles of the Discoverer, shall not exceed 1,657,440 pounds during any rolling 12-month period.

Moving past the disturbing notion that the EPA is telling Shell how much fuel it can burn to single digit units, this permit would seem to set Shell up for violating it.

Burning a gallon of diesel produces 22.2 pounds of CO2. Multiplying 22.2 by 6,346,493 gallons and then dividing by 2000 pounds equals 70,446 tons of CO2 — slightly in excess of the permit’s limit of 70,000 tons.

Add in the CO2 from the allowed burning of 1,657,440 pounds of waste, and not only is the 70,000-ton limit blown away, but Shell will likely exceed the 75,000-ton threshold for EPA GHG regulation.

Unless this math is incorrect (and we welcome correction), it would seem that the EPA is setting Shell up for failure.

The enviros are planning to challenge the EPA’s effort to allow Shell to skirt the 75,000-ton threshold. They already succeeded earlier this year in having the EPA’s Environmental Appeals Board overturn an earlier permit for Shell on the basis of GHG emissions.

Finally, note that the permit in question is simply for exploratory drilling — not drilling for production.

Via the EPA, the greens have a growing stranglehold on our economy that Republicans in Congress are doing little, to relieve.

4 thoughts on “EPA's Shell game”

  1. Not quite as simple as described. I quickly scanned the permit but didnt’ see a total criteria pollutant emission limit. However, if it is a PSD permit, then they were over one of the PSD permitting thresholds for criteria pollutants. For a permit issued prior to July 1, 2011, the GHG threshold is 75,000 tons. The world doesn’t come to an end if you go over 75,000 tons of CO2 equivalent emissions, you just have to do a BACT and dicker with EPA over that. It looks like Shell may have gone for a PSD avoidance permit for GHG by limiting the amount of fuel they used. EPA probably didn’t do the fuel and time limit, Shell did the request to avoid GHG PSD. The funky fuel numbers were probably submitted by Shell and EPA just copied them. This is done all the time in air permitting. Just some of the silliness I’ve been doing with air permit applications for about 3 decades. If it weren’t for the EPA I’d have to find honest work.

  2. Diesel fuel has a specific gravity of .95g/cm cu. which is less than water. A gallon of it weighs roughly 8 pounds. How does burning a gallon of it produce nearly 3x its weight in waste?

Comments are closed.