We’re still waiting for the EPA IG reports on the agency’s illegal human testing and the financial conflicts of interest among the agency science advisors.
We’re still waiting for the EPA IG reports on the agency’s illegal human testing and the financial conflicts of interest among the agency science advisors.
AP-42 is a joke. When Texas passed rules requiring direct measurements of flares and cooling towers, everyone was taken aback at either how much we were off. For cooling towers, most of us were far under estimated amount, and others were so far above that their cooling towers were near LEL. Furthermore, on some things, like dust emissions, the calculation results are patently ludicrous, with visible dust clouds sometimes being less than a single gram.
And Bob, requiring electronic reporting means that they don’t have to have people going through thousand-page emission inventories for each plant to present totals.
We’ve known for a long time that EPA’s emissions factors are not that good. I don’t see that their required direct electronic submissions will improve them since they have no way to evaluate the equipment from source testing. This document pretty much provides cover for the EPA to delay and interfer with the new gas and oil extraction technologies. Their intent is pretty well summarized by the cover picture: rig tower between the playground and houses.