Guest posting by Richard F. Cronin
Sept. 15, 2017
As a Chem. Engr. with 40+ years’ experience, I can tell you that the current embodiment of the U.S. EPA HURTS the environment and impedes law enforcement.
The EPA only responds to the constituency which advances the reach and power of the EPA. That would be radicalized, out-of-control environmental groups. A good read on this topic is “Environmentalism Gone Mad” by Alan Carlin — former Sierra Club activist and EPA analyst.
The minority leader on the U.S. Senate Committee for Public Works & the Environment is Tom Carper (D-DE). He is grossly complicit in the near-criminal activities of the EPA under the Obama administration. I have written to my Senator several times on this topic as well as the chimera of “renewable energy” and have been stiff-armed every time. Senator Carper is up for re-election in 2018 and is rumored to be mulling retirement. It can’t happen fast enough by my lights.
The EPA was established in 1973, by Richard Nixon, another advocate for growing the reach and power of the federal government. The major legislation for Clean Air and Clean Water Acts were passed in the 1960s and after a few revisions became pretty sound, state-of-the-art, readily interpreted, and enforceable body of regulations. All private interests, such as chemical companies, were on a level playing field. Regulations for solid wastes (RCRA) followed in 1976. Again, with a few tweaks RCRA became a pretty good body of regs.
Then in the ensuing years, the layer upon layer of over-regulation accumulated, which degraded the regs into a set of mandates that not even EPA regulators could interpret because of inconsistencies and contradictory guidance.
I recall DuPont hiring a former EPA employee who had actually written the bloated regs. He was worse than useless. All that he could tell you was “Your options could be this. It could be that. It could be the other.” He would go off to consult his EPA colleagues in Washington and came back with zip.
The EPA knew very early about the water at Flint, MI and played buck pass while people suffered.
Unsupervised EPA contractors breached a containment for cyanide mining waste into the Animus River in Colorado. The EPA shrugged its shoulders and said: “Ooopps”, while local indigenous people dealt with the mess.
With the Waters of the U.S. (WOTUS) authority, the EPA can designate any seasonal wet spot as a “protected wetlands” to harass ranchers and farmers. They also claim any seasonal creek that you could jump across as a “navigable waterway”. If the rancher or farmer challenge the EPA, the armies of lawyers come out of the woodwork to descend like locusts and bankrupt the poor guy.
The standards for PM2.5 airborne particulates are so idiotic the requisite isostatic monitoring never yields reproducible results (PM2.5 = Particulate Matter 2.5 microns or less). It only applies to major industrial exhaust stacks. The condensing steam at the exit of the stack captures and washes out particles of this size.
If PM2.5 was applied across the board, every dry dust collector and clothes dryer would be unable to conform. Pollen and dust kicked up by the winds contribute orders of magnitude greater amount of PM2.5 particulates. The greatest exposure you have to PM2.5 particulates are dandruff on your pillow and exfoliated skin. Unless exposure is as bad as a coal mine or a grossly extended period, the mucus in your air passages capture these particles. They may cause you to sneeze.
The research around PM2.5 is layered in fraud.
The only logical means of controlling particulates in an industrial operation is to establish a baseline measurement outside the plant perimeter, then maintain continuous monitoring inside the plant property to be safely below that baseline. Point source regulations assure that manufacturers are reluctant to do anything, even to improve environmental controls, because they would jeopardize their grandfathered status.
The issue of grandfathered facilities is of interest on its own. As the reasonable and necessary regulations came out, existing facilities were upgraded to conform to Reasonably Available Control Technology (RACT). As the years continued, the EPA mandated Best Available Control Technology (BACT), and Lowest Achievable Emission Rate (LAER) for any new facility or major modification to existing facilities. Quite simply, manufacturers could not do anything at those demands. Rather, they ran the facility with minimum maintenance and no new investment. As the facility was gasping its last breath, the operation was spun off into a separate business, it was picked up a fire sale price and lurched on, propped up by state grants to support employment in the state. When the decrepit facility breathed its last, the site shut down and was declared a Superfund site.
In this manner, the EPA obtained another bit of business backlog to grow their empire. By moving the goal posts for remediation, it seems that most Superfund sites will never be satisfactory to pass the test from the environmental interest groups.
Now don’t get me talking about EPA’s armed agents who conduct SWAT assaults on a paint warehouse to see that the solvent containers are properly labeled. Also, when the EPA gets wind of illegal waste hauling and dumping, EPA agents set up road blocks to intercept the trucks. Such illegal hauling and dumping is a mainstay business for organized crime. Since the EPA has federal powers, they act independently from state or local law enforcement. No notification to state authorities is the norm.
The EPA nabs a few flunky truck drivers. The truck drivers have been paid in cash and the trailers are of indistinct origin. Of course, the investigation into the crime organization which has been carefully crafted by the state attorney general goes out the window as the criminal organization lies low and shifts their operations.