Tuesday, January 29, 2019 1:33:52 PM
This AQP is no longer valid, in that MMEX-scam utterly failed, and had an incomplete processing facility permitted - missing a desalter, pre-flash, critical pump-around, redundant heat exchange, and a steam unit.
But that’s beside the point…
MMEX-scam lacked the internal competence to complete the application, and had to pay a third-party consultancy, Trinity, to file on their behalf.
The Type O AQP falls under the Texas/TCEQ Permit By Rule (PBR) process - a “must issue” system. These permits are administrative, and apply only to minor source emissions. They can be completed by populating a spread-sheet, and guided form submission by an individual with marginal intelligence, and no engineering skills - businesses like dry cleaners, rock crushers, temporary paving plants, etc., routinely do so - without hiring a consultant.
TCEQ must grant the permit, if the application package is complete, and the fee is paid. There is no engineering review, or analysis, and the applicant is on the honor system to operate only what was permitted, within the minors source limitations for that permit class.
The MMEX STRONG routinely appear in a battle of wits, completely unarmed.
When you are dead, you don't know that you are dead. It is difficult only for others. It is the same when you are stupid.
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