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Re: Turbozen post# 115986

Tuesday, 01/29/2019 2:49:50 PM

Tuesday, January 29, 2019 2:49:50 PM

Post# of 122540
Even imagining that MMEX-scam were really building something, there are two different permitting paths.

The complexities are likely beyond the MMEX STRONG, but in summary, there are categories of source emitters. In the MMEX-scam case, there are examples like the imaginary Phase I unit, a rudimentary topping unit, which would produce less than 20Tpy of certain emissions (the 20Tpy is an average across all emission types). As such, this is categorized as a minor source.

Because these kinds of systems are numerous, some temporary, the New Source Review process was streamlined and simplified by USEPA and proxies like TCEQ into Permit By Rule (PBR), a purely administrative, check-box, rubber-stamp process that has as its core the notion of "must issue."

Large facilities, like MMEX-scam's imaginary Phase II fall into a different category - major emitters. As such, these projects require full-scale New Source Review (NSR), by both TCEQ and USEPA.

The NSR process for a major emissions source is extensive, includes engineering review, and requires that at least 85% or more of the actual system design is complete, modeled, and fully simulated. This takes even competent companies 18 - 24 months, and costs several million dollars.

The MMEX STRONG should certainly do all the due diligence they are able (having failed in the first case, and invested in MMEX-scam).

The proper permitting for construction of a modern and environmentally friendly Crude Oil Refinery processing 10,000 bbl a day using a Crude Oil Distillation unit is on an honor system? I need verification on your claim because that doesn't even seem logical. thanks


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