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Comment 15 for Public Input on Cap-and-Trade Auction Proceeds (investmentplan-ws) - 1st Workshop.


First Name: Odell
Last Name: McWane
Email Address: omcwane@materialsite.com
Affiliation: McWane and Associates (www.materialsite.

Subject: Invest cap and trade revenues in engineer, consultant, datadase
Comment:
Some auction revenues should be invested in setting up and
maintaining a database of engineers and consultants who can help
regulated companies comply with the environmental requirements by
designing, building, upgrading or maintaining the power facility,
or other emission source after the regulatory requirements have
been determined.

The database should be searchable by each engineering and
consulting discipline, and with a description of what each company
or individual does.  The relevant disciplines include:

Welding engineers and consultants (see www.materialsite.com for
definition)
Metallurgical engineers and consultants (see www.materialsite.com
for definition)
Materials engineers and consultants (see www.materialsite.com for
definition)
Mechanical engineers and consultants
Civil engineers and consultants
Electrical engineers and consultants
Structural engineers and consultants

For Example:
After determining elsewhere what the regulatory requirements are,
the regulated business may decide to install an air pollution
control system, or improve the plant efficiency.  Therefore the
regulated business searches the database for a mechanical engineer
or consultant who can design the air pollution or energy efficiency
system.  The regulated business also searches the database for a
metallurgical or materials engineer who will work with the
mechanical engineer to assist in selecting and specifying the
appropriate high temperature materials needed for the emission
control technologies, so as to sustain the high temperatures,
pressures, and corrosive environment for the life of the plant
without degrading.  Also the regulated business searches the
database for a welding engineer or consultant who will work with
both the mechanical and metallurgical or materials engineer when
writing the welding specification which specifies how to qualify
welding procedures and welders to fabricate and weld the high
temperature materials so as to not degrade its microstructure. 
Degrading the microstructure of high temperature materials by
improper fabrication and welding can shorten the materials life,
and lead to premature material failure, unexpected outages, release
of air pollutants, and life threatening steam releasing accidents. 
A case in point are the attempts of some power companies, their
engineers and designers to specify advanced power plant material SA
335, Grade P91, 9Cr-1Mo steel pipe, because of its long term high
temperature properties.  And as a result having the material fail
prematurely due to improper fabrication, welding, and heat-treating
procedures used by contractors and maintenance personnel.

This example stresses the point that using the correct degreed
engineering and consulting discipline from a high quality database
in a team effort to properly select, fabricate, and weld high
temperature materials used for energy efficiency or emission
control technologies, are as important as selecting or designing
the correct energy efficiency and emission control technologies for
compliance.

Attachment:

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Date and Time Comment Was Submitted: 2012-06-07 19:32:19



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