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	These comments are a heads up on what I call progressive
energy companies,
and nonprogressive energy companies, and their potential response
to the greenhouse
gas reduction requirements.  Progressive energy companies are
those companies
committed to reducing greenhouse gas emissions and does what it
takes to get the job
done, including using qualified people in the appropriate
disciplines.  Nonprogressive
energy companies on the other hand are those companies with a
business as usual
attitude, and make excuses why they cannot reduce greenhouse gas
emissions.
	 What follows are some background information and details on how
a
progressive energy company would go about implementing the new
greenhouse gas
emission requirements, and how a nonprogressive energy company
would respond to
the requirements.
	There are several techniques and technologies that can be used to
reduce or
eliminate greenhouse gas emissions.  Some of these techniques and
technologies are
available today and are proven, and others are in various stages
of development.  What
most if not all have in common is that they are limited by the
availability, capability and
weldability of the steels and alloys of construction.  That is,
the steels and alloys and
their weldability are enabling technologies that make emission
control techniques and
technologies possible.  
	Progressive energy companies employ the three most important
engineering
disciplines for applying these enabling technologies, that is, the
Mechanical Engineer,
the Metallurgical/Materials Engineer, and the Welding Engineer. 
The mechanical
engineer is responsible for the design and layout of the power
plant mechanical
equipment and components, which includes vessels, piping, valves,
pumps, emission
control equipment etc.  This responsibility also includes the
design and operating
temperatures and pressures of the equipment and components, the
fuels used, and
writing the mechanical equipment and component specifications.  No
one understands
the design and operation of the mechanical equipment and
components more than a
person with a degree in Mechanical Engineering.
	The metallurgical or materials engineer is responsible for the
design, selection,
evaluation, recommendation and application of the steels and
alloys for the power plant
components and emission control systems.  No one understands the
depth and breadth
of the science and properties of steels and alloys more than a
person with a degree in
Metallurgical or Materials Engineering.
	The welding engineer is responsible for determining the best
processes,
methods, and procedures to use to weld and join the steels and
alloys for the power
plant components and emission control systems, while maintaining
the long term high
temperature properties of the steels and alloys.  No one
understands the depth and
breadth of the science of welding steels and alloys, and the
complex microstructure and
property changes taking place in the weld and base metal heat
affected zones more
than a person with a degree in Welding Engineering.  Contrary to
popular belief,
metallurgical and materials engineering are not equivalent to
welding engineering, and
neither is any other engineering discipline.  Welding is not a
required field of study to
receive the metallurgical, materials or other engineering degree.
	A good example of these engineering disciplines working together
correctly in a
progressive energy company is that of reducing carbon dioxide
emissions by increasing
the power plant thermal efficiency.  Increasing the thermal
efficiency requires operating
the steam power plant at higher temperatures and pressures which
has a significant
effect in reducing carbon dioxide emissions per kW of electricity
produced.  However
operating at higher temperatures and pressures causes wear and
tear on the steels
and alloys of construction which can lead to premature component
failures, plant
outages, unreliable generation, and shorter plant life. 
Therefore, before adopting this
emission control technique, the mechanical engineer in a
progressive energy company
would consult with the metallurgical or materials engineer to
determine if there is a steel
or alloy available that will last for the design life of the plant
at the new higher
temperatures and pressures proposed.  If no steel is available the
metallurgical or
materials engineer may design the steel or alloy.  Since the
design of steels and alloys
can take many years, reducing emissions by improving the thermal
efficiency may not
be an immediately available option.  Assuming a steel or alloy is
available, or the steel
can be designed in a shorter time period, the mechanical, and
metallurgical or materials
engineer would consult with the welding engineer to determine if
the steel or alloy can
be welded while maintaining its long term high temperature
properties.  If it can be
welded, the thermal efficiency of the power plant can be improved,
and the carbon
dioxide can be reduced.
	An actual real world example of nonprogressive energy companies
not using
these three engineering disciplines correctly, are the recent
attempts of some utilities,
their engineers, and designers to upgrade their plants by
specifying advanced power
plant steel SA335, Grade P91, 9Cr-1Mo-V 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.  As a
result of these failures the 2007 ASME Code was changed to include
some guidelines
on the proper handling of these steels.  I don’t think these hand
holding guidelines will
make much difference as long as nonprogressive energy companies
continue the
business as usual practice of using unqualified people to make
welding, metallurgical
and materials decisions.  Only qualified people in the relevant
disciplines will be able to
interpret, understand and properly apply these guidelines. The
ASME Code Committee
is continuing to approve other high temperature steels and alloys
as they become
available through the design and development process. 
Unfortunately if the business
as usual attitudes continue these newer advanced steels and alloys
may not be
specified and used because of a lack of understanding on how to
fabricate, weld and
heat treat these steels and alloys on the part of utilities,
energy companies, and their
engineers, designers and contractors.
	When assigning greenhouse gas emission limits and investigating
noncompliance to AB 32, the Air Resources Board should take into
consideration
whether the energy companies are using qualified people in the
relevant disciplines,
and are taking advantage of the high temperature properties of
newer steels and alloys
approved by the ASME Code to design and implement the Best
Available Control
Technology (BACT) for new and existing plants.  In other words
what are the excuses,
and are they legitimate?  The Best Available Control Technology is
only as good as the
best available qualified people in the relevant disciplines who
are designing and
implementing that technology