October 24, 2018
Eastern Regional Director
Washington Department of Ecology
4601 N. Monroe
Dear Director Pfeifer,
The Lands Council would like to provide comments on the proposed PacWest Silicon Smelter, during the scoping period. We are incorporating our letter of March 14, 2018, which is Appendix 1, which encouraged more attention to air-shed modelling and data capturing.
In addition, we request a thorough analysis of the air emissions from the smelter and alternatives to the proposed design.
Citizens in Pend Oreille and Bonner Counties are rightfully concerned about the emissions that might come from the facility, including sulfur dioxide, nitrous oxides, carbon dioxides, and particulate matter. Specifically we ask that the following be considered:
Coal from Kentucky will provide the carbon for the smelter process. We believe there are better options that would substantially reduce the sulfur dioxide. One of those options is the use of locally produced biochar. Biochar, or activated carbon, is produced from wood or agricultural waste products, such as slash piles, seed milling residue, crop residue, and other plant materials. It has a much lower sulfur content, creates jobs locally, and also avoids transportation costs and diesel emissions.
Power plants, smelters, industrial furnaces, and waste-to-energy plants all release nitrous oxides. Filters and scrubbers can eliminate much of this nitrous oxide – which like sulfur dioxide can lead to acid rain. The silicon smelter should use a state-of-the-art air pollution control system that includes an acid scrubber to neutralize acid gases with a slurry of lime and a baghouse – this works like the filter in a vacuum cleaner, trapping particulate matter with a series of “gortex” fabric filters. Ecology should conduct a thorough analysis of reducing the nitrous and sulfur oxides. The flue gas cleaning technology, Selective Catalytic Reduction (SCR), reduces nitrous oxides. We ask that SCR technology is considered. Mitigation of other expected air emissions, including PM2.5 emissions, should also be analyzed.
The carbon dioxide emissions are massive. PacWest claims that at least half of the silicon produced will be used in solar panels. What commitment is PacWest making that this would actually occur?
There are other potential contaminants, depending on the process, including mercury, carbon monoxide, etc. The analysis should look at the range and levels of pollutants and how they would be treated. How many furnaces will be at the facility and what model/type are they? If the smelter expands, projected future emissions should be analyzed.
Startup, shutdown, and intermittent use can give off very different emissions than continuous operation. What best management practices (BMPs) will be used during the smelting operation?
The proposed location of the smelter has moved from one controversial site to another. Is the current site permanent or will Ecology look at other areas in Pend Oreille County?
There have been claims about water usage and disposal. The source and quantity of that water should be addressed.
As our region makes efforts to transition away from fossil fuels to solar and wind, we must insist that renewable energy also be done in an environmentally and socially responsible manner.