A recent letter to the editor made several statements about the WSP facility that I would like to address. Many of them address technical issues that deserve more space than a letter to the editor will permit. We have taken note of all of them and will be addressing each one at upcoming public meetings and on our website, www.wspcasscounty.com. For now, let me attempt to summarize her claims and provide necessarily brief responses.
Claim: WSP’s application for their (sic) secondary metal production facility is lacking.
Response: WSP is not building a secondary metal production facility. We do not process scrap metal, we do not smelt or refine metal, and we have no metal in a molten state. We recover zinc and other important constituents from electric arc furnace dust to return them to the stream of commerce and into useful products, keeping them out of landfills. Please see pages 8-9 of our permit application for a more detailed discussion.
Claim: WSP’s application completely omits the mercury that would be liberated by burning coal.
Response: WSP will use anthracite, the highest grade of coal, and with the fewest impurities. You may be confident that the relatively low mercury content of anthracite (around 0.2 parts per million) is accounted for in calculating the facility’s expected mercury emissions.
Claim: The application says WSP’s emissions will be just under the “permitted” limit. This is a guess.
Response: The permit application materials are far from a “guess.” They were prepared in conformance with regulatory requirements, best practices, and a great deal of careful thought.
Claim: They offer no data from Zinc Nacional’s plants in Turkey, Mexico, S. Korea, or Alabama.
Response: The permit application package includes actual stack test reports from the Alabama facility, the most closely related facility to WSP. Our facility will also have fewer kilns and will utilize the latest generation of equipment and technology.
Claim: WSP will not use “best available technology” for air pollution. “Best” is electrostatic precipitators, but Cass County would get baghouse filters with the cheaper, less effective filters made of Nomax (sic) or polyester.
Response: There is no basis for any assertion that electrostatic precipitators (ESPs) would be more effective than baghouse (BH) filtration. The filter media (fabric) that we plan to use on our kiln baghouses are the most effective controls available. The product collectors, for example, feature a coated membrane for added efficiency, an added operating expense we undertake voluntarily in the interest of environmental stewardship and operating efficiency. With advances in material science and coatings such as these, baghouses are 99.5-99.9% efficient; ESPs are only 98-99% efficient.
Claim: There is no preventative maintenance plan.
Response: There is a great deal more to the safe operation of a facility than is included in a permit application. Just because it is not included in the permit application does not mean it does not exist. Maintenance plans are developed outside the realm of the permit application process and will be in place prior to startup.
Claim: There is no redundant system for filter failures.
Response: Lost product means lost revenue, so the process is designed to quickly identify any filter problems. Every module of the collectors and baghouses has a real-time sensor to anticipate potential problems. An individual compartment can be quickly isolated to allow for inspections and repairs while in operation.
Claim: Small particulate matter, PM 2.5, will be the largest category of pollution from this plant.
Response: Baghouse controls ensure we retain as much product as possible, and keep emissions well below regulatory and health thresholds of concern (and thus do not cause “pollution”). Our facility will actually generate far less small particulate matter annually than is generated from growing corn in Cass County.
Claim: WSP’s permit application does not account for approx. 319,999.5 tons of lead.
Response: Lead is definitely accounted for in the permit application, which totals 3,200 tons — not 320,000. As a recycling facility, the goal is to recover as much material from the electric arc furnace dust (EAFD) as possible. We capture and utilize the lead, which accounts for less than 1% of the EAFD. Through our process, 99.3% of the lead in EAFD ends up not in a landfill, but as an important constituent of the zinc product. Customers buying WSP’s zinc product process it further to separate the lead, which is sold to commercial users to make other products such as lead-acid car batteries and radiation shielding. The remaining 0.7% ends up as a trace constituent in the iron product. It is typically used in concrete manufacture, road construction and other processes using iron.
Claim: The used baghouse filters are thrown into the kiln.
Response: Yes, that’s how the zinc, lead and other valuable metals attached to the bag filters are recovered instead of needlessly sending them to a landfill.
Please continue to submit questions to us by phone, mail, email or to our website, where we can respond with more detailed answers. We encourage elected representatives and the community to take a close look at the benefits of our zinc recycling facility, not only for Cass County, but for the overall environment.