Title V of the federal Clean Air Act requires states to develop and implement an air operating permit program in accordance with 40 CFR Part 70 for facilities that are the largest sources of air pollution.
These operating permits are often referred to as Air Operating Permits (AOPs), Title V Permits, or Part 70 Permits. They combine into one document requirements for operations, procedures, applicable regulations, emissions standards, monitoring, record keeping, and reporting. The purpose of the air operating permit is to make it easier to comply with and enforce air pollution laws.
Washington’s (Air) Operating Permit Regulation is in Chapter 173-401 Washington Administrative Code (WAC). The regulation requires a facility to have an air operating permit if it has the potential to emit any of the following:
- more than 100 tons per year of any pollutant, such as nitrogen oxides (NOx), volatile organic compounds (VOCs), carbon monoxide (CO), sulfur dioxide (SO2), and particulate matter (PM). Lower thresholds may apply in nonattainment areas;
- more than 10 tons per year of any hazardous air pollutant (HAP), as listed in subsection 112(b) of the federal Clean Air Act; or
- more than 25 tons per year of a combination of any HAPs.
Title IV Acid Rain Program;
New Source Performance Standards (NSPS); or
National Emission Standard for Hazardous Air Pollutants (NESHAP).
Title V Permit is required for any “major emitting source”, which the HiTest Sands, Inc., silicon smelter plant in Newport will certainly be. Emissions admitted to so far (but certainly not all - we know there are many, many more) are in the thousands of tons.
Most likely, HiTest will apply for the PTE exemption (Potential To Emit), which changes the status from a “major source” of emissions to a “minor source” by a simple play of words.
A facility that avoids the Title V program by accepting a potential to emit limit on the amount of air pollution it may release is referred to as a “synthetic minor” [source]. It is referred to by this name because instead of being a “major source” subject to Title V, the Permitting Authority’s regulatory action has turned it into a “minor source.”
This is nothing more then double-speak, deliberately taking the real meaning and emissions from a major pollution source and claiming it is less then it actually is, but the permit process is designed this way. The process is in fact, designed to give approval to major pollution emitters.
Unbeknown to the public which is repeatedly told to simply “trust the process”, the air quality permit process is plagued with significant loopholes that can easily allow major polluting emitters to be authorized (that’s how they get built). This is why blind trust in the process is the same thing as doing nothing, or giving your approval for a toxic industry to destroy your town.
The PTE is easily obtained by the simple trick of claiming lower hours of operation (and thus alleged lower emissions) and by other means to claim “reduced emissions” (on paper). Voila! Your toxic industry is now only a "minor source" of emissions!
Facilities that obtain the PTE to avoid Title V program, the limit must be practically enforceable, meaning that it must be possible to know in a timely manner whether the facility is actually complying with the limit, which often doesn't happen.
The US EPA has already required that a limit be federally enforceable in order to avoid the Title V program, the public and the US EPA must be able to enforce the limit in court.
a. what the actual limit is,
b. how the limit relates to the amount of pollution being released (e.g. if the limit is on the amount of fuel used each day, how does that relate to the amount of sulfur dioxide released by the facility?)
c. how the facility shows that it is complying with the limit;
d. when and how often the facility is required to measure compliance with the limit; and
e. when and in what form the facility reports the results of any monitoring to the Permitting Authority. This is important because once reports are given to the Permitting Authority, they must be made available to the public. You may have trouble getting records that have not been submitted to the Permitting Authority.
A facility can include permit conditions that will limit or "cap" its emissions to levels below the thresholds of Title V. To appropriately limit potential to emit, all permits must contain a production or operational limitation in addition to the emission limitation.
A production limitation is a restriction on how much of a final product a facility produces. An operational limitation is a restriction on how many hours a facility operates or how much raw material a facility uses. Restrictions on production or operation that will limit potential to emit include limitations on quantities of raw materials consumed, fuel combusted, hours of operation, or conditions that specify that the source must install and maintain controls that reduce emissions to a specified emission rate or to a specified efficiency level.
Yet despite these papered claims, without constant status reports based upon actual measurements taken daily or even hourly, what the paperworks says - and what the plant admits to are not always the same. Many industries will dump elevated emissions at night when they cannot be seen, but their effects (and smell) remain and can be reported by residents. It is up to the regulatory agencies - and a concerned public to demand enforcement.
It is important to remember that the permit process has been designed to grant permit approvals. This all happens before construction, and before plant operation. What this means for the region is when the permit is granted, it will be too late to stop the construction of the plant.
This is what the Commissioners, Greg Dohrn, Senator Short and every other complicit agency, public employee and supporter of the silicon smelter want. They have all told the public that they are “waiting on the permit process” and we should too, which is in effect, the same thing as telling the public "don’t resist this project".
1. If the plant requires an air quality permit (which it clearly does), then this means they are aware of air quality issues, emissions and pollutants. Pretending they aren’t aware only means they are being deliberately deceptive.Asking the public to “wait on the permit” is not in any way any kind of objection, concern, resistance or refusal of the silicon smelter, it is in fact a tacit admission that the silicon smelter will pollute the area and will be built. Once the permit is issued, public commentary or input is going to be useless. With that permit in hand, they're going to steamroll ahead right over this entire community.
2. If the air quality permit process approves the permit, then this means they are also in agreement with the air quality issues, emissions and pollutants that will be emitted - and cannot claim no knowledge later on. This right here is grounds for future lawsuits.
3. The air quality permit does not in any way, protect the public, workers or employees from possible harm. It is simply a paper chase, required by law, a process designed to grant approval (dot the i's and cross the t's and you're good to go).
The complicity, denial, claimed ignorance and disinterest by our elected officials is a gross dereliction of duty. The public which they were hired to serve is not being informed at all about the pollutants and HAP that will be emitted, or the effects upon the air, water, soil, health, forests and wildlife. Nor have they admitted to the environmental degradation and problems this is going to cause with the region’s forests, tree mortality and the resulting forest fires.
A few more things you should know:
What are Hazardous Air Pollutants?
Hazardous air pollutants, also known as toxic air pollutants or air toxics, are those pollutants that are known or suspected to cause cancer or other serious health effects, such as reproductive effects or birth defects, or adverse environmental effects. EPA is working with state, local, and tribal governments to reduce air emissions of 187 toxic air pollutants to the environment.
Link to list of 187 toxic air pollutants
Hazardous Air Pollutants (HAPs). The Clean Air Act regulates 188 hazardous air pollutants. Hazardous air pollutants are toxic in small quantities. Health problems related to hazardous air pollutants include cancer, respiratory irritation, nervous system problems, and birth defects.Sulfur dioxide is a known emission from silicon smelters and has a pungent unpleasant odor, and can mix with nitrogen oxide to form acid rain, causing serious harm to forests and plants (deforestation). Thousands of tons of sulfur dioxide will be released into the environment, along with nitrogen oxide, which will make for acid rain, degrading our forests and polluting the air.
Sulfur dioxide (SO2). SO2 reacts with oxides of nitrogen (NOx) and other substances in the air to form acid rain. Acid rain damages forests, makes lakes and streams unsuitable for most types of fish, and damages buildings, monuments, and cars. Also, high concentrations of SO2 can cause breathing problems for people with asthma. Symptoms include wheezing, chest tightness, and shortness of breath. SO2 emissions are transformed in the atmosphere into acidic particles. Long-term exposures to high concentrations of SO2, in combination with high levels of particulate matter (discussed below), may lead to respiratory illness, weakening of the lungs' defenses, and aggravation of existing cardiovascular disease. People with cardiovascular disease or chronic lung disease, as well as children and the elderly, are most likely to suffer from health problems linked to elevated SO2 levels.
Particulate Matter (PM)
PM essentially consists of small particles of soot, wood smoke, and other compounds in solid or liquid droplet form. PM can cause respiratory problems, as well as damage to lung tissue and premature death. PM can cause or worsen respiratory diseases and aggravate heart disease. PM reduces visibility, an issue that is of particular concern at national parks and other scenic areas.Carbon Monoxide (CO)
The main source of CO is automobile emissions, but CO is also released by woodstoves and by industrial sources such as boilers and waste incinerators. The health effects related to CO include visual impairment, reduced work capacity, reduced coordination, poor learning ability, and difficulty in performing complex tasks.Volatile emissions (VOC) from silicon smelting contain 200 different chemical compounds, many which are toxic, hazardous, carcinogenic and deadly (and unmeasured). These compounds can be found within the plant and in the air emissions released by the plant.
VOCs combine with oxides of nitrogen (NOx) in the presence of heat and sunlight to form ground-level ozone. Ground-level ozone damages lung tissue and can make it difficult to breathe. Children and people with asthma and other lung diseases are most susceptible to health problems caused by ground level ozone. When ozone levels are high, however, even healthy adults may suffer. In addition, some VOCs are hazardous in small quantities in the absence of any chemical reaction.Nitrogen Oxides (NOx)
NOx is linked to almost every air pollution problem. NOx emissions result in the formation of ground-level ozone, acid rain, coastal water pollution, and reduced visibility. Because NOx can travel very long distances after being released into the atmosphere, NOx released in one state can cause environmental damage in another state.The problematic United Silicon plant operating in Iceland was measured for emissions both inside and outside the plant. This is the same problematic silicon smelting plant reported here – “Gasping for Air - UnitedSilicon’s Enduring Problems".
A Research paper was conducted on the United Silicon Plant.
On behalf of Multiconsult ASA, a pilot study of VOC within and around a silicon smelter, United Silicon, has been carried out. The silicon smelter is located at Reykjanesbær in Iceland. 10 Tenax tubes were used as passive samplers and placed in a residential area and close to the silicon smelter, both inside and outside the plant. The samples were taken between 21.05.2017 and 23.06.2017.This paper reveals the 200 different chemical compounds, but it claims that they “could not identify any compound at concentration levels, which could have effects on the population in surrounding villages.”
They found high values of anhydrides in the baghouse, and 1-3-5-Trioxane which (a polymerisation product of formaldehyde), but admit that there are likely higher concentrations of formaldehyde, but they were not covered by the measurement technique used (Anhydrides are acids, irritants to skin, eyes and the respiratory system).
Formaldehyde is listed as a hazardous air pollutant by the EPA.
“Some compounds that could occur in the emissions of a silicon factory, like Formaldehyde and Acetaldehyde or COS,will not be detected by the chosen measurement technique, because of their high volatility. Compounds bound to particle emissions will also not be detected.”One of the more interesting points is they’ve claimed that -
a) The emissions are safe and will not cause any effects on the local population;I’m not the only one who identified the failures and claims being made here, there is this assessment too: Inconclusive Report on United Silicon’s Problems
b) Over 200 chemical compounds were found, but few were actually measured from this list;
c) Only 12 measurements were made over a one month period;
What this reveals is the following:
Inadequate measurements were taken over too short a period; and the measurement techniques were insufficient. But this also reveals that there are a huge range of chemical compounds being produced, which the silicon industry does not care to admit to. They are not being adequately measured, considered, reported or addressed. Anywhere.
Moreover, their claim that there would be “no effects on the population” absolutely fly in the face of the numerous complaints and problems reported.
How serious is the problem? Please be sure to read “Gasping for Air - United Silicon’s Enduring Problems” and what has occurred with a newly built silicon smelter in Iceland.
Plagued with numerous problems and issues, the local residents complained of chemical burns, toxic emissions, respiratory complaints, elevated and extremely dangerous levels of arsenic, and air pollution.
This isn’t just a one-off issue or complaint, an Iceland citizens group was formed years ago to try to stop the smelter from being built. They’ve also documented quite a few issues, complaints, violations and problems with the smelter after it was placed into operation.
There have been over 1,000 registered complaints made against the air pollution and issues caused (Google translation) that clearly shows major issues with air pollution, respiratory, resident complaints and sulfur dioxide issues.
How does this even happen? It happens because industry helped create things like the Clean Air Act (in the United States) and have had a handle on this ever since. Many of the research papers are actually funded by industry, which is akin to asking a wolf to protect the chickens. They know what's for dinner - do you? Baked Ala Newport, and Oldtown, Idaho silica dust on the side!
Lung Function Loss Associated with Occupational Dust
Exposure in Metal Smelting -
Chronic obstructive pulmonary disease (COPD) is caused by chronic inhalation of toxic particles and gases can lead to progressive tissue injury via a cascade of inflammatory processes in the lung.What dust? Silica dust. The same toxic material that HiTest wants to truck into our communities by the millions of tons.
There is a real danger unfolding upon the Newport, Oldtown, Priest River, Sandpoint and surrounding communities that is cause for serious alarm. Fortunately, the Mayor of Sandpoint has written a letter of non-support on the silicon smelter. It's a start, but we need a lot of people now! This should be a top priority in every home and family in this entire area.
If only our untrustworthy officials in Newport would also do the same! So far, all we've seen is a red carpet treatment for a foreign corporation as they conspire and collude to betray the public trust, violate our air, water, soil and quality of life and ask us to just "trust the process" which we already know does not work as we would expect, nor does it actually protect us as it should.
If it did - there would be no complaints, no sickness, no disease, no illness, no shortness of breath, no silicosis, no cancer, nothing but happy people and industry working side by side. But that is a fairy tale and it does not exist anywhere in the world. Smelter operations are TOXIC.
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