STOP THE SMELTER
Economic growth is an important planning aspect to growth of a community or region; therefore, we are not against the plant being built in La Paz County. In fact, we appreciate their interest in locating to the county, just in a more appropriate location.
Overall, most people in the Salome/Wenden area welcome new businesses that enrich the community and the quality of life, through job creation, county revenue and work culture. The economy in eastern La Paz County is driven by: agriculture, tourism, winter visitors and residents. Unfortunately, not all current or proposed new businesses will contribute to community enrichment through sustainable economical growth. In fact, some businesses can have a significant negative impact on area that can devastate the economy, the environment above and below ground and cost taxpayers a considerable amount of money for remediation.On the west edge of Wenden, at the corner of Highway 60 and Centennial Park Road, (location of the old cotton gin) an aluminum recycling smelter development is being proposed. The new owners of the property have submitted a request to the La Paz County Zoning and Planning Commission to pass a minor amendment to the County’s Comprehensive Plan and to change the zoning of this property from agriculture to heavy industry to facilitate this development.
Highway 60 corridor between Wenden and Salome is the most desirable area for future growth. It is the “main street” for the two towns and supports the livelihood and visual appeal for the two communities. Modern day planning methods place industrial zoning far beyond city-town population centers due to the negative impacts industry has historically had on property values, human and environmental health.
The building of an aluminum recycling smelting business poses unsustainable economic development and environmental hazards for human and desert wild life. Whether you agree or disagree with this position, the County needs to hear from the people who would be the neighbors of this development. Having such a decision made for Wenden by officials who live a long way from this community would not be in the best interests of the citizens and the tourism it relies on. These talking points have been prepared to help individuals discuss this development in an informed fashion. They are not organized in any particular order. Please share them with other residents of the area as you see fit.
- The Federal EPA labels secondary (recycling) smelter factories as some of the most hazardous facilities in the United States and are a major source of hazardous air pollutants. Locating such a facility within the town limits of Wenden, 0.75 miles from an Elementary school and within three miles of another elementary and high school has the potential of causing serious health consequences for our residents. Such a facility should be located at least 25 miles from the nearest pollution center. Even the owner of this property seems to be unaware of the location of the town since a Vice President of the company stated in an OP/ED piece on AZ Central: “homes can’t be found near out site.” To illustrate, the closest house to the smelter is 0.34 miles. There are 16 homes plus the DPS office within 0.50 miles of the smelter. Wenden Elementary is 0.75 miles from the smelter. The entire town of Wenden is within 1.0 miles of the smelter.
- Information sourced from Allied Metal’s application to ADEQ and the subsequent Draft Permit states that the facility will emit nitrogen oxides, particulate matter, carbon monoxide, sulfur dioxide, lead and hazardous air pollutants including dioxins and furans (think Agent Orange). The total amount of hazardous emissions will be 35 tons per year when operating at capacity, as stated in ADEQ’s Technical Review. However, the EPA issued a report in September of 1994 that stated, “there appears to be no ‘safe’ level of exposure to dioxin”. The maps from the AERMOD modeling, showing wind dispersion, have not been made public however the charts of the data are included in the technical review. ADEQ ran wind dispersion modeling using the EPA’s AERMOD program. Their finding is that the pollutants will mainly fall within or near the fence line of the facility. As stated in the technical review, the meteorological data used to create the model came from Agulia. The data used for the background concentration of particulates was from Lake Alamo, an area devoid of the particulate contamination from farm activity, which exists at the proposed site. The balance of the data used was from Tucson and Blythe, CA. It is our belief that the data used for the modeling does not accurately represent the conditions of the proposed site. With the winds that blow in the valley, it defies logic that most of the concentrations of the pollutants, according to ADEQ’s technical review, page 10, Section G, would fall: “within or near the facility fence line.”The draft permit calls for a “Method 23” performance test for dioxins and furans within 180 days of startup. It does not however require additional testing for a period of 23 to 25 months after that initial test. It then leans on the facility to self-report. This puts the health of the residents of this valley in serious jeopardy and does not represent a rational or responsible regulatory decision on the part of ADEQ for the protection of the environment or the public health. It also does not provide protection to the livestock and crops that are located close to the facility. How will the community know if dangerous hazardous pollutants are being emitted into the atmosphere during that 23 to 25 month period.
Self-monitoring has no credibility, yet ADEQ is only requiring the company to self-monitor. Without independent third-party monitoring of the permit conditions, this proposed permit has no validity or credibility.
- MACT requires CEM (Certified Energy Manager), there is no reason that real-time data could not be submitted to third-party verification for a potentially very dangerous facility that is in close proximity to a vulnerable community.The facility will be using and storing according to their application to ADEQ, 30,000 gallons of chlorine to use in the processing of the aluminum. This is an extremely dangerous chemical. It is so dangerous that the following is true: In the event of a catastrophic chlorine event, assuming that thee is a normal mile 10 mph wind blowing east toward Wenden, the edge of the town would be exposed to a chlorine gas cloud concentration of 1,000 parts per million in just four minutes and the entire town would be exposed to 4,000 parts per million in a mere six minutes. According to the CDC, exposure of 1,000 parts per million will be lethal, 4,000 parts per million is immediately lethal. Four minutes is not enough time to evacuate the town let alone the school. It might also be noted that there are no hazmat suits or masks made for children. These wind dispersion models were created using ALOHA, an EPA program used to assess such risk.As quoted in an article by David H. Nguyen, Ph.D.:“Recycling of aluminum produces many toxic chemicals that are released into the air. Furthermore, recycling aluminum produces a waste product called “dross” that is highly toxic and has to be buried in landfills. This dross must be tightly sealed in containers so that it doesn’t leak out and enter ground water.”
What assurances do we have that this byproduct will be properly handled to protect the air and our aquifer…our ONLY source of water in the area? How and where will it be transported and how do we know that it will not be stored for a long period of time on the property increasing the chances of groundwater contamination. What happens to our air quality due to this activity?
- Also by Dr. Nguyen: “In order to be recycled, aluminum must be melted to separate the pure metal from the impurities. This process produces a waste product known as salt cake (dross). For every ton of aluminum that is melted, 200 to 500 kilograms (2.2 pounds) of salt cake are produced. This “cake” is not something that you would want to eat – it contains aluminum oxides, metallic aluminum, carbides, nitrides, sulphides and phosphides. Salt cake is highly toxic to living organisms.” This facility will produce 192,720 pounds of salt cake per year. If any of this leaches into the aquifer it will contaminate it. The aquifer under this valley is 512 square miles and is the only source of water for people, animals and agriculture. The Valley would die.The fire department in Salome and Wenden is a volunteer department with some very dedicated people. These volunteers, however are not equipped or trained to handle a hazardous material accident. There is no training or equipment that would help them in the event of a catastrophic chlorine incident.56.2 acres or 40% of this property are in a flood plain. How would this facility protect itself from floods and what would keep deadly salt cake deposits from leeching into the aquifer?
- Additionally, the property is located on the edge of the Wenden’s land subsidence bowl which has increased the chances of flood. Wenden, as a result of this bowl, has sunk 3.5 inches in the last 15 years. This does not bode well for this facility in this location. Below is a graphic of the subsidence bowl that Wenden is in, according to the Arizona Department of Water Resources:
You can clearly see the property (black circle) where the smelter is proposed. Dark blue indicates the deepest part of the bowl and is rapidly expanding and deepening.
- There will be a significant amount of increased truck traffic on highway 60, Salome Road and Centennial Road. In fact, with the stated capacity of the plant at 87,600 tons of ingots and bars a year, it would generate an additional 584-50,000 pound trucks on the local roads per month just to move in raw material and ship out finished product. That says nothing of the various service and delivery trucks that would be coming and going. This plant will operate 24/7.Wenden is a low-income, rural community as is supported by census data and which has been admitted by Loren Barton, an agent of the company, in an article written on behalf of Allied Metals and posted on AZCentral. As such, it is covered by the 1994 Executive Order 12898 – Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations. We believe that this was a factor (Environmental Racism) in selecting this location. They did not believe that they would get significant push back.
The concern here is not so much incompetence or negligence on the part of the operators of this facility.Accidents happen! It is simply not worth the risk this close to a population center.