Foxconn Technology Group’s massive LCD manufacturing campus in Mount Pleasant could increase emissions of ozone precursors in Racine County by roughly 6 percent and the plant would be among the largest manufacturing emissions sources in southeastern Wisconsin, according to permit applications and data from the state Department of Natural Resources.
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The company, which plans to build a 22-million-square-foot, $10 billion campus, submitted permit applications to the DNR for a series of facilities, including an initial assembly facility, a nitrogen plant, energy facility and the main 818 fabrication plant. The four facilities, to be built in phases over the next several years, could combine to emit 229 tons per year of nitrogen oxides, 240 tons of carbon monoxide, 52 tons of particulate matter, 4 tons of sulfur dioxide and 275 tons of volatile organic compounds.
Most of the emissions will come from the fabrication plant where Foxconn will actually be building the LCD panels that will eventually become televisions and monitors. The fabrication process involves putting thin-film transistors and color filters on two glass substrates, joining the pieces together, inserting liquid crystals and cutting the displays to size.
A third-party glass plant on the campus, likely to be built by Corning Inc., is not included in the permit applications.
Foxconn has issued several statements expressing its commitment to environmental sustainability since choosing Wisconsin for its LCD facility. The most recent statement came ahead of a public hearing on the diversion of 7 million gallons of water per day for the project and related development.
“We take a systematic approach towards integrating green and sustainable practices in our global operations,” the statement said. “We also will invest in facilities to process exhaust gas in line with U.S. emissions standards and will also invest in leading technologies for waste treatment and disposal in compliance with environmental laws and regulations.”
There’s only one facility in the state – the Verso Corp. Wisconsin Rapids paper mill – that emits at or above the levels Foxconn is proposing across all five pollutants. There are, however, a number of facilities that emit substantially higher amounts of individual pollutants. The WE Energies power plant in Oak Creek, for example, emitted 3,676 tons of nitrogen oxides in 2016.
Among southeastern Wisconsin manufacturers, Foxconn’s permit applications would allow it to be the top emitter of nitrogen oxides and volatile organic compounds, based on a review of 2016 DNR data. The campus would be in the top five for carbon monoxide and particulate matter.
The Ardagh Glass plant in Burlington is currently the largest emitter of nitrogen oxides in Racine County at 116 tons in 2016. S.C. Johnson’s Sturtevant plant was the largest emitter of VOCs in the county that year at 163 tons.
Nitrogen oxides and volatile organic compounds are the two pollutants that could cause issues for the Foxconn applications, said Kristin Hart, DNR air permit section chief said. She noted the potential emissions figures are what the company is proposing it be allowed to emit. The figures are often much higher than what a source actually emits, sometimes by as much as 50 percent, she said.
The Foxconn plant’s proposed emissions would represent a 5.5 percent increase in Racine County nitrogen oxide emissions, based on data from the EPA’s 2014 National Emissions Inventory. The campus would also increase volatile organic compound emissions in the county by 6.4 percent.
Hart said the DNR will be considering the four applications as one. The agency will be putting together a draft permit and asking for public comment, likely later this month. A public hearing will also be held before the department makes a final decision.
The review comes as the U.S. Environmental Protection Agency is considering a nonattainment designation for Racine County on a new, more stringent 2015 ozone standard. The designation, which is also being considered for Milwaukee, Washington, Ozaukee, Waukesha and part of Kenosha counties, would require new developments to meet more stringent permitting requirements.
DNR secretary Dan Meyer asked the EPA in a Feb. 28 letter to designate the entire state as having attained the 2015 ozone standard, which is what the DNR recommended last year. If the agency is going to put a non-attainment classification on parts of the state, Meyer argued the designation should only be placed on narrow areas along Lake Michigan where the ambient ozone levels exceed the new 70 parts per billion standard.
The Racine County non-attainment area the DNR says is technically supported is to the east of the planned Foxconn campus.
“Wisconsin’s manufacturing-based economy is experiencing strong growth, which is improving the livelihoods and well-being of citizens throughout the state,” Meyer wrote to EPA administrator Scott Pruitt. “EPA’s intended designations threaten Wisconsin’s economic engine and could result in severe and unnecessary economic consequences.”
The EPA could make its final decision as soon as the end of April.
Whether the non-attainment designation could cause problems for Foxconn could come down to a matter of timing, said Paul Mathewson, a staff scientist at Clean Wisconsin.
He said one interpretation is that an emissions source would be considered existing if it has been permitted and begun construction before the non-attainment designation is made.
Foxconn’s applications are based on the plant being in an attainment area. The application for the initial LCD panel assembly facility indicates construction would begin in April with operations beginning by the start of 2019. The start date for the other three facilities is to be determined with operations to begin by 2020.
