To: Tacoma.methanol.sepa@cityoftacoma.org

Saturday, February 6, 2016

EIS Scoping Comments: Tacoma Manufacturing and Marine Export Facility (TMMEF): “Proposed Methanol Plant”: SEPA Lead Agency: City of Tacoma (File No. SEPA2015-40000260025).

My comment applies to methane-to-methanol conversion process and combustion airborne inventory added—Methanol facility: “The applicant has stated 70% of natural gas will be converted to methanol, while the remainder will be combusted to produce energy for the chemical processes. Emissions associated with this combustion process will need to be disclosed.” See, Methanol EIS Draft Scope of Work 02052016.pdf (p. 5:n.8), http://cms.cityoftacoma.org/planning/Methanol%20Plant/Methanol%20EIS%20Draft%20Scope%20of%20Work%2002052016.pdf (last visited Feb 6, 2016).

In this case, we see “According to the U.S. Energy Information Administration ( EIA ) , . . . With about 100 cubic feet of natural gas needed to produce one gallon of methanol, . . .” See accord, Methanol: The Clear Alternative for Transportation – Methanol-Flexible-Fuel-Vehicles.aspx Methanol Institute, http://www.methanol.org/Energy/Resources/Alternative-Fuel/Methanol-Flexible-Fuel-Vehicles.aspx (last visited Feb 6, 2016).

Therefore, “One metric ton of methanol (2,204.62 lbs) = Approximately 333 U.S. gallons.” See, SCC – Southern Chemical Corporation » Methanol FAQ’s Southern Chemical Corporation, http://www.southernchemical.com/wp/safety-environment/frequently-asked-questions (last visited Feb 6, 2016).

As a result, My factoring, I find: (7.3-million metric tons / 333gallons) * 100-cubic feet natural gas = 2.2-million cubic feet of natural gas required with 70% conversion process; as a result, 0.9-million cubic feet of natural gas is burned or combusted and added to the airborne combustion byproducts inventory. (See, Tacoma “Draft”, Supra, P 2:n. 4).

My comment is this: With 1-million cubic feet natural gas (methane) combusted (burned) and added to Tacoma Community airborne chemical inventory; as a result, how does that compare with the average Tacoma homeowner using natural gas for heating and cooking with their airborne chemical inventory contribution? We have yet to be informed: will the Methanol facility consume “sweet- or sour-natural gas (methane)” because the amount of chemicals entrained within the natural gas stream is more with “sour-natural gas (methane)” and must be cleaned and the residue from cleaning sour-natural gas (methane)’ must go somewhere?

This “Draft” (Feb. 5, 2016) presents “[T]he EIS will not be designed to disclose every molecule of impact or capture every emission. That is an inefficient use of resources. . . .” (Supra, “Draft” p. 4). I disagree because if you are a person that is harmed by a fugitive Methanol Facility chemical molecule then a harm is a actual harm. See also, Soot Wikipedia, the free encyclopedia, https://en.wikipedia.org/w/index.php?title=Soot&oldid=702882659 (last visited Feb 6, 2016). Therefore I would suggest you don’t list the human health harm details but list every chemical molecule that will be fugitive from the Tacoma Methanol Facility processes. Just list all chemicals that will become introduced into the Tacoma Community airborne inventory caused by Methanol Facility!