folc.ca's comment on HAZCO's answer to FAQ #21

Note: The background text in the following was copied from the Frequently-asked Questions page at HAZCO's website, Nov. 2, 2005.  HAZCO's answers to "frequently asked questions" deserve further comments.  Those comments are inserted where required in HAZCO's text and are shown on yellow background.

From HAZCO's FAQ web page (quoted verbatim):

FAQ #21. What assurances can you give people living nearby that noise, lights and smells won’t impact their quality of life?

With respect to the noise, Hazco will be completing a Noise Impact Assessment prior to and, if approved, after start-up of operations.  Any noise impact beyond established acceptable levels will require attention.  

Lighting concerns have been identified and as a result Hazco is committed to using directional lighting as opposed to flood lights, minimizing the amount of light pollution.

Odours at the site will be non-existent as all of the sulphur received on site is degassed to less than 10ppm H2S.  With the facility located at the center of property and a minimum of 600 meter setback from the surrounding properties, we believe there will be no odours at the site boundaries.

Comment: It is easy to give assurances.  The less binding they are, the easier they are to give, especially when they are, as is HAZCO's last one regarding odours, firmly founded in alleged beliefs.     The more HAZCO talks about beliefs, they more one must worry.  Beliefs are opinions.  Opinions that are based on beliefs are by definition not based on known facts.  Beliefs come into existence when no, not all or few facts that substantiate and corroborate an opinion are known.     Except in totalitarian regimes, no one is likely to be legally held responsible for his beliefs or for the quality and accuracy of his beliefs.     When assurances are based on clearly stated beliefs, that will in advance exonerate the one whose beliefs will eventually be proved wrong by facts and reality.  It is extremely unlikely that any judge in civil court will hold a corporation liable for damages if that corporation caused injury and damage on account of having held wrong and long-ago-stated beliefs about its unproven future quality of performance.  That is all the more true if the harmed parties were informed of the beliefs held by the party having caused the harm inflicted and never objected to the false assertions.    Of course, once the ownership of an industrial facility whose original owners held wrong beliefs changes hands a few years down the road (quite common in today's corporate climate of frequent mergers), a totally new ball game starts.  Blame, responsibilities and liabilities are then extremely difficult to assign.    Lawyers grow rich on cases where due diligence has not been exercised and accidents were caused by harmful practices that were based on beliefs that were accepted as the basis for standard operational procedures to which no one ever objected. HAZCO is to be commended for being considerate enough to contemplate noise-impact surveys, although it would probably be better to have an independent party guard the henhouse.    Nothing has ever been said by HAZCO about the excessive noise caused at Shell's Shantz sulphur facility by the wheel flanges of 150-car sulphur unit trains rubbing against the rails of the tracks around which those trains are being pulled while being loaded.  That noise is like noise from hell and is incessant when sulphur unit trains are being loaded.  The noise can be heard for miles.  If the incredible should happen and HAZCO's proposal receives approval, we have to make certain that the noise impact modelling that may be done or contracted by HAZCO includes the noise created by hundreds of simultaneously screaming railroad car wheels.  Better yet, we have to make sure that whatever answers HAZCO produces in relation to that issue include as a yard stick the noise measured at Shantz.  That is better than any modelling.  No model is an accurate representation of reality. The lighting considerations are important, too, but directional floodlights are standard operational procedure in such circumstances.  HAZCO cannot be given too much credit for indicating that directional floodlights are intended to be used. Nevertheless, neither objectionable noise nor objectionable lighting conditions, no matter how objectionable they may be, are necessarily dangerous or even deadly.  However, the statement regarding the non-existent odours at the site is clearly false and an erroneous assertion.  To assert that odours will be absent at the HAZCO site is a very seriously misleading and dangerous statement, given that the odours of concern are those of extremely dangerous, unhealthy and even deadly substances such as hydrogen sulfide and sulphur dioxide.  There is no possible way, whether based on facts or beliefs, that would justify HAZCO's assertion that odours will be non-existent at its site and therefore absent beyond its site boundaries. Hydrogen Sulphide (H2S) Sulphur is to some extent biodegradable.  The bacteria that are attracted by sulphur and thrive on it produce hydrogen sulfide and other sulphur compounds that produce objectionable and, above certain concentrations (at which the olfactory nerves will no longer detect the rotten-egg smell of it), deadly levels of hydrogen sulfide (H2S).     H2S generated by bacteria that feed on sulphur dust emitted by HAZCO will without a doubt become a problem over the years, for instance in the well water that people in the vicinity use for drinking and other household purposes.  However, that issue is not being addressed in the question of whether odours in the vicinity of the proposed HAZCO site will be a nuisance.  The question and HAZCO's answer to it relate to whether the air in the vicinity of the proposed HAZCO site will smell of rotten eggs if the site goes into operation. Here is a summary of Alberta Environmental Protection guidelines as to what concentration of H2S constitutes an objectionable level of odour of H2S. 6.0 EXISTING GUIDELINES The current Alberta Environmental Protection ambient air guideline34 for H2S (10 ppb) is based on odour effects. The documentation states "odour is considered the limiting factor in setting ambient hydrogen sulphide limits. No health or vegetation effects have been reported at the selected ambient levels of H2S. Odour threshold is set at 0.01 ppm concentration of H2S. Threshold Limit Value (TLV) is set at 10 ppm. The minimum concentration of H2S at which human health effects (minor) start is 20 ppm for a short term exposure. There is no time averaging stated in the guideline’s documentation. However, recent Alberta Environmental Protection literature refers to a time-averaging period of 1 hour. For comparison purposes, various Canadian and United States standards and guidelines are given in Tables 6.1 & 6.2. A large inconsistency across jurisdictions is evident as the guidelines or limits vary over 6 orders of magnitude. Source: HEALTH EFFECTS OF HYDROGEN SULPHIDE: Knowledge Gaps, By Dr. Sheldon Roth and Verona Goodwin, Science and Standards Branch Alberta Environment, p. 137 <http://www3.gov.ab.ca/env/protenf/publications/H2S_Report.pdf> Note that objectionable odour of H2S will occur at a level of four parts of H2S per billion parts of air, a ratio 2,500 times lower than the upper permissible level of 10 parts per million contained in the sulphur of which HAZCO boasts.  However, notice also that although according to Alberta Environment human health will be affected when the H2S concentration in air reaches a level of twenty parts per million in short-term exposures, according to others, chronic long-level exposure to levels as low as 7 to 10 parts per billion will result in irreversible brain damage, especially in children. The sulphur will be delivered in liquid form.  When it is discharged for the forming of the sulphur storage block, the atmospheric concentration of H2S at the location of discharge is bound to be far higher than ten parts per million.  After all, the H2S that is being discharged at the ejector into the atmosphere is almost pure and highly concentrated.    In fact, the H2S released at the discharge end of the ejector will initially contain no air at all and be absolutely deadly.  It is not very reasonable to hope (or to believe, as HAZCO is apt to claim it does) that H2S released by HAZCO in such highly concentrated form into the atmosphere will become diluted through air turbulence and mixing with the ambient air to less than the objectionable level of four parts per billion before the air contaminated by it leaves the boundaries of the proposed HAZCO site. Sulphur Dioxide (SO2) Sulphur Dioxide (SO2) is not likely to be contained in the sulphur delivered to the proposed HAZCO site at more than trace amounts.  Aside from it (and sulphuric acid) being generated by bacteria that love sulphur and feed and thrive on sulphur, SO2 is produced when sulphur is burned in the presence of oxygen.  As sulphur ignites relatively easily at higher temperatures when oxygen is present, great care is taken in the production of sulphur to exclude oxygen from all processing stages.  Therefore, SO2 will not (or only miniscule levels of it) be contained in the sulphur to be delivered to the proposed HAZCO sulphur site. Unfortunately, when sulphur comes into contact with iron (such as with the iron in the steel of which transport tanks are made), it likes to go into chemical reaction with the iron and form pyrite, some forms of which ignite through nothing more than simple exposure to air.  Sulphur by itself, in air, is easily ignited. The melting point of sulphur is +119°C The flash point of sulphur is +207.2°C The self ignition point of sulphur is +232.2°C The temperature required to ignite sulphur can be produced through many circumstances, for instance by a hot bearing, the pressure of a railroad car wheel on a track covered with sulphur dust, through the friction of a front-end-loader bucket on sulphur-covered concrete, or simply through a discharge of static electricity caused by wind in sulphur whiskers that commonly form under certain atmospheric conditions at the rims of vents or ports of tanker cars.    It does not take much to create the flash-point temperature of sulphur.  Very slight accidents will bring it about.  Sulphur fires are a frequent occurrence in many sulphur-processing and -handling facilities.  Sulphur fires are relatively easy to put out when they are very small.  All it takes is water or foam or a a layer (blanket) of nitrogen.     Sulphur fires are not very easy to detect when they start.  The flame of burning sulphur is almost invisible, not easily noticed, especially in sunlight or strong light conditions.  What is noticeable about a sulphur fire is the smell of the SO2 produced by it.  That smell cannot be ignored by anyone hit by it.  SO2 is extremely pungent, very painful in all mucous membranes touched by it, eyes, nostrils, sinuses, throat and lungs.  SO2 instantly turns to sulphuric acid when it comes into contact with water.  Mucous that lines or covers mucous membranes consist largely of water.  No one having experienced it once wishes to have the water in his mucous membrane converted into sulphuric acid.  Once is enough; it is an extremely painful, damaging and at times even deadly experience. It is absolutely certain that the employees at the proposed HAZCO sulphur storage and processing facility will experience sulphur fires.  The question is whether the fires will always be detected and extinguished before they reach proportions that make it very life-threatening to put them out.  A sulphur fire of moderate proportions will make it necessary for the fire fighters to wear self-contained breathing gear.  Some sulphur fires in recent years reached catastrophic proportions and took from 14 days to a month to be extinguished.  Such large fires obviously can and do happen.  The very large volumes of SO2 produced by such fires kill all vegetation and life forms for miles around, depending on into which direction the wind blows the SO2. The question HAZCO should have posed and answered at their Frequently-asked Questions page is whether the necessary evacuation procedures are in place and what form they will take.  Moreover, HAZCO should have explained how it intends to cope with damage claims for loss of health, life, income and property when such a large fire occurs.  HAZCO shows itself to be extremely irresponsible when it downplays concerns about sulphur fires. A large sulphur-block fire (suspected to have been started through arson) in Iraq affected three cities and about 50 towns in the vicinity.  It took the US Army Corps a whole month to put that fire out.  The stench of rotting livestock carcasses made life in the aftermath of the fire unbearable in the area, and the loss of crops was estimated to be in the order of $50 million.  No information is available as to whether anyone received compensation for damages or losses caused by that fire, although in the case of a large sulphur block fire in South Africa some damages were paid — seven years after the fact. The proposed HAZCO sulphur site has the potential to cause a catastrophe of that order.  It is far better to locate it where it belongs, in an area that is very sparsely populated or not populated at all but not in the County of Lamont. Check more details and some statistics on sulphur fires and on Evacuations of residents or workers in cases of incidents of sulphur-handling-related accidents. As is apparent through the comment provided in relation to FAQ #34 in this set of pages pertaining to the HAZCO FAQs, HAZCO is aware of these web pages (the very pages you are reading right now) and the questions raised in them.  Although in their response to FAQ #34 they provide no indication of that.    Nevertheless, as you can see in HAZCO's response, all of the concerns with the facts cited in those pages are being downplayed by HAZCO.

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Created Nov. 4, 2005
Updates:
2005 11 20 (elaborated on comments pertaining to objectionable noise)
2006 10 16 (reformated)