folc.ca's comment on HAZCO's answer to FAQ #25

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 #25. What would happen if your sulphur pile caught fire?  What would the threat be to nearby residents?

In the unlikely event of a sulphur fire on site, the first responders would be the personnel currently on shift.  Given the proper training and equipment, it is intended that all such incidents will be dealt with immediately by personnel on site.  Sulphur fires are easily extinguished using water or by the use of any chemical fire extinguisher.  The onsite surface water runoff pond will also double as a fire water pond for source water.

There would be no threat to any nearby residents in the vast majority of incidences.  The Emergency Response Plan (ERP) for the facility will detail any actions required should the first responders fail to control the incident.  As a result, the ERP will be filed with the Town of Bruderheim, Town of Lamont, Lamont County, Northeast Region Community Awareness and Emergency Response Group, local industry representatives and Local Emergency Response officials.

Comment: What will happen in the event of a sulphur fire has already been explained in the comments pertaining to HAZCO's answer to FAQ #21.    However, HAZCO's answer to FAQ #25 contains false and conflicting assertions that need to be addressed. HAZCO states, "In the unlikely event of a sulphur fire on site..."  HAZCO's audacity boggles the mind.  As has been demonstrated in these web pages (the very pages you are reading right now) through the facts pertaining to the frequency and severity of sulphur fires, it is clearly wrong for anyone that has had no experience in the handling and processing of sulphur to state that sulphur fires are unlikely events. HAZCO states, "Given the proper training and equipment..."  That implies that proper training and equipment have to be provided and and must be available, but also that nothing is in place to make that a reality, and maybe not for some time. HAZCO states, "Sulphur fires are easily extinguished..."  That is true for very small sulphur fires (e. g.: a burning match stick).  It is patently untrue for sulphur fires of moderate or large size. HAZCO states, "The onsite surface water runoff pond will also double as a fire water pond for source water."  The original plans for the site made little or no provision for a water pond of sufficient size to put out a large sulphur fire at the site.  As a matter of fact, it appeared that HAZCO had intended the County of Lamont to construct and pay for the construction of such a pond, after HAZCO was made aware of the need for such a pond.     However, one of the maps made available Nov. 4, 2005 in the HAZCO Lamont information office showed a water pond east of the sulphur-prills loading facilities.     The pond dimensions or capacity are not shown on the map, although the map shows that the water depth is intended to be 12 feet.  The HAZCO representative stated that the water to be discharged into the pond is always recycled and warm, and that therefore the pond will never freeze over.  In its answer to FAQ #28 HAZCO states: ...The surface water run-off and run-off control systems have the following environmental protection measures incorporated into its design: Areas surrounding the sulphur handling areas will be sloped away from the facility to prevent surface water run-on; All precipitation that lands on the asphalt working areas of the site will be directed to the lined ditching systems on the pastille and sulphur block storage areas.  The ditching systems will direct all surface water run-off from the site to the 60mil HDPE lined surface water run-off pond.  The pond has a capacity of 10,960,000 l or10,960m3. HAZCO has no plans to discharge any of the surface water run-off collected in the surface water pond as the pond will be used as a source of water for process make-up water requirements and the fire suppression system.  In the event where water from the surface water pond needs to be released due to capacity restraints (likely due to excessive precipitation events), the water will be sampled and analyzed to confirm the surface water pond water quality meets applicable surface water quality guidelines. If the water within the surface water run-off pond does require treatment because of acidity, it will be treated using a neutralizing agent such as lime to neutralize the water. The pond is to have very gradually sloping sides and a plastic liner, with the greatest depth of the water to be 12 feet.  It appears that the volume of water that could be stored in the pond could be sufficient for most but not all sulphur fires that would occur at the site.    The pond is intended for, amongst other purposes, the collection of the surface water run-off at the HAZCO site.  Its capacity will be inadequate for that purpose.  After all, the dual purpose of the pond, to catch run-off and to serve as a source of water for fire fighting, is a conundrum.  To serve in its capacity as a reservoir for fire-fighting water, the pond would have to be always full, while to be at full capacity for the collection of run-off water from the site, it would have to be always empty.  HAZCO cannot have its cake and eat it, too.     There is little wisdom in the decision to place a sulphur-storage and -processing site right smack in the middle of a very wide and shallow seasonal run-off (the proposed HAZCO site contains what was called Mud Lake) that carries during the snow-melt and during heavy rain-falls water that drains off many sections of land in the area.    The HAZCO representative at HAZCO's Lamont information office stated unequivocally that all run-off water from the HAZCO site will go through the pond before it will be treated, neutralized and discharged downstream from the proposed HAZCO site.  It is not probable that HAZCO will achieve that, and it is unavoidable that HAZCO's promise will be broken.    Wide-spread flooding of land on the proposed HAZCO site is common (especially right in the location picked by HAZCO for its first facility), downstream towards the NW corner of the section of land intended to house the HAZCO sulphur site, throughout the pasture NW from the curve in Highway 45 on the north and west of that curve, all the way to Range Road 204 and beyond.  "Accidental" discharges of polluted water from the HAZCO site would be unavoidable.  They would be a necessary and unavoidable consequence of the design for the HAZCO site.    When the HAZCO site and its collection pond flood, it will not be possible for HAZCO to wave a wand and wish the water to stop running off downstream to give HAZCO time to decide whether the water needs to be treated before it can be released.  The floodwater will simply carry away whatever contamination is contained in the pond.    Rainfalls in this area often deposit 5 inches of water or more.  During the spring-thaw, the volumes of water moving through the location of the proposed HAZCO site have at times exceeded the extent of the flooding that occurs during moderately heavy rainfalls.     Let's consider the consequences of a moderately heavy rainfall of 5 inches (rainfalls here somewhat less often reach amounts that exceed that amount of deposited water).  Such a moderately heavy rainfall will deposit 266.7 acre feet of water on a section of land.  To catch all of that water would require a volume that covers a 22.2 acre area 12 feet deep.  As per HAZCO's answer to FAQ #28, the capacity of its collection pond is to be 10,960m3.  266.7 acre feet of water equal 328,928.5m3 of water, 30 times the capacity of HAZCO's collection pond.    How much of a given amount of rain seeps into the ground before it reaches its intended target, the collection pond, depends on the intensity of the rain.  In a heavy downpour little of it will have time to seep into the ground, and HAZCO won't have enough time to do anything at all to prevent the contents of the pond from being flushed out and into the seasonal run-off (see Mud Lake) in which the pond is located.  No amount of magic HAZCO may be able to summon will prevent that from happening.  HAZCO cannot stem a flood.  HAZCO will potentially have floods every time a given rainfall exceeds an amount of about half an inch of rain, depending on the intensity of a rain fall and on whether the soil surrounding the plant is already saturated with water or frozen.    Unfortunately, the volume of run-off water moving through the proposed HAZCO sulphur-plant site often includes the run-off from far more than merely one section of land.  Sorry for having to bring the bad news to HAZCO, but when HAZCO bought that section of land from Alberta Energy Company (AEC) Pipelines, they received for their troubles what is commonly referred to as "a bill of goods".     A solution is possible and quite likely within HAZCO's means.  HAZCO can design and construct a canal to divert water run-off that would otherwise, with the present design, frequently flood the HAZCO sulphur-site.  That would still require HAZCO to design, engineer and construct a pumping system that will keep HAZCO's plant site high and dry and the contaminated-water collection pond from being flooded with run-off water from just HAZCO's sulphur site.    The most obvious and cheapest solution is for HAZCO to find a piece of land that is high and dry and does not straddle a seasonal run-off.  The Swan Hills area contains an abundance of far more suitable site locations.    Certainly, that advice is free, but it and all of it offered to HAZCO in these web pages (the very pages you are reading right now) is worth millions of dollars to HAZCO, if HAZCO heeds it.    The currently contemplated size of HAZCO's collection pond pond is pitifully inadequate.  Especially when it is already full of water being treated and doubling as a fire-fighting water source, the collection pond will not have any spare capacity left to accommodate all of the water that needs to be stored from the run-off of even a light rainfall.  Keep in mind that during the snow melt and during heavy rainfalls the level of the flood water at the location of the pond will exceed the height of the water level in the proposed pond, so that the polluted water in the pond will be swept downstream, all the way to the North Saskatchewan Rivers, polluting vast areas of farm land along the way.  HAZCO states, "There would be no threat to any nearby residents in the vast majority of incidences."  It must be posed that a corporation making that excessively unacceptable and misleading statement will not be trusted with much else it states.  There is an abundance of readily available evidence that proves that sulphur fires not only frequently pose great risks to people, property and the environment but that they do cause great damage and even kill people and all life forms (animals as well as vegetation) in vast areas surrounding the locations of those fires.  (More details about sulphur fires are contained in the comments pertaining to FAQ#34.  Check also the web pages accessible through the links shown in those comments.) HAZCO states, "The Emergency Response Plan (ERP) for the facility will detail any actions required should the first responders fail to control the incident.  As a result, the ERP will be filed with..."  With great anticipation and trepidation, we look forward to receiving and perusing HAZCO's emergency response plan, once and whenever it should be produced by HAZCO.  (More details about the effects of SO2 are contained in the comments pertaining to FAQ#34.  See also footnote to SO2 Toxicity Table)

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Created Nov. 4, 2005
Updates:
2005 12 04 (corrected Range Road number)
2006 10 16 (reformated)