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folc.ca's comment on HAZCO's answer to FAQ #28


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 #28. There’s strong concern that if water seeps into your sulphur pile it will create significant amounts of sulphuric acid.  What assurances can you give that this won’t happen and what will you do if it does happen?

(Revised)The answer is no, rain that comes into contact with water will not instantly turn into sulphuric acid.  The water would need to stay and sit in contact with sulphur for a long while prior to become sulphuric acid so as a result we have incorporated a comprehensive surface water run-on/run-off control system at the site to minimize the length of contact of the water with the sulphur.  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.



Comment:

HAZCO states that, "The answer is no, rain that comes into contact with water will not instantly turn into sulphuric acid."  Although that is grammatically correct, that statement is semantically quite wrong.  Surely HAZCO must mean "...rain that comes into contact with sulphur will not instantly turn into sulphuric acid."

Aside from that error, SO2 released by fires at the HAZCO site will instantly turn into sulphuric acid when it comes into contact with water.  Moreover, contrary to HAZCO's beliefs, even just sulphur will cause water to turn highly acidic.  Consider this statement by a top-sulphur-expert:

"There is simply no way that we would use a metal cooling tower," said Doug Martin, Vice President and Operations Manager at H. J. Baker & Brothers' Wilmington California plant. A leading supplier of prilled sulfur for the agricultural trade, H.J. Baker & Bros. processes over 250,000 tons of sulfur a year at two California facilities.

"We spray molten sulfur into cool water in the prilling process," Martin said. "A cooling tower is needed to chill the process water after the sulfur bath. While the process water is part of a separate system, it becomes somewhat corrupted by minute sulfur fines in it. Those sulfur fines make the cooling system water highly acidic."

Source: Engineered Plastic Cooling Towers Impervious to Caustic and Costly pH Factors
By Ed Sullivan

We can expect a certain extent of increase in acid rain downwind from the HAZCO site; all the more so because HAZCO will provide a steady supply of moisture from its cooling towers to do it with even when there is no rain or fog.

Moreover, sulphur gradually but readily is converted into SO2 through the process of natural oxidization when coming into contact with oxygen contained in air.  The larger the surface of a quantity of sulphur that is being oxidized, the larger the amount of SO2 that is being produced in the natural oxidization process.  A very large surface area is to be had with a quantity of sulphur when the sulphur is in the form of dust. 

Update 2005 11 20: The large-scale and routine application of sodium lauryl sulphate with which HAZCO intends to drench the sulphur prill pile to prevent rain and melt water seeping into the sulphur pile from aiding thiobacilli in the production of sulphuric acid will present a new set of environmental problems.  Sodium lauryl sulphate is toxic to aquatic life and to people.  At any rate, HAZCO's repeated assertion that elemental sulphur is inert and will not produce produce sulphuric acid when getting into contact with water sounds hollow in the face of HAZCO's plan to employ the regular application of sodium lauryl sulphate to prevent sulphuric acid production. (See more information on sodium lauryl sulphate)

Sulphur dust, large quantities of it, is a singularly outstanding feature of sulphur-handling facilities.  Especially when the sulphur handling is done in the open air, as it would be at the proposed HAZCO sulphur site, wind carries the sulphur dust for long distances before it settles on surrounding land surfaces. 

A good portion of that sulphur dust will over time turn to sulphuric acid that will gradually seep into the groundwater and turn the land itself acidic to varying extents.  Agricultural land that is being made acidic through the deposition of sulphur dust originating from the HAZCO site can to some extent be returned to its normal state of acidity by liming.  The liming would have to be done regularly and most commonly on an annual basis.  Will HAZCO pay for the costs of that and for the costs of more frequent repairs to buildings, machinery, equipment and fences due to increasing levels of acid rain?

It will be impossible to contain the sulphur dust generated by HAZCO to the HAZCO site.  Therefore the assertions that HAZCO's provisions will prevent the creation of sulphuric acid from the sulphur dust its plant will generate are false and apply at best only to some small portions of the land surface occupied by the HAZCO site. 

Additional concerns regarding run-off water at the proposed HAZCO site and vicinity, and the inadequacy of HAZCO's design parameters for the collection pond are expressed in Comment #4 in relation to FAQ #25.

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Created Nov. 4, 2005
Updates:
2005 11 20 (added comments on sodium lauryl sulphate)
2006 10 16 (reformated)