Text of an e-mail message sent 2006 04 13 to members of the
Bruderheim Residential Committee
For your information:
Attached is a PDF file containing
the Lamont County Municipal Planning Commission's decision (240
kB) on HAZCO's proposal for the construction of a sulphur storage
and handling facility in Lamont County.
The attached document has no title page. Therefore I must assume
that it is an incomplete file, and I also cannot call it by an
official name. However, the file is exactly as I received it today
from Debbie Hamilton, the secretary of the Lamont County Municipal
Planning Commission. The MPC decision is well reasoned, except
perhaps for an apparently wrong perception by the MPC regarding the
role of volunteer fire departments if a sulphur fire should happen
at a sulphur site. (More about that in the appended comment).
Yesterday I received by fax an advance copy of the attached PDF
file. Immediately I began to inform some of the people that had
helped to make the MPC decision come about. During the ensuing
conversations with various individuals it became obvious that some
people have no clear understanding of what place the MPC takes in
the approval process for an application such as that made by HAZCO.
To clarify that issue, have a look at the flow chart of the approval
process that was put together along with the information provided
for the writing of letters of concern to Alberta Environment, about
HAZCO's application. (<http://fathersforlife.org/Bruderheim/sulphur_storage/AEnv_letter_intro_1s.jpg>,
source: Letter by The Friends of Lamont County to the residents in
the County (page 1, page 2), dated Dec. 16, 2005)
The MPC's decision does not necessarily put an end to HAZCO's
attempt to install in Lamont County what HAZCO had failed to achieve
in Thorhild County and in Sturgeon County. It is possible that
HAZCO will launch an appeal. The flow chart contained in the
document at the following link identifies the possible further steps
that may be used in attempts to push through HAZCO's intentions for
Lamont County.
<http://fathersforlife.org/Bruderheim/sulphur_storage/AEnv_letter_intro_1s.jpg>
The MPC's decision puts an end to round one in the fight to win
against HAZCO's proposal. It remains to be seen whether HAZCO
throws in the towel now or gets up and continues the fight in the
second round.
At any rate, HAZCO will not be short of a lot of money on account of
giving up. The section of land bought by HAZCO for its proposed
sulphur storage and -handling facility in Lamont County has
appreciated considerably since the time of its purchase and can be
sold for a tidy profit.
There is an outstanding issue that is also part of the approval
process. That is the pending decision by Alberta Environment
following HAZCO's application to Alberta Environment.
The decision by Alberta Environment had originally been scheduled
for the middle of March of this year. Due to the large number of
Letters of Concern that had been sent by residents of Lamont County
to Alberta Environment, Alberta Environment was moved to identify
that its decision would be delayed until about the end of the month
of March. It is now the middle of April, and Alberta Environment's
decision still has not come forth.
It is possible, although quite possibly not likely, that Alberta
Environment's decision will be in favour of HAZCO's application. If
the decision is in favour of HAZCO's application, it will become
somewhat more difficult but not impossible to win against HAZCO in
round two of the process. If Alberta Environment, too, decides that
HAZCO's application has no merits for the proposed location in the
County of Lamont, then the fight is just about over, although HAZCO
will then still have the option of launching appeals.
Regardless of the whittled-down current, and currently initial,
details of its original intents for Lamont County, the ultimate
intention of HAZCO's application is to dispose of "the
waste stream of the desulphurization units" generated by various
refineries and oil-sands oil upgraders in Strathcona County, in the
Lloydminster area, and in the Fort McMurray area and remains in
effect unchanged; only the location has changed. Approval of
HAZCO's application would in essence result in having Lamont County
become a cesspool for the waste sulphur produced by Alberta's oil
industry.
Alberta Environment made a good decision in the case of HAZCO's
application for the County of Sturgeon, when it directed that HAZCO
must do a full Environmental Impact Assessment study there. HAZCO
did not comply with that directive and instead moved its venue to a
different location. Given that in essence none of the essential
details changed in the case of HAZCO's proposal for the County of
Lamont, I trust the integrity and judgment of Alberta Environment
will lead to the same outcome, the directive to HAZCO to perform a
full Environmental Impact Assessment study here.
That is about it for now. Don't neglect to read the appended
comments regarding the use of volunteer fire departments for putting
out sulphur fires.
All the best,
Walter Schneider
_______________________
---Volunteer Fire Departments and Sulphur
Fires---
The Lamont County Municipal Planning Commission correctly
identified many serious shortcomings in the information provided by
HAZCO in relation to the application for the construction of a
sulphur processing and -handling facility in the County of Lamont.
One of those shortcomings is this:
The Developer's statement that the first responders will be
staff rather than the volunteer firefighters does not seem
feasible. Shifts and vacations may reduce the number of the
staff on the Lands at any one time, especially during the night
shift. Further, in the event of a fire not all staff would be
available to fight the fire as presumably some staff may be
required to operate the facility itself; in an emergency
situation certain staff members may not be able to leave their
posts.
Fire protection in the area is provided by volunteer Fire
Departments. Training and personnel may be very limited. The
MPC is particularly concerned about putting volunteer
firefighters in harms way; if the volunteer firefighters are
expected to address an industrial emergency lack of numbers or
lack of training (and in particular respecting hazardous
materials) may put the firefighters or in turn the public at
undue risk. The MPC is of the view that in the area of
emergency response, an industrial developer should essentially
be "user pay". However, because the developer has not tabled
the Emergency Response Plan (even in a draft from), the proposal
cannot be properly evaluated.
I am the president of the Bruderheim Rural Electrification
Association (REA) and also director for District 7 of the Alberta
Federation of Rural Electrification Associations. On account of
that, yesterday afternoon, before I knew of the MPC's decision on
HAZCO's application, I had an opportunity to discuss the issue of
using volunteer fire departments for fighting sulphur storage fires.
The AFREAs board member I had the discussion with is fire chief for
a region in central Alberta. I asked him whether his fire crews had
ever been involved in putting out a sulphur fire. He indicated that
they had been involved, but only in connection with a simulated
sulphur fire at Windburn, west of Olds. However, he stressed that
volunteer fire departments are prohibited from fighting actual
sulphur fires, and that their role in the event of such a fire would
be restricted to assisting with necessary evacuation of personnel
and people at risk.
The fire chief I spoke to mentioned that the respective roles of the
parties involved in fighting a sulphur fire are clearly spelled out
in emergency response procedures manuals. I mentioned that not even
a draft of such a manual had yet been produced in connection with
the HAZCO application for the County of Lamont.
"Oh," he said, "they haven't produced an ERP manual? Ours is about
so thick," and he indicated a thickness of roughly three inches by
the distance of the spread between his thumb and his index finger.
He recommended to get in touch with Pat Graham, the Master Chief of
the Provincial Fire Fighters Association, so as to get a better
handle on what all is involved with having local volunteer crews
fighting sulphur fires, and on what pertinent constraints apply.
I asked the Central Alberta fire chief who fights the sulphur fires
that may happen. He said that the various facilities have their own
trained and equipped firefighters, and that if they were to need
help from other fire-fighting crews, they would have to contact the
Master Chief of the Provincial Fire Fighters Association.
One thing is certain as of now in relation to fighting sulphur
fires. Regulations for work safety standards dictate that a minimum
of two firefighters must be fighting a sulphur fire. They must be
equipped with self-contained breathing apparatus. Furthermore, two
more firefighters -- also equipped with self-contained breathing
apparatus -- must be present and stand by to assist if a rescue of
the firefighters involved in fighting the fire should be necessary.
The apparently false presumption by HAZCO that our volunteer
firefighters can be expected to put out sulphur fires at the
proposed HAZCO sulphur facility may be a consequence of HAZCO's
involvement in cleaning up the site of a CPR 50-car sulphur train
derailment about half-way between Medicine Hat and Seven Persons, in
Southern Alberta, Dec. 4, 2002.
The Dec. 4, 2002 sulphur-train
derailment and fire near Medicine Hat.
4.) ...although the initial fire had been put out, additional
fires broke out repeatedly for a period of six weeks. The
reason for that was, as per the landowners, that all 42 of the
derailed rail cars had to be ripped apart, to spill the sulphur
(liquid as well as solidified sulphur) onto the adjacent land
and into the adjacent irrigation canal, as there was no method
or place available for the disposal of the sulphur contained in
the cars [where did the sulphur eventually go?]. The work
associated with that caused the additional fires. [As per
the TSB derailment report, the Seven Persons fire department
stood by for the duration of the 6-week salvage operation to put
out any fires that happened to be started during the necessary
work.] However, as the landowners report, often when HAZCO
employees went home at night to resume work the next morning,
they had to call HAZCO to tell them that sulphur at the site had
begun to burn once more. Upon being notified, HAZCO employees
would return and extinguish the new sulphur fires that had
erupted in their absence. (Full
article)
The owner of the land on which that train derailment happened told
me during my visit to the derailment site, "Well, of course HAZCO
had to put out those fires, although I don't know whether the Seven
Persons fire department ever helped with fighting the additional
fires. The Seven Persons fire department is manned by volunteers.
They've got jobs, and they could not possibly be available for a
full six-week period on standby." Incidentally, although an
evacuation of 20 people (in seven families) had taken place three
hours after the derailment happened and the initial fire that had
burned ten of the derailed cars, during the subsequent fires no
evacuation orders were issued. During that time the son of the
landowners I spoke to developed heavy and frequent nosebleeds that
persist until today, although somewhat less frequently now. The
landowners also lost a prize-stallion, a national halter champion, a
stallion that they estimate was worth $50,000.
All of that is common sense. We all know that, and we all are old
enough to have acquired a good portion of common sense. Should that
not also be true of HAZCO? Are there perhaps two brands of common
sense, one for those who for the sake of profit put people at risk
and another one for the people put at risk?
--Walter
