Don't Waste Arizona, Inc

Don't Waste Arizona, Inc.

A non-profit environmental organization created for the protection, conservation, and preservation of the human and natural environment in and around Phoenix, and the state of Arizona.

Chemical Spill

Nukes won't halt Climate Change

Proposed Zoning as National Sacrifice Zone

The proposed zoning is to place a heavy industrial use smelter in an agricultural area adjacent to residential zoning that is completely out of line with the La Paz County General Plan. A revision to the General Plan would require a public process and public input. In other words, some semblance of democracy. This heavy industrial smelter is directly counter to the existing zoning of agriculture and residential. Additionally, this has a very real chance of having a negative impact with current economic generators in La Paz county such as tourism, recreational uses, and winter visitors are all incompatible with this heavy industrial smelter.

The operators of this proposed heavy industry aluminum smelter have no use for democracy and want to jam this into an area that will be forever changed into a national sacrifice zone and with near unanimous disapproval from the public who will have to survive with this.

The cost/benefit analysis is ridiculously out of balance here. A few people benefit along with a small number of toxic jobs and the local area gets a little over 20k in taxes (insignificant) of this $10 million investment. That's the total "benefit."

There are NO, as in ZERO, benefits to the public that gets all the pollution, has to pay for the busted-up roads (80% of road damage is attributed to trucks), has to pay for the massive upgrades to the county's emergency response, and if anything happens, the public will be on tab for the cost of the county's liability. The miserly taxes collected from the smelter will not even begin to cover these costs. Then, of course, because this is now heavy industry expect a flight from winter visitors, and any local recreational activity will take a hit and there goes the tax revenue from that. Other businesses have stated they will not invest or expand if this smelter is zoned. The crops and livestock now exposed from fallout from dioxin and furans of which there is NO safe level of exposure will not help the local economy in any way. There will also be toxic aluminum pollution emitted from the facility. And then there are the health costs borne purely by the public with no help from the government that creates the toxic nightmare. Smelter towns across Arizona have been decimated health-wise and economically these are some of the most distressed areas in the State. You can buy a toxic house with toxic water in a smelter town for $10k. https://nosmelterhere.com/frequently-asked-questions/

The mortality rates for smelter towns across the country is high. No one's property values will be increased because this smelter moved in.

Once this is designated a national sacrifice zone, then other heavy industries are also going to want to move in to mask each other's toxic effects like they do in Louisiana's Cancer Alley of heavy industry where everyone's to blame and no one is held accountable.

Why this is the wrong location

Emergency response issues:

The facility emergency plan as required by EPCRA is also required by Arizona law, and it is provided to the LEPC, the SERC (State Emergency Response Commission, which is currently housed at ADEQ, but it does NOTHING), and the fire department of jurisdiction. (Wenden volunteer local fire department is not hazmat certified.) It is up to the LEPC to enforce the requirement. Or the SERC, but it doesn't do anything...

The RMP program is a federal law, and the facility would have to report to the EPA. The facility would likely provide it to the ADEQ, as the ADEQ houses the SERC. Sad thing, the RMP program just makes facilities tell EPA what the off-site consequence analysis is -- how far away the chemical released could go and harm people, but it doesn't stop a facility from locating or having these large amounts of chemicals.

According to RMP Comp, the program that computes the off-site consequence of a release, a catastrophic release would have an impact about 25 miles downwind. In the event of no wind at all, a 2-mile diameter bubble would be there. DWAZ was represented on the Maricopa County LEPC for 10 years, and did a table top exercise regarding a large chlorine release from a 90-ton rail car of chlorine, which has a 12-14 mile downwind consequence. There is another chemical spill modeling program, ALOHA, that is used for smaller releases, but it is accurate for only up to six miles. Another feature of the ALOHA modeling program is it can predict the infiltration of gases like chlorine into buildings in the event of a release. The school and the town of Wenden would have just minutes to evacuate, but without a siren alert system and planning, including drills, it is unlikely that anyone would survive. If people sheltered in their homes, it would just be a matter of minutes before the levels of chlorine that would infiltrate into homes would harm or kill people. Chlorine is hard to escape from. It immediately blinds people as their eyes water, and then they choke up, then asphyxiate. The chlorine is corrosive, so phones may not work, and cars may not start or keep running. There are not hazmat suits or breathing apparatus that fit children, either. Concentrations of about 400 ppm of chlorine gas are generally fatal over 30 minutes, and at 1,000 ppm and above, fatality ensues within only a few minutes. Based on the EPA ALOHA model, this facility should not be anywhere near a populated center. http://www.chemicalspill.org/OffSite/aloha.html

Chlorine ALOHA model Small Leak
Chlorine ALOHA model Catastrophic Leak

A DWAZ representative was an investigator in 2005 at the worst chlorine disaster in 20 years at Graniteville, SC, where ten people died. See http://www.chemicalspill.org/railcar.html for that review of the hazmat response. Fortunately, in Graniteville, it was not a catastrophic release of chlorine. The New York State Fire Training Academy had that same DWAZ representative as the keynote speaker due to this post at their next training conference.

No, the volunteer fire department is not trained or equipped for this. They are not haz mat certified, and not equipped. There wouldn't really be anything that anyone could do in the event of a catastrophic release. There wouldn't be a way to evacuate in time or to go in and rescue everyone. They would all likely die a grisly death, quickly.

Your LEPC could be a resource to the community by providing technical assistance and providing "hazard communication."The LEPC is required to update its county emergency plan when a new hazmat facility opens.
Comprehensive emergency response plans (EPCRA). Arizona adopted the federal law into state statutes. A responsible LEPC or your county emergency department, which houses the LEPC, that actually had ANY concern over public health and safety would testify at the zoning hearings and provide the data about the risks. The community is going to learn a lot about the integrity of the La Paz emergency response officials by their action or inaction on this issue.

It is very unusual for a facility with this much chlorine to be anywhere in Arizona. There are two facilities in Maricopa County that bring in 90-ton rail cars of chlorine, which is repackaged into one-ton cylinders and sent back on the rail to other sites. One of them, DPC Enterprises, had an off-loading spill of chlorine, which caused an evacuation and shelter in place response up to three miles downwind. The release of chlorine in that 2003 incident was around 112 pounds. Some wastewater and water treatment facilities utilize them. What is proposed in Wenden is unprecedented. No responsible government entity would ever consider moving such an extraordinary hazard near residents or schools. There is an elementary school 0.75 miles downwind from this facility. There are residents within a third of a mile, downwind.

The Risk Management Program (RMP) was formulated as a result of the 9/11 attacks and concerns about terrorist attacks. This facility would fall under that category. Large chemical storage units are a prime target for causing great harm to communities as a result of a deliberate act. Yet another reason this is the wrong location for this facility.

For more information please check chemicalspill.org, one of DWAZ's websites. It is a resource we put there about 20 years ago.

Flood plain:

The proposed siting of this smelter is next to Centennial Wash in an area that has had multiple "100 year"floods in the past few years. A percentage of this property is on a flood plain and sits at the edge of an alluvial that has had significant subsidence and continues to sink. Because 5-10% of the aluminum product will be waste in the form of aluminum salt cakes, huge amount of this waste will be stored on-site waiting to be shipped out and in a flood event all this goes down the Centennial Wash. Centennial Wash flow direction

Ground subsidence and groundwater issues:
https://nosmelterhere.com/what-can-you-do/

Long term pollution concerns:

Levels that are considered safe for chemical exposure DO NOT account for sensitive populations such as children or the elderly. These levels are based on a healthy 165lb male worker exposed for no more than 8 hours day/ 5 days per week. Persons with compromised immune systems for whatever reason are not accounted for. Imagine a child with asthma in Wenden sleeping under a swamp cooler in the event of a small chlorine leak upwind at the smelter. That person is not accounted for when determining safe exposures. Is there an emergency room nearby to treat such a person when exposed? Answer, NO! http://www.chemicalspill.org/WorkerRTK/hazard.html

Besides the emergency response issues with the extraordinary amounts of chlorine used, DWAZ also has concerns about will be the buildup over the years of dioxins and furans released into the environment. These are some of the most toxic chemicals produced and there are NO safe levels. It is not appropriate to site a smelter in an agricultural community as toxic chemicals consisting of dioxins, furans, and metal particulate pollution can cause contamination in the food chain.
DWAZ air permit comments



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