This letter from Neal Littman was also featured in The Compass News 360:
Sulfur plant hits bump
Posted Thursday, 7/21/2011

To All,

PCS thought this project was wired in advance with “key players”.  PCS was good at making this project sound like an extension of their existing operations.  It is NOT.  It is a chemical processing facility new to North Carolina.  It smells bad.  There are serious health hazards.  It is ugly and will have smokestacks towering twice the height of the high rise bridge.  How is this good for Carteret County?

When they approached us (Morehead City Yacht Basin) several months ago it was to seek approval for extension of their barge berth on Calico Creek “to improve material handling capacity related to their phosphate business…”  We tried to assist PCS in their expansion by discussing the channel limitations and the need to get input from the US Army due to their 175 foot vessels with greater beam than our pleasure boats.  We met with the US Army officials, they got the US Army Corps of Engineers involved and we came to a mutual agreement as to the extent of the additional dredging that was needed.  At no point during this phase of conversation did PCS mention that they really wanted to construct an industrial chemical facility immediately adjacent toMorehead City Yacht Basin.  We found that out when we received on Friday, July 1st (the start of the July 4th weekend) a very cryptic notice regarding a PCS Phosphate application for modification of an existing CAMA permit.  It was impossible to tell from the notice what the scope of the proposed project would be.  I contacted the PCS Phosphate Senior Scientist to request a copy of the Environmental Assessment, as is our right.  He emailed a copy to me.  It was only then that I understood that PCS and the State Port were proposing a new industrial chemical factory.  We had subsequent conversations with their Senior Scientist and the PCS Director of Environmental Compliance.  Jet Matthews and I were on a conference call with the PCS officials and we learned that this process was new to PCS and new to the region and no, PCS had never operated any similar facility, but that they did have experience handling molten sulfur here at the State Port and at Aurora, NC.

Molten sulfur is a different form of sulfur than what they are proposing to process.  PCS wants to purchase sulfur in its dry form and have it transported to the MC State Port in bulk cargo ships (much cheaper than buying the molten sulfur, which is commonly a by product of refining petroleum) and then convert it to its molten state. This “phase change” or change in the state of the element sulfur is what creates value for PCS.  For PCS, the minimum net operating profit per ton for changing the form of sulfur from the dry state into the molten state is about $120 and may be as high as $600 per ton. Since they are building sulfur melters with a daily capacity of 5,000 tons, this gives them a potential net operating income of $600,000 per day on the low side and up to $3,000,000 per day one the upper end. This is before amortizing the cost of the chemical factory, but that can be done with a small part of the income stream generated by the sulfur chemical plant.  Serious value is created by changing the state of the material. PCS will not easily give up that money.  Just do a Google search for “cost of sulfur” and you will gain greater understanding about the economic incentives for PCS. They are considerable.  What does Carteret County get?  Nothing… Actually, worse than nothing.  Bad smells, pollution, a considerable reduction in the tax base due to much lower property values.

Sulfur dust in its dry form is explosive.  They will be moving it around the State Port on conveyor belts.  At each “transfer point” PCS says it will provide dust control by wetting down the dry sulfur so that the dust does not build up and become explosive. Sulfur dust will be generated by every movement of the pelletized material throughout the State Port.  The conveyor system cannot be made “air tight” as it has to allow for the venting of the hydrogen sulfide and sulfur dioxide gases that are naturally formed when sulfur is in contact with oxygen.  Great.  Some of the sulfur smells escape to the atmosphere, no matter what they do.  Some sulfuric acid is formed, no matter what they do.  PCS has considerable experience with accidents causing explosions and fires from sulfur dust.  Numerous examples exist at Aurora of fires caused by train wheel contact with rails that have a dusting of sulfur…  The worst industrial accident in North Carolina in the last century was caused by dust at the West Pharmaceuticals factory in Kinston.  Similarly, Georgia’s worst industrial accident was caused by dust in a sugar refining facility.  A lot of dust will escape from the State Port.  It is much finer than the dust from the wood chip operation at the State Port and we have to deal with that debris every day in Eastern Morehead City.  It is a danger.  How does the State Port plan to prevent explosive dust from detonating the PETN explosives that the State Port periodically has present… and has spilled?  How can the State Portsegregate the fire hazards of the chemical factory and the wood chip operation?  Does anybody at the State Port have a clue about protecting the neighbors and the larger community? We see no evidence of that in practice on a daily basis.

Air quality is addressed by trying to get this project in place before the US EPA implementation of much more restrictive sulfur rules (which become effective on 1/1/2013) and by gaming how the airborne pollutants are measured.  To achieve the even the lower standards now required, PCS design engineers measure the air concentration of pollutants at ground level at the fence line or boundary of the property and they discharge the airborne pollutants from the top of a smokestack that is 150 feet high!  The Morehead City-Beaufort High Rise Bridge is only about 75 feet high!  The PCS workers will all have to wear an electronic sniffer or chemical sensor that sounds an alarm if it detects the presence of hydrogen sulfide gas (which can very quickly kill a worker).  We have people sleeping on boats less than 150 feet from the boundary of the proposed industrial chemical factory.  They don’t have sniffers.  In the PCS plan, no one outside the boundary of the property counts.  Tough.  You had your chance to object.  One of the more ludicrous aspects of the “scrubber and air filtration equipment to reduce air pollution is that the design standards call for meeting the discharge criteria for reducing harmful discharges beginning three hours after the start up of the chemical factory and end three hours before the factory shutdown.  If the system is started and stopped once each day it means that for six hours of the operation PCS can legally exceed the permit discharge limits.  The same air quality official who approved the PCS air quality permit for NC DENR told us that the State Port has in operation a very effective dust supression system for the wood chip operation, including sparyers, containment and more.  We looked out the window and let him know that it was not operating today, yesterday, last week or last month and that he should come look at it.  He mumbled something about not having travel money.  We perhaps could relocate his desk to the boundary of the State Port property…  Remember, you can smell this PCS sulfur in concentrations about 1/20th of the maximum allowable concentration they now have under the terms of the air quality permit already granted.

“This project is a great economic boon for the area and PCS is going to spend $80 million, no $85 million no, $90 million on this project.” The facts are:
(a) that the vast majority of that money flows to suppliers of specialty items and contractors from far outside Carteret County;
(b) that PCS does not pay any taxes at all to Morehead City or Carteret County (never has and will not in the future).  You see, the State Port just leases the property to PCS and PCS pays “fees” to the State Port and as a State Agency the State Port pays no taxes.  Local governments just have to provide emergency services, water and sewer and the rest of the taxpayers absorb the cost; and
(c) very few additional employees are needed to operate the facility.  Our one business will lose more employees and contractors and vendors than PCS will be hiring due to people relocating their boats to more pleasant communities.  It is easy to untie the docklines and sail away. What about all of the other businesses in the community?
(d) If this industrial chemical project is finally approved, property values in the community will plummet and vibrant downtown business will be a thing of the past.  Even if the value of the PCS project was $200 million and they were going to spend half of it here in Carteret County, it would be a small fraction of the cumulative damage to the value of property in our communities.  It adds nothing to and instead will take away a great deal of money from the tax base.  We have already begun seeing people put their plans on hold!  Please tell us how this particular “economic development project” is in any way a good thing for Carteret County!

The important elements of this proposed project are:
1.  There would be significant discharges to the air of sulfur dust, the gaseous forms of sulfur dioxide and hydrogen sulfide and lesser discharges of other toxic and non toxic gases.  Significant quantities of sufuric acid are produced in this planned industrial chemical plant which will end up in the waters of our area after being airborne and causing significant increased corrosion rates, injury to flora and fauna as well as terribly complicating respiratory problems in humans.

2.  The quantities of gases that PCS says they will discharge is interpreted by humans as a very nasty smell.  It really is the smell of rotten eggs and worse.  Noxious smells have the worst possible effect on tourism, property values and quality of life.  No other factor even comes close in industrial communities.

3.  There is a considerable net loss of jobs, not a net gain due to the harmful effects of the chemical factory.  PCS has never before done this chemical process and cannot cite a single similar facility where this same method is used.  They claim it is safe though.  They have had accidents before and no mechanical system works all of the time.  The last major PCS accident at the State Port was when their ship crashed into the railroad bridge in theMorehead City turning basin.  The railroad bridge was out of commission for many weeks.  The probabilities of an accident are quite high given the dangers involved.  PCS has exactly zero experience operating this type of facility!

4.  Our area depends on good water and air quality.  We will lose that.  For what?  This PCS chemical factory is not economic development, it is an economic and ecological disaster for Carteret County.

When was the last time Beaufort and Morehead City had unanimous votes about anything?  They have about this very stinky project.  It is smelly, both literally and figuratively and is very close to final approval!

We have to keep trying to get people to read and understand what PCS itself has to say about its own design in the plans and environmental assessment.

Again, please let me know why this is a good idea!

Thanks,

neal
Neal Littman, General Manager
Morehead City Yacht Basin
252-659-2615 cell
252-726-6862 ofc