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1. 12 Should we determine the exceedance of the operational threshold values by using the trends in the monitoring data over several years or the most recent monitoring data In the new Directive impacts of sulphur dust to soils are defined by comparison of soil data from each monitoring event against the operational threshold values in section 3 2 3 1 Considering the dynamic nature of soil acidification the most recent monitoring data should often give a more accurate assessment of the site The trend in monitoring data will help to estimate the rates of soil acidification or where a mitigation plan is implemented the rates of soil recovery Regarding the threshold values for mitigation could Alberta Environment and Water clarify when to use the total sulphur analysis and when to use elemental sulphur analysis Alberta Environment and Water has adopted a set of operational thresholds with multiple parameters in section 3 2 3 of the new Directive All of those parameters must be determined in a Routine Monitoring Program Some baseline soils at our monitoring areas are alkaline If those soils require liming should our plant mitigate the soils to a neutral condition or the alkaline condition Where the soil has an alkaline baseline or background condition and the measured soil pH values in the Routine Monitoring Program still remain above 6 5 the benefits of liming may be outweighed by an adverse effect on the availability of nutrients
2. that a 1 1 soil to water ratio works well with most soils When less water is used vigorous shaking needs to be incorporated into the extraction procedure When too much water is used it may cause formation of emulsions that reduces the recovery rate of elemental sulphur December 2011 Page 5 of 6 Government of Alberta m Directive for Monitoring the Impact of Sulphur Dust on Soils FAQs 17 The new Directive cites both the acetic acid dissolution method and the carbon dioxide weight loss method for the determination of soil carbonates Which method should we use for mineral soils and which for organic soils When mineral soils have a low carbonate content the acetic acid method as modified by Ashworth 1997 works better When mineral soils have a high carbonate content 5 or more the acetic acid dissolution method will no longer be sensitive unless the amount of soil sample 1s markedly reduced Alternatively the carbon dioxide weight loss method can be used For Organic soils follow the carbon dioxide weight loss method because high amounts of organic matter can make the acetic acid dissolution method inaccurate December 2011 Page 6 of 6
3. DIRECTIVE FOR MONITORING THE IMPACT OF SULPHUR DUST ON SOILS FREQUENTLY ASKED QUESTIONS December 2011 Government of Alberta m Government of Alberta m Directive for Monitoring the Impact of Sulphur Dust on Soils FAQs ISBN ISBN 978 0 7785 9621 9 Printed ISBN ISBN 978 0 7785 9622 6 On line Web Site http environment gov ab ca info Directive for Monitoring the Impact of Sulphur Dust on Soils Frequently Asked Questions December 2011 Alberta Environment and Water Any comments questions or suggestions regarding the content of this document may be directed to Alberta Environment and Water 10th Floor Oxbridge Place 9820 106 Street NW Edmonton Alberta T5K 2J6 Fax 780 422 4192 Email land management gov ab ca Additional copies of this document may be obtained by contacting Information Centre Alberta Environment and Water Ath Floor Twin Atria Building 4999 98 Avenue Edmonton Alberta T6B 2X3 Phone 780 427 2700 Fax 780 422 4086 Email env infocent gov ab ca Government of Alberta m Directive for Monitoring the Impact of Sulphur Dust on Soils FAQs INTRODUCTION Purpose of the Directive for Monitoring the Impact of Sulphur Dust on Soils Frequently Asked Questions In December 2011 Alberta Environment and Water released a Directive for Monitoring the Impact of Sulphur Dust on Soils to update and replace the Soil Monitoring Guidelines under its 1989 Air Monitoring Directi
4. ctive but they will need to clarify the reporting requirements with the Director In this case they must choose the new Directive or remain with the 1989 Soil Monitoring Guidelines in their entirety they cannot use both 3 What kinds of industrial operations are required to conduct soil monitoring for the impact of sulphur dust on soils Approval holders that handle solid elemental sulphur and also have the requirements in their approvals to monitor impacts of deposition of sulphur dust to soils must conduct the soil monitoring program Typically these facilities handle and process solid elemental sulphur using blocks base pads prilling towers granulating facilities loading unloading facilities and or store more than 100 tonnes of solid elemental sulphur 4 If our plant only operates liquid elemental sulphur processing facilities do we need to conduct soil monitoring for sulphur dust and its potential impact on soils Usually this is not required Section 2 of the new Directive has granted an exemption to this type of facility provided that any historical impacts to soils by solid elemental sulphur operation have been remediated to appropriate standards Approval holders must follow the terms and conditions in their approvals 5 When should our plant use this Directive or the 2009 Soil Monitoring Directive The Directive for Monitoring the Impact of Sulphur Dust on Soils focuses on lands in the vicinity of plants that handle solid elemen
5. data must be determined for each of the specified depth intervals as outlined in section 2 2 2 2 As measurements of soil bulk density can cause significant disturbance to a sampling location 1t may not need to be measured again in the subsequent soil monitoring and mitigation events unless the site is disturbed by new construction or change in land use 8 Some of our clients have older plants and they did not have baseline soil data prior to the introduction of the 1989 Soil Monitoring Guidelines Can they compare their soil monitoring data against those of the older background locations Yes For some older plants where baseline soil data are not available it is acceptable to use background locations as a surrogate baseline provided that the locations are not affected by plant operations and the soil types are the same as the locations being monitored 9 The new Directive specifies a monitoring frequency of every other year at a minimum Our plant has just established a new operation which handles solid elemental sulphur Can we conduct the Routine Monitoring Program on an annual basis so that we can understand the deposition patterns of sulphur dust faster Yes The plant may conduct annual monitoring as needed but must follow the reporting frequencies in the approval December 2011 Page 3 of 6 Government of Alberta m Directive for Monitoring the Impact of Sulphur Dust on Soils FAQs QUESTIONS ABOUT THE MITIGATION PROGRAM 10 11
6. method does produce distinctly different results with quality control samples of known concentrations the laboratory may use the new method to either a re analyze any stored baseline samples or b analyze suitable background soil samples and use them as a surrogate baseline The 1989 Soil Monitoring Guidelines specifically stated that pH tests for organic soils and forest litter needed to be done at a 10 1 liquid to soil ratio whereas for mineral soils a 2 1 ratio Should we continue to use these ratios Yes The above soil specific ratios have been widely used in determination of soil pH and are cited in the references of the new Directive The new Directive has specified the calcium chloride CaCl method for determination of soil pH can our plant use the water suspension method instead If the water suspension method has been consistently used by an approval holder to determine soil pH in previous monitoring events it should be followed in the future to get comparable data The extraction efficiency for elemental sulphur with the chloroform extraction method by Watkinson et al 1987 in the new Directive appears to be affected by the soil wetting procedure How should our laboratory deal with that problem Published data on soils from New Zealand and United Kingdom indicated that wetting the soil to the moisture range of 0 5 water holding capacity or above the plastic limit gives complete recovery of elemental sulphur Literature suggests
7. tal sulphur It may also extend to selected locations within the boundary of a plant site when the overall pattern of deposition of sulphur dust needs to be assessed Monitoring for the release of sulphur to soils within the plant boundary and releases of other substances to soils in general is otherwise addressed by the Soil Monitoring Directive AENV 2009 as amended under the corresponding approval December 2011 Page 2 of 6 Government of Alberta m Directive for Monitoring the Impact of Sulphur Dust on Soils FAQs QUESTIONS ABOUT MONITORING AND SAMPLING 6 The new Directive indicates that composite soil samples must be used in all monitoring events to address the potential impacts of sulphur dust How should the sampling be carried out in the field A minimum of five separate soil samples must be collected within a five meter radius of a sampling location The depth intervals defined in section 2 2 2 2 of the Directive must be followed The samples must be composited within each depth interval for that location Where it is possible the composite samples should be mixed in the field 7 When determining soil bulk density at each major sampling location should our plant determine the bulk density of all sampling intervals at all five sub locations within a five meter radius of a major sampling location Measurements of soil bulk density at one representative sub location are adequate for the programs in the Directive The bulk density
8. to vegetation Instead the Mitigation Program should focus on source control and protection of other sensitive ecosystem components of the land The proponents should contact the regional staff members of Alberta Environment and Water for site specific solutions If the soil pH is below pH 6 5 for agricultural soil or pH 5 0 for forest soils liming is needed and the targeted pH should be within the optimal range pH 6 0 7 0 for agricultural soils and pH 5 0 6 5 for forest soils for nutrient uptake December 2011 Page 4 of 6 Government of Alberta m Directive for Monitoring the Impact of Sulphur Dust on Soils FAQs QUESTIONS ON ANALYTICAL METHODS 13 14 15 16 The new Directive requires some different analytical methods than the 1989 Soil Monitoring Guidelines Are the facilities with existing monitoring programs required to use the new methods How can we accurately compare results using the old versus new methods The soil analytical methods are normally updated in a 10 year period in scientific communities and improvements are often adopted along the way Laboratory procedures for soil analyses need to be updated to remain relevant and all approval holders are required to use the new methods or equivalent methods that are otherwise authorized by the Director One exception is explained in 15 below It is not anticipated that the updated methods will result in drastically different analytical results If a new laboratory
9. ve The new Directive specifies regulatory requirements and provides guidance for monitoring and mitigation of the impacts of sulphur dust on soils for those sulphur handling and processing facilities whose operational approvals have the foregoing requirements The Directive for Monitoring the Impact of Sulphur Dust on Soils Frequently Asked Questions FAQs serves as a companion document for the new Directive It is intended to be a living document to address operational questions from approval holders or their consultants It may be periodically updated or amended December 2011 Page 1 of 6 Government of Alberta m Directive for Monitoring the Impact of Sulphur Dust on Soils FAQs GENERAL QUESTIONS 1 What is the Directive for Monitoring the Impact of Sulphur Dust on Soils The Directive specifies regulatory requirements and provides guidance for monitoring and mitigation of the impacts of sulphur dust on soils for those sulphur handling and processing facilities whose operational approvals have the foregoing requirements This Directive is an update and replacement of the Soil Monitoring Guidelines under section II C 3 and the Appendix A 7 of Alberta Environment s 1989 Air Monitoring Directive 2 When will the new Directive become effective The new Directive will come into force for relevant approvals when they are amended to include the Directive Prior to any approval amendment the approval holders may voluntarily use the new Dire
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