RING OF FIRE METALS PTY LTD. - Approval for variance from the Liquid Fuels Handling Code

RING OF FIRE METALS is requesting the following variances for its temporary (10 years) fuel facility located at a Northern Ontario mining site on a rocky, uneven terrain where digging is not possible:

1. To use (an) unapproved:
   1. Collapsible fabric tanks: “Arctic King Series” – a total of three tanks, each with 76,000-litre capacity (one will contain jet fuel, which is not under TSSA’s jurisdiction) [contrary to Liquid Fuels Handling Code (LFHC) 1.3.1 & 3.1.1]
   2. Secondary containment liner: “Insta-Berm” (contrary to LFHC 1.3.1)
   3. Flexible hose: “New Line NL-3280 Low-Temp Artic Multi-Purpose” (contrary to LFHC 1.3.1)
   4. Containment sumps under dispenser - “Mini-Berms” trays or similar portable spill containment devices (contrary to LFHC 1.3.1 & 4.6.7)
   5. Dispenser pump (contrary to LFHC 1.3.1)
2. Not to use an anti-siphon/automatic valve (contrary to LFHC 4.1.5)
3. To use a flexible hose with a melting temperature less than 538 °C for an aboveground piping system (contrary to LFHC 4.4.1)
4. Not to use a shear valve (contrary to LFHC 4.6.3)

Please note that the items numbered and lettered above, respectively, correspond to the items numbered and lettered under each subheading.

Proposal Details

LFHC Requirements that Would Not be Met:

1.3.1.

Equipment installed at a facility or on a highway tank shall be approved and installed in accordance with the requirements of this Code and the manufacturer’s instructions, and shall be appropriate for the service for which it is intended.

3.1.1.

Only aboveground storage tanks certified in accordance with an approved Standard shall be installed.

4.1.5.

Aboveground fuel storage tanks, including those located in dikes, require the following valve or valves, located as close to the tank as possible:

(a) where the fuel piping connection on the tank is located below the stored liquid level in the tank, a normally open, fire-safe valve that will automatically close when exposed to a fire condition; and

(b) where the fuel piping run extends below the stored liquid level in the tank, an anti-siphon valve or method that will automatically prevent siphoning of the fuel from the tank should a leak occur in the piping.

Note: A commonly used, acceptable method would be a normally closed solenoid valve that only opens when there is a demand for fuel flow in the pipeline.

4.4.1.

Aboveground piping and components shall be non-combustible and shall have a minimum melting temperature of 538 oC (1000oF).

4.6.3.

Where dispensing equipment is installed on an island or support structure, it shall be securely fastened, and an approved shear valve, installed in accordance with the manufacturer’s installation instructions, shall be installed beneath the dispensing equipment.

4.6.7.

Approved containment sumps shall be provided under the dispensers.

Why the Code Would Not be Met

This temporary fuel facility, which is only intended to operate for 10 years, is located on a rocky terrain where digging is not possible. Since this is a mining site, it requires specialized equipment.

1. 1. The location does not allow for the installation of approved steel tanks. Approved steel tanks must be installed on a level concrete pad, which is impossible in a remote area on a rocky, uneven terrain.
   2. An approved liner for this application does not exist due to a lack of certification services by Underwriters Laboratories of Canada (ULC).
   3. An approved hose for this application does not exist (the approved size is limited to 1 inch, while the required size is 1.5 inches).
   4. Approved containment sumps are not suitable for this application. The approved sumps are designed for permanent retail facilities and installed underground, which is not possible in this case.
   5. Approved dispenser pumps are not suitable for this application. The approved dispenser pumps are designed for permanent retail facilities where sumps are installed underground and attached to the dispenser on a concrete island, which is not possible in this case.
2. Anti-siphon valves are designed to mount on the top of a rigid tank, but the facility will be using collapsible fabric tanks which are not compatible with anti-siphon valves.
3. The rigid steel piping that meets the Code’s required melting temperature does not accommodate the movement of collapsible fabric tanks, which require flexibility and portability.
4. Shear valve installation is designed for standard dispensers only. The dispensers at this gas station will not be standard and therefore will not be compatible with a shear valve.

Safety Assessment

1. 1. The tanks will be designed, constructed, and operated in accordance with the Canadian Standards Association (CAN/CSA) B837-14 “Collapsible Fabric Storage Tanks (Bladders)” standard.
   2. “Insta-Berm” secondary containment liners are compliant with the ULC-S668 standard.
   3. A professional engineer (P. Eng.) has stamped a letter stating that the proposed flexible hose is suitable for the intended application.
   4. The size and capacity of each “Mini-Berm” tray (or similar portable spill containment device) will be dependent on the location where it is deployed.
   5. Dispenser pump electrical equipment is CSA approved for hazardous locations (Class, Div I, Group D), and the wiring is in accordance with Section 18 of the Canadian Electrical Code (CEC) for hazardous locations.
2. Monitoring procedures in the form of daily inspections will be performed to identify any leaks (e.g., breaks in the lines). Procedures will also be in place to ensure valves are locked when not in use.
3. A Fire Safety Plan will be implemented to address fire prevention, evacuation, and emergency response. Emergency procedures outlined in O. Reg. 217/01 will be followed. Employees will be trained in emergency procedures, and all procedures will be documented and readily available in the fuel tank area and other identified locations within the camp.
4. The dispensing hose will be fitted with a breakaway connector (used to prevent stretching or breaking), and the nozzles will be without trigger latches [nozzles without trigger latches require constant attendance (pressing release) so a spill is prevented].

In addition, to minimize or eliminate risks to employees and the natural environment, the following mitigations will be implemented on site:

• • Fire resistant secondary containment
  • Setback distances
  • Fencing
  • Reduced vehicular traffic
  • Training
  • Signage
  • Fire suppression

TSSA assesses that there is likely to be no environmental impact should these variances be granted. TSSA has approved similar variances in the past (e.g., SR 1062934 & SR 1304264).