BVD HOLDINGS COCHRANE INC - Approval for variance from the Liquid Fuels Handling Code

Liquid Fuels Handling Code (LFHC) Requirements that Would Not be Met:

3.5.2.  Tanks and tank compartments shall have a maximum individual capacity of 80,000 L and a maximum aggregate capacity of 200,000 L.

Note: This Clause does not apply to cardlocks/keylocks located at bulk plants.

Why the Code Would Not be Met

Clause 3.5.2 of the Liquid Fuels Handling code limits the aggregate capacity for aboveground tanks to 200,000 L. However, in the past years the site run out of fuel causing backup on highway transport. To avoid this issue and to ensure adequate fuel supply the facility capacity needs to be increased. The facility is located in the Northern Ontario with limited options for fuelling in the area.

Safety Assessment

1. Tank overfills are a leading cause of spills associated with aboveground fuel storage tanks. To prevent this, all tanks will be equipped with three stages of overfill prevention.
   1. Stage 1 – high level warning alarm / light which will signal the delivery driver that a specific tank is reaching “Full” status. This warning will be triggered by the tank level monitor, sounding a warning buzzer and illuminating a warning light at the offload pump control panel adjacent to the offload pumps. This alarm will be initiated when the tank is approximately 90% full, allowing the driver to verify progress and safely complete offloading.
2. Stage 2 – cUL approved mechanical overfill prevention valve installed in the tank fill connection to stop fuel transfer into the tank at 95% in accordance with LFHC 2017.
3. Stage 3 – critical high level alarm light and shutdown of any offloading pump associated with the tank which is being (over)filled. This approach will safeguard against any loss of product due to overfills.
4. The storage tank facility will be fully enclosed by a 6 ft tall chain link fence with lockable access gates and privacy slats. This fencing will prevent unauthorized persons from accessing the tanks and associated piping.
5. The storage tank facility area will be equipped with automatic pole mounted yard lighting for visibility and safety.
6. Traffic protection will be installed around the tank area perimeter to provide protection from vehicle damage.
7. The existing Cardlock operation is equipped with an oil water separator to capture and process any fuel spillage. This provides additional containment in the unlikely event of a tank area fuel spill.
8. The storage tank facility will be approximately 60 meters from the nearest building and 45 meters from the closest public roadway.
9. The facility will be equipped with 4 emergency stop devices (ESD). The activation of    any ESD which will stop ALL fuel pumping and dispensing operations. ESD’s will be situated at Cardlock, Point of Sale, Building Exterior, and Tank Farm / Offloading area.

TSSA assesses that there is likely to be no environmental impact should this variance be granted.