VALE CANADA LIMITED - Approval for variance from the Liquid Fuels Handling Code

Vale Canada has a project underway to install a new fuel management system to monitor its fuel consumption. Potential system features include:

• cardlock/keylocks at each site
• upgrades to the existing level controls
• complete storage tank replacements, if necessary
   
  This proposed fuel management system is currently out to tender for a design-build solution. The final vendor decision may not be determined until October 2020. As such, Vale would like to wait until the vendor and project details are confirmed, before making any fuel management system changes.

Current fuel management system deficiencies at the sites—along with their respective mitigation methods—are as follows:

• All six sites have fuel hoses that are not certified by the Underwriters’ Laboratories of Canada (ULC). Clause 1.3.1 of the Liquid Fuels Handling Code (LFHC) requires that equipment be approved for use.
  • Mitigation method: Vale Canada will replace all the hoses with ULC-approved hoses by December 31, 2020, regardless of the final specifications for its new fuel management system.

• Five sites (excluding 117 Coleman Mine Rd) do not have pressure relief for the piping. Clause 4.1.8 of the LFHC requires that piping have pressure relief.
  • Mitigation method: Periodic inspection of the tank systems in accordance with LFHC Section 7 (Table 4).

• One site (487 Power St) has an emergency vent that is less than six inches above the spill container. Clause 4.3.2.4 of the LFHC requires that emergency vents be at least six inches above the spill container.
  • Mitigation method: A new storage tank facility is being constructed at this site.  Therefore, the deficient tank will be out of service by June 2021.

• One site (1702 Godfrey Drive) has a spill container that has a drilled hole plugged with washers, bolts and silicone.
  • A new approved spill container will be installed, in accordance with clause 1.3.1 of the LFHC, when the facility is upgraded.

Some locations have a horizontal tank in a dike, while others have a double-wall aboveground storage tank. To further mitigate the abovementioned deficiencies, Vale Canada will continue periodic monitoring of the tank systems, in accordance with LFHC Section 7 (Table 4). In addition, the horizontal and the double-wall tanks at each site will be subject to weekly visual inspections performed by a certificate holder and monthly inspections by a petroleum mechanic.