SUNCOR ENERGY PRODUCTS PARTNERSHIP - Approval for variance from the Liquid Fuels Handling Code

Please note items numbered 1 and 2, respectively, correspond to the numbered items under each subheading.

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

1. 3.2.1.4. Aboveground storage tanks shall be installed, (c) except at marinas, not less than 30 metres from a waterway.

2. 8.2.6. Where tanks, piping, or dispensers of an aboveground storage tank system with an individual tank capacity greater than 5,000 litres have been removed or replaced and the property continues to maintain fuel storage equipment or tank systems, the owner or operator of the facility, the owner or operator of the storage tank systems, or the owner of the property on which the equipment is installed, as the case may be, shall submit an assessment report to TSSA that delineates the full extent of any petroleum product that has escaped from the tanks, piping, and dispensers, into the environment or inside a building both on site and, where necessary and practical, off site.

Reasons Why Code Would Not Be Met:

1. The new TK-01 tank will be located at the same location as the previous TK-01 to maximize the utilization of the existing infrastructure. This in turn will minimize the disturbances caused by construction to the site (which is an active and operating facility).

• The foundation for the previous TK-01 can be built up to accommodate the new larger size tank without constructing new. (This greatly reduces the extent of earth work and excavation, which is a major consideration since the tank is located within an existing active and operating tank farm.)
• Facility/Equipment sizing (i.e. pipes, pumps) will remain as is. Existing piping and pumps can be re-used without modifications.
• Inlet and outlet piping are existing and can be re-connected and re-used for the new tank.
• Associated steel support structures (for piping, cables/cable tray) are existing and can be re-used.

2. The new TK-01 will be located within an engineered containment dike that continues to be in use following the removal of the aboveground storage tanks (TK-01, TK-03, and TK-04). Soil sample collections will involve excavation which will compromise the integrity of the tank farm. To maintain the integrity of the dike, Suncor would prefer not to submit an environmental report, which requires soil sample collections.
    

Safety Issues Addressed by Code:

1. Provides a buffer zone to capture any leaks/spills before they enter the waterway.
2. Identifies and remediates any contamination that may have leaked from the tanks.

Equivalent Safety Methods to Mitigate Abovementioned Issues:

1. Distance from the River:

• TK-1 will have a bottom leak detection system (i.e. a drainpipe will run from under the tank floor to a leak detection well).

• The tank will be located within a clay dike that has a permeability of 5 x 10^-9 cm/s (which exceeds the 10^-6 cm/s impermeability requirement of the LFHC) and has an available containment capacity (27ML) that is more than 1.5 times the LFHC required containment capacity (16ML).

• In addition to the clay dike, TK-1 will have an additional liner (Enviro liner 6040 by Layfield) on the underside of the tank which will provide tertiary containment.

• In addition to the independent overfill protection device specified by the LFHC, the new TK-01 will have an additional continuous automatic level monitoring system which provides real-time level readings in the tank and informs Operations of any abnormalities.

• Suncor has adopted the disciplined approach of American Petroleum Institute (API) Standard 2350 for Overfill Protection for Storage Tanks in Petroleum Facilities. Suncor’s Corporate practice for overfill prevention in Distribution Terminals is highly conservative and involves multiple layers of alarms/warnings and manual/automated corrective actions before reaching the overfill condition.

• The proposed tank TK-1 will exceed the design requirements of API 650 (the standard that covers the minimum requirements for design, manufacture, installation, materials and inspection of aboveground vertical cylindrical tanks, without refrigeration, with open or closed roof, built with welded steel plates):

• • Suncor specified higher-quality steel plates.
  • Tank bottom and shell plates were specified with greater thickness than required by API.
  • Shell vertical joints are seamless, full penetration welds which result in stronger welds and overall better structural integrity.
  • Welding electrodes specified by Suncor on bottom joints provide stronger welds and higher resistance to corrosion and environmental factors.
  • Suncor specified higher corrosion allowance on all internal shell, bottom and wetted structural components.
  • Suncor specified design-specific gravity of the liquid stored shall be minimum 1.0 (equivalent to water), and the design liquid level higher than the API requirement. This translates to a more robust tank structure than a typical API tank.

• The tank side sampling system is equipped with self-closing valves with spring return handles (deadman valve). This feature ensures no escape of tank contents during sampling operations.

• Leak detection program – Suncor’s Terminal Operations department performs monthly visual monitoring of the surface of the groundwater in each of the leak detection groundwater monitoring wells, within the tank farm, for the presence of floating, free-phase hydrocarbon or sheen. In addition, there is semi-annual groundwater monitoring and annual groundwater sampling by a certified environmental consultant. Both programs are intended to provide early warning/indication of a potential breach. These programs allow Suncor to take corrective action to remove/eliminate the concern in advance of a potential failure.

2. No Environmental Report

• Semi-Annual Monitoring and Annual Sampling Program

There is an environmental groundwater monitoring and management program for the Thunder Bay Terminal. This program involves semi-annual groundwater monitoring and annual groundwater sampling by a certified environmental consultant, which includes headspace vapour concentration readings, water level measurement and determination of liquid-phase petroleum hydrocarbon detection.

As part of the Thunder Bay Terminal environmental groundwater monitoring and management program, there are numerous groundwater monitoring wells located within the Terminal property. Suncor has identified three (3) monitoring wells that are relevant to this Variance application.

• One (1) monitoring well (BH7) is located between TK-01 and TK-02, inside the tank farm.
• One (1) monitoring well (BH5) is located south-east of TK-04, outside the tank farm, along the shoreline.
• One (1) monitoring well (BH6) is located south-east of TK-01, outside the tank farm, along the shoreline.

The 2020 Groundwater Sampling Report prepared by TERRAPEX Environmental, dated October 30, 2020, shows that the benzene, toluene, ethylbenzene and xylene (BTEX) and petroleum hydrocarbon (PHC) fractions’ F1-F4 levels fall within the Ministry of the Environment, Conservation and Parks (MECP) Table 9 Site Condition (Generic Site Condition Standards for Use within 30 metres of a Water Body in a Non-Potable Groundwater Condition). There are no impacts in the groundwater samples collected from the monitoring wells.

• Leak Detection Program

A leak detection program is in place at the Thunder Bay Terminal where Terminal Operations perform monthly visual surveying / monitoring of the surface of the groundwater in each of the leak detection groundwater monitoring wells, within the tank farm, for the presence of floating, free-phase hydrocarbon or sheen, using a dedicated clear bailer. In addition, Terminal Operations also conduct visual inspection of the monitoring wells to assess their condition and potential need for repairs/upgrades.

• Tank Floor Condition of Demolished Tanks

TK-01, 03, 04 were emptied, cleaned, and removed from service permanently on the following dates:

• TK-01: out of service since September 13, 2005
• TK-03: out of service since September 28, 2019
• TK-04: out of service since September 28, 2006

The tanks were never returned to service from the above dates and were demolished in October 2019.

TK-01, 03, 04 all had internal epoxy coating applied on the tank floor, which provided additional corrosion protection.

The final API 653 (the standard that covers the inspection, repair, alteration, and reconstruction of steel aboveground storage tanks used in the petroleum and chemical industries) out-of-service inspection report for each tank detailing the floor condition of each tank was summarized in Attachment 7. It was evident from the inspection reports that no tank contents had escaped TK-01, 03 and 04, as the floor, shell, and welds were all intact. Despite the age of the tanks, no through-holes developed from internal and/or external corrosion factors.

In addition to the inspection records of the tanks, there were no reported leaks or spills from TK-01, 03 and 04 known to Suncor.