GREENSTONE GOLD MINES GP INC - Approval for variance from the Liquid Fuels Handling Code

Liquid Fuels Handling Code (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.

Why the Code Would Not be Met

1. An approved nozzle for mining and industrial applications does not exist.

The FloMAX FNBL is a specialized fuel nozzle designed for use in mining and other industrial applications. This nozzle is designed to fill diesel fuel tanks on equipment such as haul trucks, loaders, excavators and other construction equipment. There are several key differences between this nozzle and typical CAN/ULC‐S620-approved nozzles used at retail fuel stations:

• The FNBL nozzle has specifically been designed for and used in the harsh environment typical in mining and heavy construction operations.
• This nozzle has been designed to transfer fuel at higher flow rates (682 LPM) than typical retail nozzles and is required to fill the large fuel tanks found on this construction equipment in a timely manner.
• This nozzle fills the equipment tank through a special receiver fitting on the bottom of the equipment’s fuel tank instead of “splash filling” from the top of the tank:
  • This increases operator safety by moving the filling point to ground level, eliminating the need to use ladders or scaffolds to access the fill point.
  • The nozzle design includes a pressure sensing spring which works with either a pressurized or non‐pressurized tank vent and valve system to shut off the nozzle when the tank is filled.
  • The nozzle and receiver both incorporate a dry‐disconnect design to nearly eliminate any product loss.
  • The nozzle securely attaches to the receiver fitting which prevents the possibility of the nozzle inadvertently becoming disconnected from the equipment tank while filling.
  • The nozzle is designed with an interlock that will not allow fluid to flow unless it is connected to the receiver.

2. An approved 1‐1/2” diameter hose does not exist.

A 1‐1/2” Continental Plicord ExtremeFlex petroleum transfer hose would be used as the diesel fuel dispensing hose, in conjunction with the Flomax 1‐1/2” FNBL nozzle for medium flow dispensing into heavy equipment.

• A ULC‐S612-approved hose larger than 1” is not available from any manufacturers that Fireball Equipment Ltd (Greenstone Gold Mines’ vendor) could find.
• The Flomax FNBL nozzle required to fill the heavy equipment requires a 1‐1/2” hose connection to provide the required fill rates (~400 L/min) for the larger tanks included in this heavy equipment. A 1” hose could not be used with these flow rates. The velocity in a 1” hose would exceed the 7 m/s requirement provided by the NFPA 77 ‐ “Recommended Practice on Static Electricity”.
• The 1‐1/2” Continental Plicord ExtremeFlex petroleum transfer hose has been in service at medium flow diesel dispensing stations installed by Fireball Equipment Ltd on active mine sites for more than 5 years with no reported concerns.

Safety Assessment

1. In a letter dated August 8, 2021, sealed by A.S. Gendre, P.Eng., Gendre confirms that the FloMAX FNBL diesel fuel nozzle meets and exceeds the requirements and safety objectives listed in the CAN/ULC‐S620:2016 – “Standard for hose nozzle valves for flammable and combustible liquids” – and supports the variance.

2. In a letter dated March 1, 2022, sealed by A.S. Gendre, P.Eng., Gendre confirms that the Continental Plicord Extremeflex hose meets the safety objectives of the requirements listed in the ANSI/CAN/UL 330 – “Hose and Hose Assemblies for Dispensing Flammable and Combustible Liquids” – for use in the medium flow diesel dispensing application at the Greenstone Gold Mine site.

TSSA assesses that there is likely to be no environmental impact should these variances be granted.