Read our most recent letter below, sent out to Transportation and Infrastructure Minister Claire Trevena, as well as other government officials. Fire at the tank farm poses a particular hazard. Excerpts from a report written by Deputy Fire Chief Chris Bowcock of the City of Burnaby Fire Department, entitled “Trans Mountain Tank Farm Tactical Risk Analysis May 01, 2015” summarizes the magnitude of a fire and risks of the expansion at this facility are included in our letter.
Danger Associated with a Burnaby Mountain Trans Mountain Tank Farm Expansion
We are writing on behalf of the Concerned Professional Engineers (CPE), a group of registered Professional Engineers that has been analyzing the risks of major infrastructure projects in British Columbia since 2012. We wish to express our concern that Kinder Morgan and the Federal and Provincial Governments have not done a proper risk assessment when reviewing the Trans Mountain Expansion Project (TMEP) proposing an expansion of the pipeline and the tank farm on the south side of Burnaby Mountain.
As registered Professional Engineers, CPE derives its mandate from the Code of Ethics of our Association of Professional Engineers and Geoscientists of BC (APEGBC). This code states, in part,
“…members and licensees shall… hold paramount the safety, health and welfare of the public, the protection of the environment and promote health and safety within the workplace”
To date, we have primarily focused on the marine shipping aspects of the Trans Mountain Expansion Project. For a quick overview, the 2-minute video on the home page of CPE website provides a brief summary of our concerns about the potential catastrophe should a tanker inbound in ballast or loaded outbound, collide with the Second Narrows highway and/or the railway bridges.
The shipping of oil risk comes down to location. The Eastern Burrard Inlet is the riskiest of all ports studied in 1987 by the Federal Ministries of Environment and Fisheries. If a tank farm was to be built in the lower mainland, a far safer location would be to build the tank farm and terminal at Roberts Bank.
We also have a link on our web site to a graphic 10-minute video by Bob Bossin of Gabriola B.C., where he addresses the issue of the proposed expansion of the Trans Mountain Tank Farm (TMTF) on Burnaby Mountain.
A well researched report by Deputy Fire Chief Chris Bowcock of the City of Burnaby Fire Department, entitled “Trans Mountain Tank Farm Tactical Risk Analysis May 01, 2015” summarizes the magnitude of a fire and risks of the expansion at this facility. These risks include firefighters and a large number of the public in adjacent areas.
A tank fire event could easily develop into a situation involving the evacuation of thousands of people in a worst-case scenario.
To provide context for our concerns, we have included some pertinent paragraphs from the Trans Mountain Tank Farm Tactical Risk Analysis May 01, 2015, Deputy Chief Bowcock’s report;
Tank Farm Layout and Density Increases Risk
“On 16 December 2013, Kinder Morgan submitted an application to the National Energy Board (NEB) for the expansion of the Trans Mountain Pipeline system, which includes the expansion of the Burnaby Mountain terminal. The expansion involves the densification of storage tanks within the existing foot print of the site from 13 to 26 tanks – a tripling of the subject terminal’s storage capacity from 1.7 million barrels to 5.6 million barrels.”
“The decreased tank spacing within the tank farm has additional significant consequences. Many of the potential tank fire scenarios within the Trans Mountain Tank Farm facility would be inextinguishable due to lack of safe firefighting positions. The general configuration proposed by Kinder Morgan provides insufficient safe access routes and operating positions from which firefighters could apply protective streams to isolate or extinguish fire events.”
“Fires occurring in this tank farm will have a potential to be severe in magnitude. Inherent in the layout of this tank farm is the potential of a fire event occurring in such close proximity to adjacent tanks, that subsequent ignition of additional storage tanks is a dangerous reality. A significant emergency management concern in a facility of this type is the escalation from a single tank fire to a multiple tank fire event. The resource requirements and the excessive complexity and risk to emergency responders, typically prevents safe firefighting of a multiple tank fire event.”
Tank Fire Burnout
“Tank fire Burnout has historically been utilized as a contingency option for fire extinguishment when adverse environmental conditions exist, a lack of firefighting resources exist or when the facility design precludes safe offensive firefighting operations. Therefore the use of a Tank Burnout tactic exposes the community to the full potential impact and duration of toxic smoke and heat discharge based upon the volume of crude oil present at the time of ignition.
The operations associated with evacuating persons potentially impacted by a 4 day tank fire event from a facility with such tight proximity to high density residential communities would constitute an emergency activation of provincial scale.”
Tank Fire Boilover
“The potential for Boilover exists in any wide boiling range hydrocarbon, such as a crude oil storage tank full surface fire. For a proposed 200’ storage tank, a Boilover event can discharge heated and molten crude oil outwards to 2,000’. A Boilover event occurring from a Tank Fire in the TMTF, would result in large area life hazard and the potential for propagation of additional storage tank fires due to the mass discharge of molten crude oil over areas encompassing;
- The entire TMTF
- The Shellmont Tank Farm
- Forest Grove Community
- Meadowood Community
- Sperling-Duthie Community
- Closing Gaglardi Way and Burnaby Mountain Parkway”
Reader’s who wish to increase their knowledge and detail of tank fire layout and density, fire burnout and fire boilover, additional to this summary are directed to access Deputy Fire Chief Chris Bowcock’s excellent report at following link, with special attention to page 59 and 60;
Toxic Smoke Discharge
“In Kinder Morgan Canada Risk Assessment Trans Mountain Expansion Project – Burnaby Terminal Project, October 1, 2013, Doug McCutcheon and Associates Consulting, wrote; “A toxic impact up to 5.2 km downwind due to SO2 created in a fire and smoke impacts as far out as 43 km”
“Kinder Morgan Canada (KMC) has stated it is expecting a time frame of toxic smoke discharge prior to possible extinguishment of 1 – 2 days. It is expected that the 1 -2 day burn time would generate sufficient toxic smoke plume discharge to significantly affect the entire Greater Vancouver Regional District, with specifically high concentrations of exposure and respiratory health hazards to all Burnaby, Port Moody, Coquitlam, and New Westminster residents at risk with pre-existing respiratory conditions.”
Highly toxic Hydrogen Sulfide will very quickly, upon facility release, expose residential areas to conditions that are immediately dangerous to life.
• Irritation of eyes, nose, throat and respiratory system
• Breathing difficulties in Asthmatics
• Coughing, difficulty breathing, headache, dizziness, nausea, vomiting, staggering and excitability
• Shock, convulsions, inability to breathe, extremely rapid unconsciousness, coma and death
Kinder Morgan’s Emergency Response Limitations
“The detail not present in KMC’s answer to … (partial quotation)… within the existing emergency management programs at Kinder Morgan Tank Farm, KMC has no immediate emergency communication plans, protocols or procedures to notify the community at the first identification of hazard to the community.”
“As the authority having jurisdiction for fire protection approval within the City of Burnaby, the Burnaby Fire Department has recently been advised by KMC on May 30, 2014, that the facility no longer has the emergency response ability to extinguish fire events with internal facility resources, and that additional hydrocarbon specialized firefighting resources from regional facilities are no longer available.”
We believe that Deputy Fire Chief Chris Bowcock summarized his concerns well, when he wrote:
“These factors pose significant risks to lives and property arising from the densifications of petroleum products on a sub-standard, ill-configured and under sized property located in proximity to urban residential and other populations.”
Dr. Ivan Vince, CEng. FIChemeE, of ASK Consultants, Bromley, U.K.
A paper written for the City of Burnaby by Dr. Ivan Vince, May 22, 2015, strongly rejects the Burnaby Mountain Tank Farm expansion plans by Kinder Morgan.
Dr. Vince levels several criticisms of the risk assessment performed by Doug McCutcheon and Associates Consulting submitted by Kinder Morgan including the following;
3.2.2 “contains several shortcomings and errors, of which the most important is the gross underestimate of the risk of boilover.”
3.2.6 “For the Burnaby tank farm, in my opinion, the risk is dominated by tank boilover, since this scenario has by far the most severe and most extensive potential consequences and, though relatively infrequent, is wholly credible (has a far from negligible likelihood of realization)“
3.3.7 “Radiant heat from the fireball as well as the rainout of burning oil would be capable of igniting litter in the surrounding forest and a variety of exposed combustible materials on and around houses. If an uncontrolled forest fire is a credible scenario, then evacuation of Simon Fraser University would be problematic, since both access roads pass very near to the tank farm and might be impassable during the incident.”
3.2.12 “A review of incidents world wide by the Swedish National Testing and Research Institute supports the LASTFIRE finding that full surface fires are likely to escalate; Of 22 full surface fires (out of 104 fires recorded),16 went on to produce boilover.”
Diluted Bitumen (Dilbit)
The final issue we wanted to address was our concern that Kinder Morgan and the Federal and Provincial Governments appear to have disregarded or ignored the issue that Kinder Morgan according to market requirements, propose to ship either crude oil or diluted bitumen (Dilbit) through the expanded pipeline.
Unlike conventional crude oil, Dilbit is a mixture, often heavier than water, of unrefined Bitumen and a diluent. This diluent is usually a cocktail of volatile solvents like naptha or natural gas condensate that allows the thick Bitumen to be pumped through pipelines. These light hydrocarbons are toxic and highly flammable.
A spill in the Kalamazoo River, Michigan in July, 2010 of Diluted Bitumen, from Alberta oil sands, off-gassed portions of volatile diluent containing fumes of benzene and toluene in the spill area. Nearly 60 percent of the local population experienced symptoms such as nausea, dizziness, headaches, coughing and fatigue. Clean up crews were issued respirators to protect them from toxic fumes.
We believe that Kinder Morgan and the Federal and Provincial Governments must be held accountable for proposing and/or approving this expansion without a detailed risk assessment that addresses the concerns referenced. We believe the risk to firefighters, the public and surrounding areas is extremely high and we are asking everyone for their support in opposing the expansion of the Burnaby Mountain Tank Farm.
Brian Gunn, P. Eng.
Spokesperson for CPE (firstname.lastname@example.org)
Peter S, Hatfield, P. Eng.
Member of CPE (email@example.com)