LAFARGE CANADA INC. - Approval for variance from the Liquid Fuels Handling Code

Please note items numbered 1 and 2, respectively, correspond to the numbered items above in the Proposal Summary.

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

1. 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.

2. 5.6.1.10. All bulk plants shall be designed with an oil/water separator, acceptable to the Ministry of the Environment and Climate Change.

Reason why Abovementioned Code Requirements Cannot be Met:

1. FloMAX FNBL-P nozzle:

The existing fleet of mining equipment was manufactured by Caterpillar and equipped with 1.5-inch dry-break style connections (‘dry-break style’ describes a hose connection device type that provides an automatic mechanism to seal off both the hose and the fixed pipe end when the hose is disconnected) suitable for use with either FloMAX or Wiggins style nozzles. These tanks and fill systems are designed by Caterpillar so that the nozzle will stop automatically when the tank reaches its intended fill level. This is a standard fill system used by major construction/mining equipment manufacturers around the world. Fill connections for these tanks are located below the top of the tank at a safe and convenient height for the operator. There are no alternative fill locations or fill methods for these fuel tanks.

The FloMAX nozzle has a flow rate of up to 150 GPM,which is compatible with the 1.5-inch dry-break style connections on Lafarge’s mining equipment, compared to a flow rate of approximately 60 GPM for conventional one-inch nozzles. For a large fleet of machines equipped with dry-break style connections, such as Lafarge’s, productivity is increased by reducing time spent refuelling equipment.

The FloMAX FNBL-P fuelling nozzle is not certified in accordance to the Underwriters Laboratories of Canada (CAN/ ULC) S-620:2016 standard.

2. No oil/water separator (OWS):

The new fuelling facility is equipped to ‘bottom load’ the mine’s mobile refuelling truck (bottom loading is a method of filling tank trucks by pumping fuel into cargo tanks through a system of valves and fittings mounted under a truck). Fuel from this vehicle is only dispensed into other mine-owned and-operated equipment to sustain operations. Mobile fuelling represents a small fraction of the mine’s operations but is the activity that has triggered the classification of the fuel facility as a bulk plant.

The new tank and pumphouse (the building where the pumps and other pumping equipment will be installed) will be located on the blasted “bedrock” floor of the quarry, making the installation of an OWS system extremely costly due to the site preparation. The operation of a separator system within a mining environment is also problematic due to the amount of dirt and solids that would fall from trucks, and then enter into and congest the OWS system. Since water from the separator would need to be pumped out, an OWS system would not be functional during the winter operations when pumps and piping are frozen.

Equivalent Safety Methods:

1. In support of Lafarge's request, the company has submitted a report, signed by Andrew Gendre, P.Eng., comparing the FloMAX nozzle to the CAN/ULC-S620, the standard for hose nozzle valves for flammable and combustible liquids:

• Section 4 - Construction

Due to the design of the nozzle using a dry-disconnect receiver instead of a spout and valve actuation interlock to this receiver, some requirements of section 4 do not apply (4.1.2, 4.1.3, 4.2.2, 4.2.4 and 4.2.5)

• Section 5.5 – Moist Ammonia-Air Stress Cracking Test 

There are no brass components in the valve, so this section is not applicable.

• Section 5.9.1 – Spout Weak Section Strength Test 

Because the design of this nozzle does not include a spout, this section is not applicable. It is recommended to install a dry-disconnect breakaway valve in the fuel hose on which the nozzle is installed to mitigate damage and spilled fuel if a driver inadvertently drives away with the nozzle connected.

• Section 5.10 – Release and Shut Off Test

Due to the bottom fill receiver mechanical connection design of the nozzle and receiver discussed above, this section does not apply.

• Section 5.12 – Endurance Test 

Testing has been completed to 10,000 cycles instead of 100,000 cycles. Most of these nozzles are installed in harsh environments and, as such, usually have damage requiring replacement before 100,000 cycles would be reached. These nozzles have been used successfully at mine sites all over the world for many years with no issues when installed and operated as per the manufacturer’s requirements.

• Section 5.15, 5.16 – Accelerated Air Oven Aging Test & Tensile Strength and Ultimate Elongation

Testing was not performed, however industry standard sealing elastomers (Viton B70, Nitrile 70 and Fluorosilicone) are used in the design of the valve. These materials have been tested and used successfully and extensively in industries with diesel fuel.

The report concludes that the FloMAX FNBL diesel fuel nozzle meets and exceeds the requirements and safety objectives listed in the CAN/ULC-S620:2016 standard.

2. Refuelling of the mobile tanker can be performed safely without an oil water separator because, as Lafarge reports:

• The fuel truck is operated by a dedicated, trained mine employee.

• The truck will typically be refuelled once per day to support production requirements only. This low frequency presents a much lower risk of spills than at retail facilities or other private fuel outlets which do not require an OWS.

• During fuelling, the operator remains within approximately two metres from the fuel connection and emergency stop device. This allows for an immediate response, in the event of a concern. Even in the unlikely event of a component failure, operator response will be very rapid to avoid a significant spill.

• Bulk tanker refuelling will take place on a concrete pad to allow for the containment and capture of any minor spills or leaks. The area surrounding the concrete spill pad is bedrock capped with a layer of aggregate that has been densely compacted by the passage of Cat 777 haul trucks that weigh approximately 125,000 lbs when empty and nearly 300,000 lbs when loaded. Due the compaction levels, this material will resist liquid penetration and will reduce liquid absorption into the ground, in the unlikely event of a spill or leak.

• The refuelling connection is a double dry-break connection using a Dixon 5400 API coupling so that, upon disconnection, the contents from the truck and the fuelling couplings are contained. It is a standard operating requirement that the operator place a containment pan under the fuel connection during the connection, fueling process, and disconnection of the truck. Any minor drips or spills during the connection process will be captured before reaching the spill apron.

• Overfill prevention will include:
  • a Scully Intellitrol system which is interlocked to ensure that the vehicle cannot be inadvertently overfilled. This equipment is the same as, and meets, the safety standards of fuel transfer equipment at major distribution terminals; and

• • a Titan Logix Finch II system installed on the mobile fuel truck to monitor the levels in both compartments and signal a high-level alarm for the operator to stop the truck fill process.

• The fuel facility is equipped with seven global emergency stop devices (situated at all fuelling locations) to immediately stop the flow of all fuel in the event of a leak or spill. During the tanker refuelling process, the operator procedure requires that the driver remain in attendance at the fuel connection point, which is within approximately two metres from an emergency stop device. This proximity will help ensure that the equipment can be immediately shut down to prevent any significant spill during the tanker refuelling process.

• The fuel facility is equipped with a readily accessible spill containment kit in the event of a leak or spill.