SHELL CANADA PRODUCTS - Approval for variance from the Liquid Fuels Handling Code

TSSA granted Shell’s Keele Terminal a variance for this purpose on May 11, 2000. Shell is requesting the variance be updated to include the new berm extension area.

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

3.3.1.3.2 The floor and walls of every dike shall be constructed to be compatible with

the liquid being stored, shall be leak tight, and shall be made of a material that has a maximum permeability of 1 × 10^-6 cm per second for a minimum period of 72 hours in order to withstand the full hydrostatic head of product within the dike.

 Why the Code Would Not be Met

The use of this available quantity of native materials for the berm extension construction would avoid Shell having to import clay from external sources and dispose of this native material.

Equivalent Safety Measures

The combination of the materials of construction combined with Keele Terminal’s environmental monitoring and prevention and emergency response plan provide a tank berm with an equivalent level of safety to that of the Code requirement. Details of each element are discussed below:

1. Natural Containment Features

Preliminary testing of the native subgrade and reworked native fill that would be used to construct the berm extension shows similarity to soil comprising the berm walls and floor of the existing main tank farm. The data indicates that existing native soil that will comprise the berm extension floor should meet the permeability requirement in the Code, but the extension walls will have a permeability similar to the existing berm walls.

2. Environmental Monitoring

a. Annual monitoring of wells located outside the tank farm berm would flag any changes in groundwater conditions. Monitoring of headspace vapour readings and depth to groundwater in selected monitoring wells is carried out, and groundwater samples from selected existing monitoring wells are collected and submitted for laboratory analysis. The results are compiled into an annual report

b. Monthly leak detection is carried out in monitoring wells installed down gradient of aboveground storage tanks located within the existing main tank farm berm. The monitoring includes measurement of the headspace vapour readings and inspection of the groundwater surface in each well for presence of floating free-phase product. All results are recorded and compiled and maintained in Shell files. No leak detection wells will be added to the berm extension as it will not contain any tanks.

c. The Keele Terminal is staffed 24 hours per day. The operators conduct regular inspections of the tank farm berms during their rounds.

d. Storm water that accumulates in the existing main tank farm berm is visually inspected for evidence of potential petroleum hydrocarbon impact before it is pumped through the existing oil/water separator system operated in accordance with a Ministry of the Environment, Conservation and Parks (MECP) Environmental Compliance Approval (ECA). Storm water accumulations in the berm extension would be managed in the same way. A related application for ECA amendment has been submitted to the MECP.

3. Product Release Prevention Measures

Petroleum product releases can occur due to equipment failure or tank overfilling. A tank rupture is not considered a credible product release scenario. The Hazard and Effects Management Process (HEMP) is a structured and systematic analysis methodology involving the Identification, Assessment and Control of hazards and the Recovery from effects caused by a release of the hazards. Continued application of HEMP over a number of years has resulted in comprehensive engineered controls and robust management systems which together ensure that risks associated with Shell’s operations are managed to levels which are As Low As Reasonably Practicable (ALARP).

The following barriers ensure the risk of product release is minimized, and in the case of a loss of primary containment (LOPC), the volume released to the tank farm is limited:

a. The maximum working level or normal fill level (NFL) is the highest level to which a tank is routinely filled with product under normal operations;

b. A pre-rail car or pre-pipeline verification calculation is carried out to validate that sufficient ullage is available below the NFL in the receiving tank;

c. Audible High Level Alarm (HLA) after NFL both inside the control room and outside on the terminal property indicates to the Operator that an action is required. The Operator will immediately stop rail car unloading and/or immediately contact the pipeline operator to request the flow to the tank be diverted or stopped.

Note, a DRT (demonstrate responsive time) exercise is performed every year to validate the alarm settings;

d. Audible High-High Level Alarm (HHLA) both inside the control room and outside on the terminal property indicates to the Operator that immediate action is required. In addition, it triggers an automatic shutdown of the product inlet motor operated valve (MOV) to the tank;

e. Hourly reconciliation procedure by Terminal Operators requires investigation when out of tolerance;

f. Instrumentation is maintained per manufacturers’ recommendations and testing is carried out on a monthly basis;

g. Tanks are inspected and maintained per API 653 requirements.

4. Emergency Response Protocols

The Keele Terminal utilizes the Shell Incident Management System (Shell IMS) in the event of an emergency. The elements of the Shell IMS model were developed and refined from actual incidents and are derived from the Incident Command System. Shell maintains and exercises its Emergency Response Plan (ERP) which ensures that any product release is immediately addressed through a standard approach to emergency response. A copy of the ERP is available at the Terminal and an electronic copy is available on the ShellNet. The “Roadmap for Initial Assessment and Response” details all steps to be followed from the moment a LOPC is detected or if the potential for product release is identified. In the ERP, all relevant product containment and clean up equipment is listed as well as emergency contacts, emergency service providers, regulatory notification requirements and remedial action plan.