SUDBURY INTEGRATED NICKEL OPERATIONS GLENCORE COMPANY - 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. 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. 6.1.1.13. Dispensing of product inside a building shall only be done with the approval of the authority having jurisdiction. Fixed dispensing equipment for product shall not be installed within any wholly enclosed building.

Reason why Abovementioned Code Requirements Cannot be Met:

1. The FloMAX dry-break style fuel nozzle is not certified in accordance with the Underwriters Laboratories of Canada (CAN/ ULC) S-620:2016 standard. Although not approved by ULC, the FloMax nozzle is ideal for use at mines because of its high flow rate and special dry-break connection that is designed to fit mining equipment. 

2. Due to the height of the building and the steep incline of the excavator access ramp to the upper mezzanine, excavator travel in and out of the building must be minimized to ensure operator and equipment safety. As a result, fuel must be dispensed into the excavator inside the building.

Equivalent Safety Methods:

1. FloMAX FNBL nozzle:

The Cat 329 excavator is 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 FloMAX nozzles. The fill system is 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 mining equipment, compared to a flow rate of approximately 60 GPM for conventional one-inch nozzles. Productivity is increased by reducing time spent refuelling equipment.

In support of Glencore’s request, the company has submitted the report below, 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. Indoor Fuelling

Fuelling is expected to occur two times per week with approximately 300 to 400 litres of diesel fuel transferred into the excavator each time. Fuelling will be performed by the equipment operator. This operator will receive training on safety-related concerns including but not limited to system operations, spill containment and response, and fire response.

The offload building has natural ventilation: The overhead door on the excavator access ramp is interlocked to ensure that it is in the open position before fuelling can commence. The total flow rate with the door open is 104,600 m3/hr * (far more than the minimum 250 m3/hr required by clause 4.1.7.2(4) of the Ontario Fire Code (OFC).  * Based on results from Area 5100 Airflow Survey ‐ Oct 6, 2020 report.

During fuelling, the operator is within two metres of an emergency stop to ensure a rapid response in the event of a spill. The fuelling area is a concrete pad surrounded on three sides by a concrete wall. The operator will place a spill containment boom at the open side during fuelling. The facility also has a readily accessible spill containment kit.

The building is sprinklered and the fuelling area will have two 40:BC fire extinguishers.