VALE CANADA LIMITED - Approval for variance from the Liquid Fuels Handling Code

Please note that all updates to the original variance request are in bold text.

Vale Canada has a project underway to install a new fuel management system to monitor its fuel consumption. Potential system features include:

• cardlock/keylocks at each site
• upgrades to the existing level controls
• complete storage tank replacements, if necessary

This proposed fuel management system is currently out to tender for a design-build solution. The final vendor decision may not be determined until October 2020. As such, Vale would like to wait until the vendor and project details are confirmed, before making any fuel management system changes.

Current fuel management system deficiencies at the sites—along with their respective mitigation methods—are as follows:

• All six sites have fuel hoses that are not certified by the Underwriters’ Laboratories of Canada (ULC). Clause 1.3.1 of the Liquid Fuels Handling Code (LFHC) requires that equipment be approved for use. VALE has been unable to obtain a 1.5" dispensing hose approved for use in Ontario.  In consultation with several industry manufacturers, a ULC certified hose in 1.5" is not available; therefore, a variance application has been submitted to TSSA for authorization to use hoses that are suitable in comparison with CAN/ULC-S612:2016, Standard for Hose and Hose Assemblies for Flammable and Combustible Liquids.  

• • Mitigation Method: VALE is committed to standardizing the components and replacing all hoses identified as ‘non-compliant’ by no later than May 1, 2021, with adequate hoses, once authorized by TSSA.

• Five sites (excluding 117 Mine Rd) do not have pressure relief for the piping. Clause 4.1.8 of the LFHC requires that piping have pressure relief. VALE is installing a new Fuels Management System to monitor incoming, consumption and dispensing of fuels.  This project includes installing a cardlock/keylock system at each site and upgrading the existing level controls.  The project is ongoing, as the hardware is currently being installed throughout VALE operations in Sudbury. That said, it would not be feasible to proceed with any major re-configurations of the piping systems prior to the installation of items for the parallel projects.  The request is to complete the re-configuration of the piping systems to eliminate the concerns of potential pressure lock-up conditions by no later than May 1, 2021.
  • Mitigation method: It is unlikely that the piping will experience an over-pressure during the winter months.

• One site (487 Power St) has an emergency vent that is less than six inches above the spill container. Clause 4.3.2.4 of the LFHC requires that emergency vents be at least six inches above the spill container.
  • Mitigation method:  A new storage tank facility is being constructed at this site.  Therefore, the deficient tank will be out of service by June 2021.

• One site (1702 Godfrey Drive) has a spill container that has a drilled hole plugged with washers, bolts and silicone.
  • Mitigation method:  A new approved spill container will be installed, in accordance with clause 1.3.1 of the LFHC, when the facility is upgraded.

Some locations have a horizontal tank in a dike, while others have a double-wall aboveground storage tank. To further mitigate the abovementioned deficiencies, Vale Canada will continue periodic monitoring of the tank systems, in accordance with LFHC Section 7 (Table 4). In addition, the horizontal and the double-wall tanks at each site will be subject to weekly visual inspections performed by a certificate holder and monthly inspections by a petroleum mechanic.