VAPOR BC

11631 Seahurst Road, Richmond, BC, V7A 4K1 Phone: 604 240-1986 Fax: 604 271-5535

www.vaporbc.com vaporgroup1@gmail.com

28 June 2012 Rachel Shaw, Project Assessment Director, Oil and Gas Projects BC Environmental Assessment Office 2nd Fl., 836 Yates Street Victoria, BC V8W 1L8 Yoss Leclerc, Harbour Master/ Director, Operations & Security, Port Metro Vancouver 100 The Pointe 999 Canada Place Vancouver, BC, V6C 3T4 Et al. Cc: Honourable Minister of Environment, Terry Lake Honourable Premier Christy Clark Honourable Peter Kent, Minister of Environment Canada, Mr. Adrian Pollard, Vancouver Airport Fuel Facilities Corporation Mr. Tim Leadum, Ecojustice. Et al. Subject: The VAFFC jet fuel transport proposal is a reviewable project in BC. Dear Rachel Shaw and Yoss Leclerc, Since the Vancouver Airport Fuel Facilities Corporation (VAFFC) jet fuel transport proposal is really a reviewable project, the BC Environmental Assessment Office (EAO) must require the VAFFC to tell us what the worst case hazard footprints4 and risk areas5 would be for people, plants and animals around the entire site adjacent to the Silver City Entertainment Complex, i.e., the 80,000,000 liter tank farm, marine terminal AND a giant Panamax tanker off-loading jet fuel at the marine terminal. Currently, the BC EAO is lacking due diligence, in leading a voluntary harmonized review, by not invoking a formal and thorough BC Environmental Assessment (EA) based on the total energy stored at the proposed VAFFC jet fuel marine terminal and tank farm during off-loading from a Panamax tanker. Imagine what would happen if a twin engine plane, like the one that crashed into an apartment building in Richmond12 in 2007, crashed into one of the jet fuel storage tanks on the tank farm or the Panamax tanker unloading jet fuel at the marine terminal, or jet fuel vapour in air caused by a leak in the tank farm, was ignited inadvertently. We want to eliminate similar conflagrations like one at the Miami International Airport13, on 24 March 2011 or Buncefield, UK6, 15.

By our calculations, the total energy stored in that toxic and flammable jet fuel in the tank farm and Panamax tanker would be equivalent to more than 1,000,000 tons of TNT. If that energy were released quickly as it would be in the case of a fire or an explosion, it would be catastrophic over a wide area. The condos, 400 meters away from the Panamax tanker at the marine terminal, would be devastated by the searing radiant heat, flammable gas cloud, blast overpressure and flying debris4. These are unacceptable risks. Jet fuel vapours and air mixture can explode6, 7, 8, 9, 10, 11 at a temperature as low as 35 C. A litre of Jet-A has 34.67 megajoules (MJ) of energy3, so 80 million litres has 2.7 petajoules2 (PJ) of energy and berthed Panamax tanker with 80 million liters also has 2.7 PJ of energy. Thus the worst case total energy stored at the site is 5.4 PJ which is equivalent to 1,280,000 tons of TNT2. The public, in Richmond and Delta, has been misled by BC EAO saying that the VAFFC jet fuel transportation project on the South Arm of the Fraser River is not a "Reviewable Project" and therefore does not require a mandatory BC Environmental Assessment. Including the energy stored in a Panamax tanker unloading jet fuel plus the tank farm, exceeds by 80% the legal threshold1 of 3 petajoules (PJ) of energy stored needed to initiate an Environmental Assessment by the BC EAO. Safety and reliability are not the same. You can have a highly reliable system that rarely fails, but when it does fail, it fails catastrophically causing many fatalities, injuries and ecological damage. Alternatively, you can have a safe system that is less reliable but always fails into a safe state, with minor consequences, if any. Storing 5.7 PJ of energy, equivalent to more than 1,000,000 tons of TNT, on one site is an unacceptable safety and ecological risk to foist upon unsuspecting and uninformed citizens of Richmond, Delta, and Vancouver, especially when there is a safer and more reliable option that is ecologically friendlier such as a pipeline only solution to existing refineries. It has a much smaller impact when an incident occurs. A pipeline only solution will significantly minimize the worst case regrets when something goes wrong. This demands a joint federal/provincial independent expert Panel Review with full public hearings that enable the public to have experts16 present their views and also to hear the views of the Governments and the proponents experts, instead of an inadequate voluntary harmonized one! Yours safely, Jim Ronback, P. Eng. (retired Systems Safety Engineer), Director of VAPOR Delta, BC

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Reference and Notes: The trigger / threshold for a BC EA of an energy storage facility must exceed 3 x 10^15 joules = 3 PJ (petajoules) of stored energy. Thats 3 with 15 zeroes after it. One million, 1,000,000 joules (MJ), is approximately the kinetic energy of a one-tonne vehicle moving at 160 km/h (100 mph). One gigajoule (GJ) is equal to one billion (1,000,000,000) joules. Six gigajoules is about the amount of potential chemical energy in a barrel of oil, when combusted. Kerosene type BP Jet A-1 has 43.15 MJ/1 kg and a density at 15 C is 804 kg/m^3. The 80,000,000 liter tank farm containing toxic and flammable jet fuel has 2.7 PJ of energy stored. That is 90% of the criteria for a BC Environmental Assessment for the tank farm alone. If we add the energy stored in a Panamax tanker containing 80,000,000 liters of jet fuel, offloading at the marine terminal, we get an additional 2.7 PJ of energy stored on the site. Thus the total worst case energy stored at the site is 2.7 + 2.7 = 5.4 PJ which exceeds the BC EA reviewable project criterion by more than 80%. BC EAO Reviewable Projects Criteria: (1 Subject to subsection (2), a new energy storage facility with the capability to store an ) energy resource in a quantity that can yield by combustion > 3 PJ of energy.

1)

1 Energy Storage Facilities

http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/13_370_2002 . The above item is one of the triggers/ thresholds for reviewable projects used by the BC EAO. 2) Megajoule - The megajoule (MJ) is equal to one million (10^6) joules, or approximately the kinetic energy of a onetonne vehicle moving at 160 km/h (100 mph). Because 1 watt times one second equals one joule, 1 kilowatt-hour is 1000 watts times 3600 seconds, or 3.6 megajoules. The petajoule (PJ) is equal to 10^15 joules. 210 PJ is equivalent to about 50 megatons of TNT. This is the amount of energy released by the Tsar Bomba, the largest man-made nuclear explosion ever. Joule http://en.wikipedia.org/wiki/Joule 3) Kerosene type BP Jet A-1 has 43.15 MJ/kg and a density at 15 C is 804 kg/m3. http://en.wikipedia.org/wiki/Aviation_fuel . Therefore, for the tank farm, 804 kg/ m3 = 804 kg / 1000 liters = 0,805 kg / 1 liter, 80,000,000 liters = 80,000,000 liters * 0.804 kg /1 liter = 64,320,000 kg of jet fuel. 64,320,000 kg * 43.15 MJ = 2,775,408,000 MJ = 2,775,408,000,000,000 Joules = 2.7 PJ of energy in the tank farm. This is equivalent to the energy stored in (2.7/ 210) x 50 megatons = 0.64 M tons of TNT = 640,000 tons of TNT. A Panamax ship would typically have a DWT of 65,000 to 80,000 tonnes. (1 tonne = metric ton = 1000 kg) A Panamax tanker unloading at the marine terminal is at most 80 % full (because of clearance over the Massey tunnel). The 80,000 tonnes capacity * 0.8 = 64,000 tonnes of jet fuel = 64,000,000 kg / 0.804 kg/ 1 liter = 79,601,990 liters = 80 M liters. 64,000 tonnes = 64,000,000 kg * 43.15 MJ/1 kg = 2,760,000,000 MJ = 2,760,000,000,000,000 joules = 2.7 PJ of energy in the tanker. That combined stored energy is equivalent to 5.4 PJ * (50,000,000 tons of TNT / 210 PJ) = 1,280,000 tons of TNT. KABOOM!! 4) RISK ANALYSIS OF LADWP MARINE TANK FARM http://www.portoflosangeles.org/EIR/WilmWaterfront/DEIR/Appendix_G.pdf . 5) Phast 6.6 will provide more transparency within the risk results and significant improvements in the accuracy with which explosion risks can be assessed in areas of congestion and around occupied buildings. http://www.dnv.com/services/software/publications/2008/no_2/phast2009explosionextension.asp . 6) "Thermobaric explosives apply the principles underlying accidental unconfined vapor cloud explosions (UVCE), which include those from dispersions of flammable dusts and droplets. In previous times they were most often encountered in flour mills and their storage containers and later in coal mines, but now most commonly in discharged oil tankers and refineries, the most recent being at Buncefield in the UK where the blast wave woke people 150 kilometres (93 mi) from its centre" http://en.wikipedia.org/wiki/Thermobaric_weapon ,

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http://en.wikipedia.org/wiki/Buncefield_fire . 7) "Use normal foam. Wear normal fire kit in combination with breathing apparatus. Spillages and decontamination run-off should be prevented from entering drains and watercourses. Substance can be violently or explosively reactive. Compendium of Chemical Hazards: Kerosene (Fuel Oil). http://www.who.int/ipcs/emergencies/kerosene.pdf . 8) Confined kerosene vapor explosion: Severity prediction laws based on numerical simulations http://www.researchgate.net/publication/216723863_Confined_kerosene_vapor_explosion_Severity_prediction_laws_bas ed_on_numerical_simulations . 9) ... The flammability of hydrocarbon liquids in aerosols form is very different from that in the form of a liquid pool which is dictated by the flash point or vapor pressure ... the main mechanism controlling aerosol explosion is the combustion of vapor/air mixture." Explosion properties of aerosol/air mixtures http://www.aidic.it/aaas08/webpapers/43DiBenedetto.pdf . 10) "Flammability depends on many factors: Ignition source (energy, temperature); Fuel state (vapor versus mist, mass loading); Turbulence; Temperature; Pressure ... Flash point is not a useful characterization of explosion hazard" page 20 EXPLOSION OF AVIATION KEROSENE (JET A) VAPORS http://www2.galcit.caltech.edu/EDL/projects/JetA/reports/EX_20F.PDF . 11) Jet A Nominal Flammability Range A simple representation of Nestor's experimental data is to fit the flammability limits to a straight line in altitude versus temperature coordinates using the properties of the standard atmosphere to convert from pressure to altitude. The results are shown in the plot.

TLFL

TUFL

(kft (psi ) a) (C) (F) (C) (F) 0 35. 95. 85. 14.7 0 0 0 185.

Jet A Nominal Flammability Range http://www2.galcit.caltech.edu/EDL/projects/JetA/JetAFlammRange.htm . 12) 1 dead, 2 injured after plane crashes into building in Richmond, B.C. http://www.cbc.ca/news/canada/british-columbia/story/2007/10/19/bc-plane.html . 13) Videos of Miami Jet Fuel Tank Farm Fire on March 24, 2011 http://www.youtube.com/watch?v=m7Mu4fJaLUo&feature=player_embedded . http://www.youtube.com/watch?v=sXYBsuhB6u0&feature=player_embedded . http://www.youtube.com/watch?feature=player_detailpage&v=2uiSIQHkLEU . 14) Chemical Accidents with Jet fuel jp-8 http://www.factsonline.nl/accidents/%205405/D57AC0CA-230B-4160-BBCE-C4D84943A9FF/chemical-accidents-with-jetfuel-jp-8 . 15) Recommendations on the design and operation of fuel storage sites http://www.endress.com/eh/central/info/resource.nsf/imgref/Download_Buncefield_Investigation_DORecommendations.pdf/$FILE/Buncefield_Investigation_DO-Recommendations.pdf . 16) Engineering a Safer World - Systems Thinking Applied to Safety, Nancy Leveson, MIT Press 2011 http://sunnyday.mit.edu/safer-world/index.html , http://mitpress.mit.edu/0262016621 .

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