Ronback Critique on Norske Study June 16, 2012 Ronback and Langer FINAL Jr1

7/31/2019 Ronback Critique on Norske Study June 16, 2012 Ronback and Langer FINAL Jr1

1/10

A Critique of the Fraser River Tanker Traffic Study prepared for Port Metro

Vancouver by Det Norske Veritas, June 6th

, 2012.

By James Ronback, P. Eng. (Retired), Delta, BC

Revised June 16, 2012

A. The Process Related to the Tanker Traffic (Risk) Study.

The Tanker Traffic Study commissioned by Port Metro Vancouver (PMV)* is an importantcontribution to the debate as to the wisdom of PMV allowing tankers carrying hazardous liquidbulk cargoes into the Fraser River as related to the Vancouver Airport Fuel FacilityCorporations (VAFFC) less than responsible proposal to ship giant quantities of toxic andflammable jet fuel into the Fraser River Estuary and unload it there and store it on the South Armof the Fraser River in Richmond before transferring to YVR by means of a pipeline across

Richmond. Unfortunately this new study has some major shortcomings that are not identified inthe Vancouver Sun's June 9th, 2012 article (6) by Jeff Lee.

Originally this study was to be independent of the VAFFCs proposal but as the BC EAO reviewwas stalled from a 180 day review to one that will exceed 500 days, this study is now understoodto be part of the BC EAO considerations in possibly permitting this project.

The method by which this study has been conducted will again cause maximum controversy andconflict. Originally VAPOR asked to see the terms of reference and provide input into the studybut this request was refused by Port Metro Vancouver. The public is now left in the position torespond to the media and to BC EAO when the opportunity for public input and comment has

largely passed. It is strongly recommended that BC EAO allow a level playing field to exist inwhat has been a less than defensible and legitimate review by again allowing public to providecomments into the BC EAO review before they consider this report as is. It is new informationthat can bias any decision and the public must be afforded an opportunity for additional input.

B. The Tanker Traffic Study - A Piecemeal Review of the Overall Risk Associated with

Tanker Traffic in the Fraser River Estuary.

One of the scenarios reviewed is the transport of toxic and flammable jet fuel via Panamaxtankers up the Fraser River to the proposed Vancouver Airport Fuel Facilities Corporation(VAFFC) marine terminal on the South Arm of the Fraser River just east of the Massey Tunnel.

The scope of this study was limited, as related to VAFFC proposal, only to hazards ofmaneuverability and navigability of towed giant Panamax jet fuel tankers and barges on theFraser River.*(http://www.portmetrovancouver.com/en/users/marineoperations/navigation/TankerTraffic.aspxIt does not take into account the enormous hazards posed by the tank farm six stories high with80,000,000 liters of toxic and flammable jet fuel, i.e., kerosene, to be built on an extremelyhazardous earthquake liquefaction zone in Richmond. Earthquakes will not impact a jet fueltanker in the river as much as it would a tank farm and jet fuel handling facilities on land.


2/10


3/10

Based on their configuration, if a blast occurred, their largest resultant hazard footprint extendedto 1280 feet (390 meters) for radiant heat. Within this distance exposed personnel will feelextreme pain within 15 to 30 seconds and will suffer second degree burns after 30 seconds.Within 800 feet (244 meters), the explosions and resulting air blast are generally accompanied byflying fragments or debris. These "missiles" have the potential to severely injure or kill people

from flying debris. Within 650 feet (198 meters) the blast overpressure is sufficient to rupture eardrums. Within 160 feet (49 meters) a gas cloud from the release of flammable material will movewith the speed of the wind and mix with the air as it does so. Such a cloud can become ignitedwhen the gas to air mixture is above the lower flammability limit. These distances are measuredfrom the edge of the diked area,http://www.portoflosangeles.org/EIR/WilmWaterfront/DEIR/Appendix_G.pdf.

Thus the PMV tanker traffic study must be augmented with additional risk studies (18) toconduct such a review and provide much more thorough System Safety analyses to provide duediligence needed to determine whether or not the VAFFC proposal can be approved by theharmonized PMV and the BC Environmental Assessment Office (EAO) process. It must identify

and quantify the worst case hazard footprints for fire, smoke, blast damage and ecological impactresulting from potential fires, explosions, spills, etc., occurring when these enormous jet fueltankers are berthed at the marine terminal and off-loading toxic and flammable jet fuel into thetank farm on the south arm of the Fraser River.

D. Ignoring the Actual Risk and Possible Worst Case Scenarios

The worst case hazard footprints of the proposed huge tank farm holding toxic and flammable jetfuel will be enormous. Neither VAFFC nor the BC EAO nor PVM have revealed how big thesehazard footprints are. The hazard footprints have not been provided as done in Los Angeles. Ifan uncontrolled fire got started and one of the six tanks exploded, burst and spilled burning jetfuel into the Fraser River, it would contaminate the water table and the entire Fraser RiverEstuary and threaten the salmon fisheries and wildlife habitat for migrating birds for decades.

The blast wave and fire would damage nearby structures and windows in and around Silver Cityand the condos just 400 meters from the proposed marine terminal and tank farm. Take a look atthe recent jet fuel tank farm fire in Florida that destroyed the fire safety mechanisms intended toprotect it (http://www.vaporbc.com ). Remember - the fisheries, wildlife and microbialcommunities that are the victims of Exxon Valdes in Alaska or the BP Horizon disaster in theGulf of Mexico have yet not fully recovered (5, 13 and17)!

In Richmond it could get even worse if the giant Panamax tanker berthed there also caught fireand exploded. The conflagration would cause large areas to be evacuated for miles until the fires,smoke and subsequent cleanup could be finished. Scenarios similar to those used for SystemSafety analyses used for the LAX fuel tank farm should be seriously considered (12). Further,this study seems to indicate that PMV wants to open the door to other tanker traffic in the FraserRiver including more flammable oil products. This will of course greatly increase the risk on theriver and its broad ecologically sensitive estuary for all involved.


4/10

Any attempt to clean up jet fuel spills large or small in the Fraser River Estuary would be at bestless than 15% effective. The effectiveness of VAFFC's or BC's emergency services ability tocontain a major spill has not been quantified in this report. The jet fuel would disperse into thefast flowing water column and most of it would pass under any oil booms set along the shoresand marshes. The toxic additives would become embedded in the shores, marshes and river

bottom killing the biota that the fish and wildlife depend on, and contaminate the biofilm on thetidal flats that nourishes the migratory shorebirds. Additional Risk Acceptance Criteria thatincludes the environment must be must be provided (22).

E. Accountability and Liability.

What about the consequent liabilities? Who's going to pay for the lost jobs, damaged homes,devastated businesses, lost fisheries, dead and sick wildlife and their contaminated habitats? It'sus, the citizens and taxpayers of Metro Vancouver. Each affected municipality is obliged toprovide special foam fire fighting, emergency and clean up capabilities which do not exist and

are not paid for by VAFFC or the tanker owners. Ideally, the spiller pays, but it will be a majorchallenge to prove it and collect on those damages, especially from tankers flying under a flag ofconvenience, because their liabilities are limited by international conventions. Also what is thenon-profit VAFFC liable for? Will Air Canada and WestJet and the other airlines that formedVAFFC belly up to the bar and compensate society for their terrible planned fuel handlingfacility? Also the liabilities extend into the USA in that they have a legal right to fish a part ofthe Fraser River salmon runs and protect international migratory birds that belong to all of us onthis planet.

Nearby property values on both sides of the river are already impacted by this threat.Condominium values have gone down. Despite ever escalating property values in the Vancouverarea, condos bought near this proposed VAFFC terminal have indeed dropped since 2006 andany approval of any such tanker traffic and terminal facilities to handle such toxic and flammablefuels will further destroy property values. Who is to be held accountable for that real propertyand wealth loss and the needless stress caused to thousands of citizens in the area over the pasttwo years?

All these external liabilities were not factored into the total 60 year lifetime cost of this project toour communities when VAFFC was picking the option with "most merit". This proposed projectis not viable, nor desirable. It's insane to allow it to proceed. VAFFC, a consortium owned by of27 airlines with Air Canada as the major share owner, needs to use a minimum regret strategyinstead of a maximum win strategy when picking the best option to satisfy their jet fuel needs.

F. Failure to Examine Safer Options, i.e., a pipeline via Ferndale, WA.

Alternatively, by using a more reliable pipeline-only solution, if any spill occurs it will besmaller and contained with a much smaller worst case hazard footprint. A pipeline-only option(#3 or #8) in the VAFFC proposal, to the existing refineries in BC or WA is a much safer and amore environmentally friendly solution and will have fewer incidents. VAFFC will still be ableto buy their jet fuel at spot market prices and have it delivered to the large deep sea fuel dock at


5/10

Cherry Point, WA terminal and then transported safely via pipeline to the VancouverInternational Airport (YVR).

The current maximum supply limit is 5.29 million liters per day (MMLD). BMB Fuel ConsultingServices estimates that by 2027 YVR would need 7.98 MMLD compared to the VAFFC estimate

of 10.68 MMLD (21). The latter estimate may be questionable given that YVR had the samenumber of takeoffs and landings in 2011 as they had in 2002 (22), suggesting very little growthin fuel consumption. Passenger volume at 17,000,000 in 2011 was only 0.5% more than in 2006.Its not clear if they have taken in account 40 to 50% improvements in aviation fuel intensity (thefuel required per passenger kilometre) over the long term (24).

Assuming that the volume of jet fuel needed will double by 2027, i.e., 10.6 MMLD. and sincethe current 8" pipeline from Westridge terminal to YVR provides about 80% of the current needthen a new pipeline would have a larger cross section have a diameter of about ((8*8/0.80)*2) =x*x, where x is the new diameter. Solving for x, the new pipe diameter is about 12.65 incheswhich would be rounded up to 14".

A rough estimate for a 60 kilometer 14 pipeline and pumping stations via Blaine, WA, to theCherry Point terminal is about $55,000,000 dollars (19, 20). The incremental increase in cost forproviding a pipeline-only solution that eliminates potential jet fuel tanker traffic from the FraserRiver Estuary as well as the current tanker and barge traffic from Cherry Point, WA via BurrardInlet to the Westridge terminal offsets these huge external liabilities that do not impact VAFFCbut can drastically impact the surrounding communities of Richmond, Delta and Vancouver.

The scope of the PMV Tanker Traffic Study must be expanded to include the cumulative hazardfootprints of the unloading process and storage of hazardous jet fuel into a tank farm plus rivervessel traffic. Once done, PMV must provide the opportunity for the public and System Safetyexperts at arm's length to review and comment on it. Scaling up river traffic from small barges togiant Panamax tankers carrying hazardous liquid bulk makes an enormous difference. Getting ridof Panamax tanker traffic up the Fraser River and the Burrard Inlet will minimize our cities'worst case regrets.

Also as part of this shortcoming, the BC EAO must assume a great deal of responsibility forrefusing to consider any other alternatives or even a single safer alternative. This is a majorshortcoming in BC EA legislation and approach and does not serve the public interest properlyand is yet another reason why the BC EA process has been so criticized and is largely ineffectivein conducting a proper and responsible environmental assessment (EA). They have insteadnaively accepted an irresponsible concept for review which they have conducted in a piecemealreview that will take three times the time they advertise they can do an EA and issue permits.Greater environmental leadership has to be shown by both the Federal and BC governments inthis major environmental assessment shortcoming.


6/10

G. Conclusions:

Unfortunately PMV has fostered a study to a very limited set of stake holders and refused publicoverview and the final product as completed by Det Norske Veritas is piecemeal and out ofcontext and again ignores overall cumulative environmental and safety risk and the related

hazard footprints and risk areas. Such studies can and have already misled the public and cancause an unbalanced review by PMV and the BC EAO in that the PMV is in an obvious conflictof interest in promoting more business for their port and running the Federal EnvironmentalAssessment review of a project on their land that they would dearly like to see approved and thendirecting a study without public overview that erroneously indicates that shipping tankers ofhazardous materials into the Fraser River, especially toxic and flammable jet fuel, is a low riskand acceptable activity.

It is truly ironic that when VAFFC tried to ship jet fuel into the Fraser River Estuary in 1989, theproposal was soundly rejected by a Federal Review Panel process. Why in 2012 are we stillconsidering a project 100 times of greater risk to be considered and allow that project to open up

the doors to almost any kind of hazardous tanker traffic into a world class ecological jewel??

I respectfully request that Delta, Richmond and Vancouver pressure our MLAs and MPs to takea strong stand and squash this this insane proposal. It is a disaster waiting to happen within its 60year life. Your grandchildren will thank you for it.

Yours safely,

Jim Ronback, P.Eng., (retired) Systems Safety Engineer1530 Kirkwood Road,Delta, BC,V4L 1G1

604 948 1589


7/10

H. References and Additional Reading.

1) Evaluation of Fuel Delivery Optionshttp://www.vancouverairportfuel.ca/files/Fuel%20Delivery%20Options%20Report.pdf

2) Marine Spill Response Options: The Manualhttp://www.iosc.org/papers_posters/01200.pdf

3) Freshwater Net Environmental Benefit Analysishttp://www.epa.gov/oem/docs/oil/fss/fss06/eddy.pdf

4) "Pipelines are inherently safer to the public than other modes of freighttransportation for natural gas and hazardous liquids (such as oil products)because they are, for the most part, located underground."- Page 3, GAO/RCED-00-128 Oversight of Pipeline Safety

"From 1989 through 1998, pipeline accidents resulted in an average of about22 fatalities per year. Fatalities from pipeline accidents are relatively lowwhen compared with those from accidents involving other forms of freighttransportation: On average, about 66 people die each year from barge

accidents, about 590 from railroad accidents, and about 5,100 from truckaccidents. While these statistics provide an indication of the relative safetyof pipelines for transporting natural gas and hazardous liquids, the totalnumber of major pipeline accidents (those resulting in a fatality, an injury,or property damage of $50,000 or more) increased by about 4 percentannually over this 10-year period. Most fatalities and injuries occurred as aresult of accidents on pipelines that transport natural gas to homes andbusinesses (primarily intrastate pipelines), while most property damage

occurred as a result of accidents on pipelines transporting hazardousliquids (primarily interstate pipelines). Furthermore, pipelines thattransport hazardous liquids account for nearly eight times as many majoraccidents per mile of pipeline as do pipelines that transport natural gas tohomes and businesses. The Office of Pipeline Safetys data on the causes ofpipeline accidents are limited to a few categories, but these limited dataindicate that damage from outside forces, such as excavation, is theprimary cause of such accidents."- Page 4, GAO/RCED-00-128 Oversight of Pipeline Safety

The following table clearly summarizes the relative risk of various modes of transportation.(http://www.pipelinerisk.com/pdf/General_account_report.pdf).


8/10

5) Microbial Communities Changed After Deepwater Horizon Spillhttp://www.newswise.com/articles/view/590091/?sc=dwhr&xy=10000760.

6) Shipping aviation fuel, canola on the river low-risk: Port Metro Vancouver reportBy Jeff Lee, Vancouver Sun June 8, 2012http://www.vancouversun.com/technology/Shipping+aviation+fuel+canola+river+risk+Port+Metro+Vancovuer+report/6754852/story.html .

7) Miami International Airport fuel tank farm fire could mean massive airline delayshttp://www.wptv.com/dpp/news/state/miami-international-airport-fuel-tank-farm-fire-could-mean-massive-airline-delays .http://www.vaporbc.com .

8) Preparing for the Big One!- Tactical preparation for major incidents involving fuels.http://www.apssafety.net/sitebuildercontent/sitebuilderfiles/lviatankfarms.pdf.

9) "Kerosene 4000' upstream from water plant intake. Versar states at 180 ppb [parts per billion]kerosene people won't drink water because of bad taste".On-Scene Coordinator's Report: Battle of Bull Run, Manassas, Virginia, March, 1980http://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=9100CIY1.txt .

10) The quantitative risk of oil tanker groundings - MIT Masters Thesishttp://dspace.mit.edu/handle/1721.1/11033 or

http://www.dtic.mil/cgi-bin/GetTRDoc?Location=U2&doc=GetTRDoc.pdf&AD=ADA315738 .

11) A study of storage tank accidentshttp://www.sciencedirect.com/science/article/pii/S0950423005000641http://www.youtube.com/watch?v=S40RcLsar-g .

12) The following scenarios, for consideration in the VAFFCs expanded System Safety review,are adapted from:

Table 1: Relative Occurrence of Transportation Accidents Per Ton-Mile of Oil

Transported, 1992-97

Event Pipeline* Rail Tank ship Barge Truck

Fatality 1.0 2.7 4.0 10.2 87.3Injury 1.0 2.6 0.7 0.9 2.3Fire/explosion 1.0 8.6 1.2 4.0 34.7

*The rates of occurrence are based on a value of 1.0 for pipeline.Values of less than 1.0 indicate a better safety record.Source: Association of Oil Pipelines.- Page 10 GAO/RCED-00-128 Oversight of Pipeline Safety


9/10

"In December 1997, Camp Dresser & McKee Inc. conducted a hazard analysis of the potentialfor fire and/or explosion at the LAXFUEL Fuel Farm. The following worst-case scenarios forfire or explosion at the fuel farm facility were considered."

Scenario 1: This scenario assumes that a single 13,000,000 litre tank in the largest containment

area ruptures and the fuel subsequently ignites. The berm of the containment area is assumed toremain intact. Scenario 2: This scenario could be initiated from Scenario 1. If the fire was not immediatelycontrolled, the heat caused by the contained flames could result in the rupture (with possibleexplosion) of one or more of the other tanks within the bermed area. Scenario 3: The impact of a large aircraft crashing into the fuel farm or an oil tanker at berthor a pipelinefrom the terminalor a collision between vesselsor with obstaclesin the FraserRiver Estuary could be expected to cause a similar but larger event. With such an occurrence,the secondary containment would probably be damaged, and unable to control the released fuel.Under this scenario, burning fuel could flow along the ground surface to the storm drain systemsurrounding the facility and into the Fraser River. Ignited fuel might flow within the system,

creating thermal damage, although there would be little risk of explosion. It is likely that a firewithin the storm drain system would quickly burn out due to a lack of oxygen.Scenario 4: An incident during off-loading of a tanker or barge causing a fire and explosioncould spread to the tank farm and a fully loaded tanker at berth. The heat caused by the

flames could result in the rupture (with possible explosion) of one or more of the other storage

tanks or the oil tanker.

Note: The aircraft fuel stored in the largest quantities at LAX is termed Jet A fuel, which is akerosene type fuel, made up of hundreds of different hydrocarbons. Due to the physicalproperties of Jet A fuel (e.g., low volatility and low explosion potential), an explosion wouldonly be expected under confined conditions and as flame speeds associated with Jet A fuel arenot conducive to detonation, the probability of explosion is very low, but not negligiblehttp://www.ourlax.org/docs/draft_eir_NE/T14c_LR.pdf page 7.

13) Office of Exxon Valdez Oil Spill (EVOS) Damage Assessment and Restorationhttp://www.fakr.noaa.gov/oil/

14) A Probabilistic Analysis of Tanker Groundingshttp://www.dept.aoe.vt.edu/~brown/Papers/ISOPE97aPaper.pdf.

15) Risk Acceptance Criteria or "How Safe Is Safe Enough"http://www.questconsult.com/resources/papers/pdf/paper48.pdf.

16) Gibraltar blamed in Spain for oil spill - 07-06-11- ... the spill is from the tanks that went up in flames in Gibraltar port and that 6 kilometres ofbeach are already affected.The Gibraltar port has said that 4 or 5 tonnes of residues escaped to the sea.http://www.panorama.gi/localnews/headlines.php?action=view_article&article=7491

17) Esler, D., Trust, K., Ballachey, B., Inverson, S., Lewis, T., Riszzolo, D., Mulcahy, D., Miles,K., Woodin, B., Stegeman, J., Henderson, J., Wilson, B., Cytochrome P4501A Biomarker


10/10

Indication of Oil Exposure in Harlequin Ducks up to 20 Years After the Exxon Valdez Oil Spill.,Wiley-Blackwell, April 2010: DOI: 10.1002/etc.129

18)Risk Acceptance Criteria: current proposals and IMO position - 2002http://research.dnv.com/skj/Papers/SkjValencia.pdf .

19) Regression models estimate pipeline construction costshttp://www.ogj.com/articles/print/volume-109/issue-27/transportation/regression-models-estimate-pipeline-construction._printArticle.html .

20) North American Pipeline Construction Costhttp://www.ziffenergy.com/download/pressrelease/PR20090731-01.pdf.

21) Aviation Jet Fuel Supply to Vancouver International Airport (YVR).http://www.bcuc.com/Documents/Proceedings/2007/DOC_15780_B-2_BMB_Fuel_Report.pdf.

22) Towards environmental risk acceptance criteriaPierre C. Sames and Rainer Hamann, Germanischer Lloyd AG, 2009http://www.martrans.org/docs/ws2009/Hamann.pdf.

23) YVR Financial and Operating Highlights (2002-2011)http://www.yvr.ca/AR/2011/assets/pdf/vancouver-airport-authority-2011-economic-report.pdfpage 2, 3.

24) Flight path to Sustainable Aviation, May 2011.http://www.csiro.au/files/files/p10rv.pdf, page 15.

Prepared by James Ronback for VAPOR, Collaboration and editing by Otto Langer.