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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 important contribution to the debate as to the wisdom of PMV allowing tankers carrying hazardous liquid bulk cargoes into the Fraser River as related to the Vancouver Airport Fuel Facility Corporations (VAFFC) less than responsible proposal to ship giant quantities of toxic and flammable jet fuel into the Fraser River Estuary and unload it there and store it on the South Arm of 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 in the 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 review was stalled from a 180 day review to one that will exceed 500 days, this study is now understood to 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 and conflict. Originally VAPOR asked to see the terms of reference and provide input into the study but this request was refused by Port Metro Vancouver. The public is now left in the position to respond 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 in what has been a less than defensible and legitimate review by again allowing public to provide comments into the BC EAO review before they consider this report as is. It is new information that 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 Panamax tankers 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 of maneuverability and navigability of towed giant Panamax jet fuel tankers and barges on the Fraser River. *(http://www.portmetrovancouver.com/en/users/marineoperations/navigation/TankerTraffic.aspx It does not take into account the enormous hazards posed by the tank farm six stories high with 80,000,000 liters of toxic and flammable jet fuel, i.e., kerosene, to be built on an extremely hazardous earthquake liquefaction zone in Richmond. Earthquakes will not impact a jet fuel tanker in the river as much as it would a tank farm and jet fuel handling facilities on land.

If a major incident occurs at the tank farm while a Panamax tanker 275 meters long, is unloading at the marine terminal, a major jet fuel spill, fire or explosion will damage the Fraser River Estuary for decades. Improbable events as defined in this report are allowed to occur at least twice in the 60 year lifetime of this project. Even though such catastrophes are rare events, they must be thoroughly examined by System Safety experts and be mitigated to a level as low as reasonably practicable or eliminated if the risks are unacceptable. What is a river, a giant estuary, a large salmon run or a human life worth (15)? Although consultants will refer to these major incidents as rare events, the study does indicate a higher than acceptable rate of expected accidents in the Fraser River that will give rise to spills, i.e., accident, in general, every 2 to 5 years and spills up to 920 tonnes of jet fuel from the tankers alone. This is in addition to a high frequency of spills at the unloading facility and even at the storage tank farm which this study does not take into account. The original VAFFC studies predicted a frequency of 50 barrel (6000 litres) spills every 6 years and up to a 1000 (160,000 litres) barrel spills each 30 years. Now Det Norske Veritas predicts shipping accidents, in general, about every 5.9 years on the average. For a random total cargo spill in 2016 traffic levels, the average spill size would be 917 tonnes of kerosene, i.e., over a million litres of jet fuel about every 194 years. There will still be large cargo spills every 50 years! In each incident since it is a random event it cannot specify exactly how large and in which year this event may occur. These may be acceptable in some unregulated countries but not in the fragile and very productive Fraser River Estuary which is still home to the worlds largest runs of salmon and it is an estuary of global significance as related to migratory wildlife. To portray such rare spills of high consequence having acceptable impacts is irresponsible, reckless and insensitive to the precautionary protection of life on this planet.

C. Failure to Require and Conduct a Proper Overall Risk Study -- PMV, VAFFC and BC EAO are ignoring the cumulative impacts to public safety and to Fraser River salmon, wildlife and migratory birds. Excluding the cumulative risks due to the hazards of the tank farm and the unloading operations from this study makes the overall risks appear artificially low. It is a disaster waiting to happen anytime within its 60 year life. PVM and BC EAO and VAFFC must prevent it from happening by eliminating this hazard in the first place. A pipeline-only solution from YVR to the existing refineries in BC or Washington State is the only viable solution with the least regrets. What is missing from this PVM Tanker Traffic Study is the kind of necessary detail needed to assess the cumulative worst case hazard footprint of the VAFFC proposed marine terminal, tank farm, and the berthed jet fuel tanker plus vessel traffic on the south arm of the Fraser River. A hazard analysis of the potential for fire and/or explosion similar to what was done for the LAX tank farm (12) must be done for VAFFCs proposal. A risk analysis on a similar fuel tank farm site in the Los Angeles waterfront was done to justify its demolition to make their waterfront safer for housing, commercial and public development.

Based on their configuration, if a blast occurred, their largest resultant hazard footprint extended to 1280 feet (390 meters) for radiant heat. Within this distance exposed personnel will feel extreme 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 by flying 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 ear drums. Within 160 feet (49 meters) a gas cloud from the release of flammable material will move with the speed of the wind and mix with the air as it does so. Such a cloud can become ignited when the gas to air mixture is above the lower flammability limit. These distances are measured from 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) to conduct such a review and provide much more thorough System Safety analyses to provide due diligence needed to determine whether or not the VAFFC proposal can be approved by the harmonized 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 impact resulting from potential fires, explosions, spills, etc., occurring when these enormous jet fuel tankers are berthed at the marine terminal and off-loading toxic and flammable jet fuel into the tank 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 jet fuel will be enormous. Neither VAFFC nor the BC EAO nor PVM have revealed how big these hazard footprints are. The hazard footprints have not been provided as done in Los Angeles. If an uncontrolled fire got started and one of the six tanks exploded, burst and spilled burning jet fuel into the Fraser River, it would contaminate the water table and the entire Fraser River Estuary 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 City and the condos just 400 meters from the proposed marine terminal and tank farm. Take a look at the recent jet fuel tank farm fire in Florida that destroyed the fire safety mechanisms intended to protect it (http://www.vaporbc.com ). Remember - the fisheries, wildlife and microbial communities that are the victims of Exxon Valdes in Alaska or the BP Horizon disaster in the Gulf 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 fire and 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 System Safety 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 Fraser River including more flammable oil products. This will of course greatly increase the risk on the river and its broad ecologically sensitive estuary for all involved.

Any attempt to clean up jet fuel spills large or small in the Fraser River Estuary would be at best less than 15% effective. The effectiveness of VAFFC's or BC's emergency services ability to contain a major spill has not been quantified in this report. The jet fuel would disperse into the fast flowing water column and most of it would pass under any oil booms set along the shores and 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 the tidal flats that nourishes the migratory shorebirds. Additional Risk Acceptance Criteria that includes 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's us, the citizens and taxpayers of Metro Vancouver. Each affected municipality is obliged to provide 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 major challenge to prove it and collect on those damages, especially from tankers flying under a flag of convenience, because their liabilities are limited by international conventions. Also what is the non-profit VAFFC liable for? Will Air Canada and WestJet and the other airlines that formed VAFFC belly up to the bar and compensate society for their terrible planned fuel handling facility? Also the liabilities extend into the USA in that they have a legal right to fish a part of the Fraser River salmon runs and protect international migratory birds that belong to all of us on this 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 Vancouver area, condos bought near this proposed VAFFC terminal have indeed dropped since 2006 and any approval of any such tanker traffic and terminal facilities to handle such toxic and flammable fuels will further destroy property values. Who is to be held accountable for that real property and wealth loss and the needless stress caused to thousands of citizens in the area over the past two years? All these external liabilities were not factored into the total 60 year lifetime cost of this project to our communities when VAFFC was picking the option with "most merit". This proposed project is not viable, nor desirable. It's insane to allow it to proceed. VAFFC, a consortium owned by of 27 airlines with Air Canada as the major share owner, needs to use a minimum regret strategy instead 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 be smaller 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 a more environmentally friendly solution and will have fewer incidents. VAFFC will still be able to buy their jet fuel at spot market prices and have it delivered to the large deep sea fuel dock at

Cherry Point, WA terminal and then transported safely via pipeline to the Vancouver International Airport (YVR). The current maximum supply limit is 5.29 million liters per day (MMLD). BMB Fuel Consulting Services 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 same number of takeoffs and landings in 2011 as they had in 2002 (22), suggesting very little growth in 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 (the fuel 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 since the current 8" pipeline from Westridge terminal to YVR provides about 80% of the current need then 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 inches which would be rounded up to 14". A rough estimate for a 60 kilometer 14 pipeline and pumping stations via Blaine, WA, to the Cherry Point terminal is about $55,000,000 dollars (19, 20). The incremental increase in cost for providing a pipeline-only solution that eliminates potential jet fuel tanker traffic from the Fraser River Estuary as well as the current tanker and barge traffic from Cherry Point, WA via Burrard Inlet to the Westridge terminal offsets these huge external liabilities that do not impact VAFFC but 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 hazard footprints of the unloading process and storage of hazardous jet fuel into a tank farm plus river vessel traffic. Once done, PMV must provide the opportunity for the public and System Safety experts at arm's length to review and comment on it. Scaling up river traffic from small barges to giant Panamax tankers carrying hazardous liquid bulk makes an enormous difference. Getting rid of 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 for refusing to consider any other alternatives or even a single safer alternative. This is a major shortcoming in BC EA legislation and approach and does not serve the public interest properly and is yet another reason why the BC EA process has been so criticized and is largely ineffective in conducting a proper and responsible environmental assessment (EA). They have instead naively accepted an irresponsible concept for review which they have conducted in a piecemeal review 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 in this major environmental assessment shortcoming.

G. Conclusions: Unfortunately PMV has fostered a study to a very limited set of stake holders and refused public overview and the final product as completed by Det Norske Veritas is piecemeal and out of context 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 can cause an unbalanced review by PMV and the BC EAO in that the PMV is in an obvious conflict of interest in promoting more business for their port and running the Federal Environmental Assessment review of a project on their land that they would dearly like to see approved and then directing a study without public overview that erroneously indicates that shipping tankers of hazardous materials into the Fraser River, especially toxic and flammable jet fuel, is a low risk and acceptable activity. It is truly ironic that when VAFFC tried to ship jet fuel into the Fraser River Estuary in 1989, the proposal was soundly rejected by a Federal Review Panel process. Why in 2012 are we still considering 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 take a strong stand and squash this this insane proposal. It is a disaster waiting to happen within its 60 year life. Your grandchildren will thank you for it. Yours safely, Jim Ronback, P.Eng., (retired) Systems Safety Engineer 1530 Kirkwood Road, Delta, BC, V4L 1G1 604 948 1589

H. References and Additional Reading. 1) Evaluation of Fuel Delivery Options http://www.vancouverairportfuel.ca/files/Fuel%20Delivery%20Options%20Report.pdf 2) Marine Spill Response Options: The Manual http://www.iosc.org/papers_posters/01200.pdf 3) Freshwater Net Environmental Benefit Analysis http://www.epa.gov/oem/docs/oil/fss/fss06/eddy.pdf 4) "Pipelines are inherently safer to the public than other modes of freight transportation 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 about 22 fatalities per year. Fatalities from pipeline accidents are relatively low when compared with those from accidents involving other forms of freight transportation: On average, about 66 people die each year from barge accidents, about 590 from railroad accidents, and about 5,100 from truck accidents. While these statistics provide an indication of the relative safety of pipelines for transporting natural gas and hazardous liquids, the total number of major pipeline accidents (those resulting in a fatality, an injury, or property damage of $50,000 or more) increased by about 4 percent annually over this 10-year period. Most fatalities and injuries occurred as a result of accidents on pipelines that transport natural gas to homes and businesses (primarily intrastate pipelines), while most property damage occurred as a result of accidents on pipelines transporting hazardous liquids (primarily interstate pipelines). Furthermore, pipelines that transport hazardous liquids account for nearly eight times as many major accidents per mile of pipeline as do pipelines that transport natural gas to homes and businesses. The Office of Pipeline Safetys data on the causes of pipeline accidents are limited to a few categories, but these limited data indicate that damage from outside forces, such as excavation, is the primary 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 ).

Table 1: Relative Occurrence of Transportation Accidents Per Ton-Mile of Oil Transported, 1992-97

Event Fatality Injury Fire/explosion

Pipeline* 1.0 1.0 1.0

Rail 2.7 2.6 8.6

Tank ship 4.0 0.7 1.2

Barge 10.2 0.9 4.0

Truck 87.3 2.3 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

5) Microbial Communities Changed After Deepwater Horizon Spill http://www.newswise.com/articles/view/590091/?sc=dwhr&xy=10000760 . 6) Shipping aviation fuel, canola on the river low-risk: Port Metro Vancouver report By Jeff Lee, Vancouver Sun June 8, 2012 http://www.vancouversun.com/technology/Shipping+aviation+fuel+canola+river+risk+Port+Met ro+Vancovuer+report/6754852/story.html . 7) Miami International Airport fuel tank farm fire could mean massive airline delays http://www.wptv.com/dpp/news/state/miami-international-airport-fuel-tank-farm-fire-couldmean-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, 1980 http://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=9100CIY1.txt . 10) The quantitative risk of oil tanker groundings - MIT Masters Thesis http://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 accidents http://www.sciencedirect.com/science/article/pii/S0950423005000641 http://www.youtube.com/watch?v=S40RcLsar-g . 12) The following scenarios, for consideration in the VAFFCs expanded System Safety review, are adapted from:

"In December 1997, Camp Dresser & McKee Inc. conducted a hazard analysis of the potential for fire and/or explosion at the LAXFUEL Fuel Farm. The following worst-case scenarios for fire 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 to remain intact. Scenario 2: This scenario could be initiated from Scenario 1. If the fire was not immediately controlled, the heat caused by the contained flames could result in the rupture (with possible explosion) 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 berth or a pipeline from the terminal or a collision between vessels or with obstacles in the Fraser River 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 system surrounding 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 fire within 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 explosion could 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 a kerosene type fuel, made up of hundreds of different hydrocarbons. Due to the physical properties of Jet A fuel (e.g., low volatility and low explosion potential), an explosion would only be expected under confined conditions and as flame speeds associated with Jet A fuel are not conducive to detonation, the probability of explosion is very low, but not negligible http://www.ourlax.org/docs/draft_eir_NE/T14c_LR.pdf page 7. 13) Office of Exxon Valdez Oil Spill (EVOS) Damage Assessment and Restoration http://www.fakr.noaa.gov/oil/ 14) A Probabilistic Analysis of Tanker Groundings http://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 of beach 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

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 - 2002 http://research.dnv.com/skj/Papers/SkjValencia.pdf . 19) Regression models estimate pipeline construction costs http://www.ogj.com/articles/print/volume-109/issue-27/transportation/regression-modelsestimate-pipeline-construction._printArticle.html . 20) North American Pipeline Construction Cost http://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 criteria Pierre C. Sames and Rainer Hamann, Germanischer Lloyd AG, 2009 http://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.pdf page 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.

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