Port of Anchorage Fuel Terminal. Fire Hazard Calculations. 100% Submittal

Transcription

1 Port of Anchorage Fuel Terminal Fire Hazard Calculations 100% Submittal Coffman Project # April 2016

2 Table of Contents: Fire Hazard Calculations 1. Summary General Site Conditions Fire Scenarios Heat Flux Hazard Thresholds Computational Fluid Dynamics (CFD) Calculations CFD Modeling Input Criteria Heat Flux based upon Shokri and Beyler (Shaped Based) Detailed Calculations NIST Acceptable Separation Distance Calculations

3 1. Summary This report provides a review of the expected heat-flux at various distance from the fuel terminal based upon the worst-case pool fire estimated by Crowley and the potential hazards to the surrounding area. The worst-case pool was based upon the complete failure of the largest tank on-site and the resulting combustible liquid contained within the dyke area. Three different calculation methods were utilized to evaluate the expected heat release rates: 1. Computational fluid dynamics (CFD) model utilizing Fire Dynamics Simulator (FDS) Software (with and without wind from the north) 2. Shokri and Beyler (Shaped Based) Detailed Calculations 3. NIST Acceptable Separation Distance Calculations It is recommended that the results of the FDS model be viewed as the most accurate since they accommodate the specific geometry of the site. This report recommends that the distances provided by the FDS model be doubled to provide a safety factor of two. This practice matches the recommendations of the NIST Acceptable Separation Distance Calculations. Fire Simulation Recommended distance from edge of fire * Quasi Steady State Heat-Flux Potential Hazard Wood Ignition < 50-feet 25.0 kw/m2 Fatality Exposure Injury Exposure > 50-feet 12.5 kw/m2 > 100-feet 9.5 kw/m2 4.0 kw/m2 No hazard > 200-feet 1.6 kw/m2 The minimum energy required to ignite wood at indefinitely long exposure This value is typically used as a fatality number. Heat flux required to raise a bare steel plate, insulated on back, to 300 C/572 F. The minimum energy required for piloted ignition of wood, and melting of plastic tubing. Sufficient to cause pain in 8 seconds and 2nd degree burns in 20 seconds. Sufficient to cause pain to personnel if unable to reach cover within 20 seconds. However, blistering of skin (second degree burns) is likely; 0% lethality Will cause no discomfort for long exposure Note that a detailed review of the other requirements of NFPA and API (i.e. dike design, tank supports, emergency venting, process piping, and fire suppression systems) are beyond the scope of this report. In addition, this report does not take into account any potential impact due to explosions. 3

4 Fire Hazard Calculations 100% Submittal 25 April 2016 Figure 1 - Simplified hazard zone map based upon FDS model with 2x safety factor 4

5 2. General Site Conditions The fuel terminal is located adjacent to a residential area to the south. There is a significant change in elevation/grade between the two areas. A basic summary of tank sizes is provided below for reference. All tanks are fixed cone-roof type without internal floating roofs. Tank # Diameter Height Safe Fill Product Stored ft 47-ft 89,941 bbl JP ft 48-ft 42,110 bbl JP ft 48-ft 17,248 bbl JP ft 48-ft 36,844 bbl Standby for spill response ft 46-ft 88,831 bbl JP ft 48-ft 61,262 bbl Standby for spill response ft 48-ft 46,087 bbl JP ft 48-ft 61,262 bbl JP ft 48-ft 61,262 bbl JP ft 47-ft 89,864 bbl JP ft 48-ft 91,854 bbl JP-8/SPCC Tank ft 48-ft 36,844 bbl JP ft 56-ft 93,351 bbl JP ft 56-ft 93,351 bbl JP ft 56-ft 60,279 bbl JP ft 56-ft 93,351 bbl JP-8 5

6 Figure 2 Reference site plan. Green line is top of containment wall/berm. Red line is the outline of the expected liquid level from the complete failure of a single tank (image from an Enterprise Engineering report) 6

7 2.1. NFPA 30 - Prescriptive Tank Shell-to-Shell Spacing The sole product being stored is JP-8. Since it has a flash point above 100 F (37.8 C), the product is defined as a Class II Combustible liquid per NFPA NFPA Table provides prescriptive recommendations for tank spacing as summarized below. Table Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks Tank Type Fixed Tank - Class II Liquids All tanks not over 150-ft in diameter 1/6 x sum of adjacent tank diameters but not less than 3-ft Based upon a review of the civil drawings, the existing tank layout meets these minimum requirements Active Fire Suppression Systems All tanks are currently protected by a manually operated 3% AFFF foam-water system applied over the entire interior surface of the tank. The system is fixed and does not require any mobile equipment to be manually connected prior to delivering foam to the tanks. The quantity of on-site foam-concentrate storage is approximately 2,200 gallons. 1,100 gallons of this foam is stored in barrels as backup. 1,100 gallons provides sufficient delivery time to comply with NFPA requirements. 3. Fire Scenarios For these fixed cone-roof tanks without internal floating roof, the worst-case fire scenarios considered was the complete failure of the single largest tank and the resulting combustible liquid within the containment area. Ignition of the spill would subsequently result in the pool fire considered in this report. It should be noted that any accidental discharge in the diked area would be expected to be immediately noticed and the total volume of spill is expected to much less than the total volume of a tank. While not reviewed by this report, the consideration of a potential tank-top fire is a typical second fire scenario. A tank-top fire would be much smaller in size and therefore the containment area pool fire covered by this report is the worst-case condition. In addition the site has fixed foam suppression on all tanks and with prompt response by personnel, a tank-top fire should be contained to a small fire. Figure 3 - Expected pool size due to a 105,300 Barrel Spill (image from an Enterprise Engineering report) 7

8 4. Heat Flux Hazard Thresholds The key measurement in determining the potential hazard from a fire is the heat flux at the surface of adjacent materials/equipment. Heat flux is the rate of heat energy transfer through a given surface. The following thresholds provide general guidance on the impact of heat flux at various levels. Heat Flux Potential Hazard 37.5 kw/m 2 Sufficient to cause damage to process equipment and tanks (1) 32.0 kw/m 2 Loss of strength of structural steel exposed to the fire to an extent that its primary load-bearing capacity is reduced significantly over the duration of LNG fire being analyzed. (3) 25.0 kw/m 2 The minimum energy required to ignite wood at indefinitely long exposure (1) 12.5 kw/m 2 Heat flux required to raise a bare steel plate, insulated on back, to 300 C/572 F. The minimum energy required for piloted ignition of wood, and melting of plastic tubing. This value is typically used as a fatality number. (1) 12.0 kw/m 2 Additional cooling should be provided to prevent ignition (4) 9.5 kw/m 2 Sufficient to cause pain in 8 seconds and 2nd degree burns in 20 seconds. (1) 8.0 kw/m 2 Potential ignition of crude oil (4) 5.0 kw/m kw/m kw/m 2 At least 10 persons would suffer second-degree skin burns on at least 10% of their bodies within 30 seconds of exposure to the fire. (3) At least on person inside the building would suffer second-degree burns on at least 10% of the body within 30 seconds of exposure to the fire. (3) Sufficient to cause pain to personnel if unable to reach cover within 20 seconds. However, blistering of skin (second degree burns) is likely; 0% lethality (1) No pain was shown, regardless of the exposure duration for thermal fluxes below 1.7 kw/m 2 (2) 1.6 kw/m 2 Will cause no discomfort for long exposure (1) 1.0 kw/m 2 Approximate solar constant on a clear summer day These numbers were obtained from the following sources: (1) Guidelines for Chemical Process Quantitative Risk Analysis, Second Edition, page 269, American Institute of Chemical Engineers Center for Chemical Process Safety (CCPS), (2) SFPE Handbook, third edition, chapter 11 page (3) NFPA 59A-2016 Table Radiant Heat Flux and Thermal Dosage Outside the Plant Boundary include the following recommendations: (4) BP, EI, Lastfire studies for crude oil (5) 49 CFR, Part 193 (Liquefied natural gas facilities: Federal Safety Standards) Thermal radiation protection. 8

9 5. Computational Fluid Dynamics (CFD) Calculations The CFD calculations in this report have been completed utilizing the Fire Dynamics Simulator (FDS) software, developed by the National Institute of Standards and Technology (NIST). The Fire Dynamics Simulator (FDS) is the most peer-reviewed and experientially verified software available. A CFD model provides the most realistic model as it accounts for wind (flame leaning), convective heat transfer, and detailed information on all sides/surfaces of the tanks. A summary of the worst-case heat-flux values measured along a north-south axis centered between tanks 32 and 33 are shown in the table below. Two models were run: one with no wind and one with a 16 mph wind from the north. Thermocouples spaced along this axis at 10-meters on-center starting at the edge of the containment berm. Figure 4 Location of heat-flux measurement points (two separate views) Distance from edge of source to target Radiant Heat Flux with a 16 mph wind from the North* Radiant Heat Flux with No Wind* 33 feet 7.80 kw/m kw/m2 66 feet 3.63 kw/m kw/m2 98 feet 1.96 kw/m kw/m2 131 feet 1.35 kw/m kw/m2 * All measurements are Quasi Steady State Heat-Flux averaged from 30 to 60 seconds after simulation has stabilized. 9

10 Figure 5 Visual of model entered into FDS Figure 6 Visual of smoke from FDS with 16 mph wind from the north 10

11 Fire Hazard Calculations 100% Submittal 25 April 2016 Figure 7 Overlay of radiant head flux from FDS and aerial photo with no wind Note that due to the visual rendering this color presented are for horizontal surfaces only. Vertical surfaces experience higher heat fluxes due to the geometery. For display purposes all values over kw/m2 are represented with the same color (e.g. heat fluxes greater than 12.5 kw/m2 are present). 11

12 Fire Hazard Calculations 100% Submittal 25 April 2016 Figure 8 Overlay of radiant head flux from FDS and aerial photo with 16 mph wind Note that due to the visual rendering this color presented are for horizontal surfaces only. Vertical surfaces experience higher heat fluxes due to the geometery. For display purposes all values over kw/m2 are represented with the same color (e.g. heat fluxes greater than 12.5 kw/m2 are present). 12

13 6. CFD Modeling Input Criteria 6.1. Atmospheric Wind Speeds and Direction Historical wind data was reviewed for the project site and incorporated into the model. Wind direction varies significantly depending upon the season. The worst-case condition of a prevailing wind from the North blowing at 16 mph (7.15 m/s) towards the residential area was used in the CFD model based upon conservative historical data for the area. 13

14 6.2. Heat Release Rate per Area (HRRPUA) of JP-8 The heat release rate of a fire is the best measure of its potential to do harm. This section provides backup reference for the source of data used in the model and any experimental data to validate the results. JP-8 is a Kerosene based jet propellant. As such where detailed chemical / thermal proprieties were not available, those from Kerosene were applied. For our specific model, the speed at which the fire will ramp-up or how long it will burn does not matter in this evaluation as we are only interested in the worst-case heat-flux expected adjacent to the fuel terminal. It should also be noted that the analysis of hazardous liquid fires is relatively independent of the type of liquid; burning rates and heat release rates do not vary significantly from fuel to fuel, nor does the nature of the fire. As such if in the future the type of fuel is slightly different than that modeled, there is limited impact on the calculation results. Extensive large-scale open pool fire experiments utilizing JP-8 were conducted by Sandia National Laboratories (SNL) around 2008 (Blanchat, T. and Figueroa, V., Large-Scale Open Pool Experimental Data and Analysis for Fire Model Validation and Development. Fire Safety Science 9: doi: /iafss.fss.9-105). The results of this testing have been utilized as inputs for the modeling of the pool fire. The SNL testing included am 8-meter diameter pool fire with a 5.76 m/s wind speed that resulted in a Pool Surface Heat Flux of 97 kw/m2. Numerous other NIST tests of large scale pool fires have an average surface heat flux of 100 kw/m2. Our model is utilized the 97 kw/m2 number. From the NIST report Thermal Radiation from Large Pool Fires a steady-state HRRPUA (q f) value of 1,700 kw/m 2 was utilized in the CFD model. 14

15 6.3. Mesh Size The entire model has dimensions of X:305-m [1,000-Feet], Y:470-m [1,542-Feet], Z:160-m [525- Feet]. The model will be divided up into 2,099,520 cells with an approximate cubic dimension of 2.2-meters (7.22-feet). A mesh sensitivity study was conducted with smaller mesh sizes, but had no appreciable differences in results were noted beyond this size. The cell size (dx) for a given simulation can be related to the characteristic fire diameter (D*), i.e., the smaller the characteristic fire diameter, the smaller the cell size should be in order to adequately resolve the fluid flow and fire dynamics. A reference within the FDS User Guide (Verification and Validation of Selected Fire Models for Nuclear Power Plant Applications. NUREG 1824, United States Nuclear Regulatory Commission, 2007) used a D*/dx ratio between 4 and 16 to accurately resolve fires in various scenarios. From the FDS User Guide: These values were used to adequately resolve plume dynamics, along with other geometrical characteristics of the models as well. This range does not indicate what values to use for all models, only what values worked well for that particular set of models. The 2.2-meter cell size correlates to a D*/dx ratio of Simulation Duration As the FDS model essentially has no ramp up time for the fire, the model only needs to be run until the heat flux has quasi stabilized. Based upon several different simulations, the analysis only needed to be run for at least 30 seconds before becoming quasi steady state. A total simulation time of 60-seconds was used to be conservative. 7. Heat Flux based upon Shokri and Beyler (Shaped Based) Detailed Calculations As a validation check of the outputs from the CFD model, a traditional shape based source heat flux calculation was performed based upon the Shokri and Beyler detailed method. This type of calculation is algebraic in nature and ignores convection. Known issues with this type of model area as follows: 1. Wind is not taken into consideration 2. Limited accuracy for pool fires over 50-meters in diameter because no experiments of this size have been performed for validation. 3. Under estimates radiation to near-field targets 4. Over estimates radiation to far-field targets The output of the calculations for this specific site are summarized below: Distance from edge of source to target Estimated heat flux at target 33 feet kw/m2 244 feet 1.6 kw/m2 15

16 8. NIST Acceptable Separation Distance Calculations Another guideline for determining the radiation from a fire comes from the Department of Housing and Urban Development (HUD) Regulation 24 CFR Part 51, Subpart C which is titled Siting of HUD-Assisted Projects Near Hazardous Operations Handling Conventional Fuels or Chemicals of an Explosive or Flammable Nature. Specifically paragraph of this section states the following recommendations: (a) Thermal Radiation Safety Standard Projects shall be located so that: (1) The allowable thermal radiation flux level at the building shall not exceed 10,000 BTU/sq ft per hour [31.5 kwh/sq m] (2) The allowable thermal radiation flux level for outdoor, protected facilities or areas of congregation shall not exceed 450 BTU/sq ft per hour [1.4 kwh/sq m] These recommendations basically flow the same guidelines as noted in section 4 of this report. The recommended calculation method for the ASD comes from the National Institute of Standards and Technology (NIST) report from Nov 2000 Thermal Radiation from Large Pool Fires. A basic summary of the recommendations of this report is noted in the tables below. Note that these numbers are very conservative so as to provide a simplistic base line when doing an initial review of a site. It is estimated that these numbers have at least a two-times safety factor. Simplified NIST Thermal Radiation from Large Pool Fires Table 1 Mass Burning Heat of HRR Per Unit ASD to Liquids Rate Combustion Area Kg/m 2 / s kj/kg kw/m 2 Structures* Kerosene ,200 1, meters 50 feet ASD to People* 400 meters 1312 feet * The ASD noted is the distance beyond which the thermal radiation flux criteria is satisfied, regardless of fire size. Calculated Radiant Heat Flux based upon NIST method Estimated heat flux of source Distance from edge of source to target Estimated heat flux at target 100 kw/m2 (no obstructions between source and target) Beyond scope of equation 107 feet 31.5 kw/m kw/m2 H/D = kw/m2 (substantial thermal barrier between source and target) H/D = feet 1.6 kw/m2 Beyond scope of equation 31.5 kw/m2 53 feet 12.5 kw/m2 296 feet 1.6 kw/m2 16

17 Fire Hazard Study GHCC Review Comments/Reponses, September 2016 # Comment Response 1 Fire Dynamic Simulation (FDS) 1.a Radiant Heat Flux at burning pool edge - Figure 2 shows a red line indicating the expected liquid level, or pool size, from the modeled tank failure. Why do the FDS calculations show zero kw/m2 at the southeastern edge of the pool fire under no wind conditions (Figure 7) and many pockets of zero kw/m2 with a 16 mph wind (Figure 8)? Figures 7 and 8 are snapshots of the model at a specific split-second of the model simulation and the images are not averaged over any amount of time. As such, they provide an easy to understand visual of general heat-flux location, but not necessarily average heat flux anticipated. To address the variation of the visual representation, point measurement devices have been utilized (referenced as thermocouples for the purposes of this report). The thermocouple data has been averaged over 30-seconds and better accommodates for the volatility of the burning pool fire. Please reference the table on page 9 of the report for expected heat-flux values at different points from the pool fire. In regards, to the lack of heat flux in Figures 7 (no wind), there is the significant shielding by tanks 2, 29, and 30 and therefore minimal heatflux in this corner (i.e. line-of-sight situation). Also when the pool fire outline is converted to cubes within the FDS model, there is some accuracy lost due to mesh size (see section 6.3 of the report for further discussion). Since the pool depth between tanks 2 and 29 is very shallow, the model correlates this small area to be ground and not the pool fire which also reduces the heat-flux in this corner of the model. The FDS thermocouple readings located between tanks 33 and 32 are not affected by this minimal reduction in pool fire size. In regards to the blank spots on Figure 8 (16 mph wind), this is a result of the significant volatility of these pool fires and the specific split-second time the snapshot was taken.

18 Fire Hazard Study GHCC Review Comments/Reponses, September b Radiant Heat Flux on Vertical Surfaces - Figures 7 and 8 note that the visual rendering illustrates heat flux for horizontal surfaces only but that vertical surfaces (not shown) experience higher heat fluxes due to geometry. Because of the close proximity of the bluff and homes on top important vertical or near vertical surfaces could be presented to the fire face. Please interrogate the modeling results with and without wind to see if sufficient energy is released to cause vegetation on the steep bluff side to ignite or the north sides of homes on the bluff edge to burn. 1.c Radiant Heat Flux and Wind there appears to be very little difference in modeling results between Figure 7 with no wind and Figure 8 with 16 mph wind. What is the elevation of these horizontal slices, are they the same? Does the radiant flux stay roughly centered on the tank farm at all elevations under the modeled wind condition? The limitations of Figures 7 and 8 are addressed by utilizing thermocouples within the model located at 10-feet above-grade and located every 33-feet (10-meters) as shown on page 9 of the report. As discussed in item 1.a above, the thermocouple measurements provide a better indication of the expected heat flux. Page 9, section 5 provides expected heat fluxes at different distances and addresses the potential impact on the bluff and houses. Figures 7 and 8 are not slices, but a snapshot of the heat flux through the surfaces boundaries within the model. As such there is no elevation and they are the same measurement points. The tilting of the flames is fairly limited due to the significant amount of tanks creating shielding of the flames. See attached additional figures, with and without wind, which show an approximation of the flame locations based upon the FDS model. See response to item 1.d below for additional discussion of flame representation. 1.d Radiant Heat Flux Visual Representation Figure 6 showing the smoke plume is a helpful image which would be easily understood by residents of the neighborhood. From the modeling results would it also be possible to similarly illustrate the Heat Flux plumes for injury, fatality, and wood ignition, with and without wind? The FDS software can provide a visual representation of the Heat Release Rate Per Unit Volume (HRRPUV). Attached are several snapshots at different times, with-andwithout wind, for reference. We typically don t include these images as they are slightly misleading since the HRRPUV is not an exact representation of the luminous flame.

19 Fire Hazard Study GHCC Review Comments/Reponses, September e Simplified Hazard Zone Map please provide the modeling contours overlaid on the site map for the three critical heat flux hazards (wood ignition 25.0 kw/m2, fatality 12.5 kw/m2, and injury 4.9 kw/m2). Please then explain what distances were doubled (for the 2x engineering model uncertainty factor) to arrive at the Simplified Hazard Map Figure 1. Figures 7 and 8 are basically the contour heatflux map overlaid the site map. However, these figures are only applicable for the single pool fire modeled and should not be over analyzed. Please reference response to item 1.b for discussion on why the thermocouple point measurements provide a more accurate representation of the expected heat flux. Please reference response to item 1.f for discussion of the 2x safety factor applied to the FDS results. 1.f Appropriate Engineering Model Uncertainty Factor please provide references which cite that 2x modeling results is suitable for overcoming FDS model limitations to assess impacts on the general public and private residences. The FDS results fairly closely match the Shokri and Beyler method. The Shokri and Beyler meathod is referenced in multiple standards and recommends a safety factor of 2x when used in design. This is the basis of the recommended 2x safety factor recommended in the report. References can be found within the following: NFPA Handbook (12 th edition) section 3, chapter 9 (page 3-156) SFPE Engineering Guide for Assessing Flame Radiation to External Targets from Pol Fires (June 1999) SFPE Journal of Fire Protection Engineering Vol 1, No 4, 1989, Radiation from Large Pool Fires

20 Fire Hazard Study GHCC Review Comments/Reponses, September a NIST/HUD Modeling of Acceptable Separation Distances FDS vs. HUD - the report states that modeling methods and allowable radiant heat flux levels used by the US Department of Housing and Urban Development in their CFR Regulation 24 Siting of HUD-Assisted Projects near Hazardous Operations Handling Conventional Fuels of Chemicals of an Explosive or Flammable Nature are similar to the FDS approach. However, the radiant heat flux contours calculated by the HUD approach indicate harm to people well inside the boundaries of the neighborhood. Please provide an overlay map of the neighborhood comparing the key contours of both approaches and describe why the HUD method is deemed inappropriate given the limitations of both approaches and the higher standards required when dealing with engineering uncertainty and the public. As noted on page 16, the HUD method is very conservative so as to provide a simplistic base line when doing an initial review of a site. It is estimated that these numbers have at least a two-times safety factor. HUD s general guidance is if you can meet their simplified procedures, then a more detailed calculation is not required. The site does comply with the HUD ASD recommendation of 50-feet for structures (see simplified NIST Thermal table on page 16). However, the site does not comply with the 1,312 foot ASD recommendation for people. As such, HUD recommended their more detailed calculation method which resulted in a minimum fatal exposure distance of 107-feet. When the 2x safety factor included in the HUD method is removed, we arrive at the same recommended fatal exposure distance of approximately 50-feet. As basic comparison of the agreement all three methods within the report is provided below: Distance from edge of source target FDS values with 2x safety factor FDS 16 mph wind Shokri and Beyler method NIST method without barrier and no 2x safety 33-feet feet (Max 12.5 for range) 66-feet feet (Max 4.0 for range) 244-feet

21 Fire Hazard Study GHCC Review Comments/Reponses, September a Fuel type JP8 vs. Gasoline, etc. the report states that, "the analysis of hazardous liquid fires is relatively independent of the type of liquid" and, "if in the future the type of fuel is slightly different than that modeled, there is limited impact on calculation results". The modeling was done for jet fuel JP8 (kerosene). Specifically, would gasoline, naphtha or any other flammable liquid product stored in bulk by any other operator at the Anchorage port tank farms result in a more adverse impact on the neighborhood (i.e. anything with characteristics more than slightly different from JP8)? 4 Fire Suppression 4.a Required Foam Quantity what is the surface area of the modeled pool fire? How much foam concentrate is required to suppress a pool fire of that size and shape? If the first foam suppression effort fails, how much foam concentrate remains for a second attempt. This statement matches the findings from the NIST Thermal Radiation from Large Pool Fires report. As the burning rates and heatrelease rates do not vary significantly, the models provided can be used for a variety of products. As quick summary of the burning rates and heat-release rates for a couple sample products is provided below: Material Heat- Burning Release Rate kg/m 2 rate /s kw/m 2 JP ,200 JP ,300 Gasoline ,400 The approximate surface area of the worst-case pool evaluated was approximately 124,560 sq ft. This was based upon a pool fire due to complete failure of the largest single tank within the containment area. The exact amount of foam-concentrate required to suppress a fire of this size is difficult to establish absolutely based upon historical fire scenarios. The goal should be to contain vs. suppress if the fire reached the size to cover almost the entire site. 2,200 gallons of foam is stored on-site for the purposes of suppressing any tank-top fire scenario with a safety factor of at least two. 4.b Required Fire Water Rate what is the rate of water required to be mixed with the foam concentrate to suppress the modeled pool fire? What is the delivery rate of the fire hydrants adjacent to the site? If there is not enough water supply from the municipal system (this was a finding of the conflagration desktop drill) what is the backup plan? Is the backup plan codified with formal Inter-Governmental, Inter- Agency, or Government-Industry agreements? The city hydrants in this area can provide roughly 3,000 gpm in this area. As noted above, a complete pool fire due to complete failure of the largest single tank will be a containment plan and not a suppression plan. The worst-case tank combined foam-water flow rate of 1016 gpm is required for tank-top fire at tank 32 based upon as-builts. We would also assume two individual monitors flowing 750 gpm each (1,500 gpm total) for cooling of exposed tanks for individual tank fires. Combined this is a flow rate of 2,516 gpm at the available water supply is adequate for these type of fire.

22 Fire Hazard Study GHCC Review Comments/Reponses, September Risk Mitigation Measures 5a. The original Hazard Study indicated the importance of risk mitigation measures as the key barrier to adverse consequences on the neighborhood. Listed in Table 5.2 are the 118 risk mitigation measures identified. It was also noted that keeping up to date on industry standards and best practices will insure the safest possible operation. Assurance of Regular Monitoring what is Crowley s plan for periodically updating compliance with Table 5.2 and reporting status to the Community Council? 5b. Continuous Improvement what is Crowley s plan for maintaining pace with the evolution of industry standards and the acquisition and implementation of best practices with regard to the identified measures? Crowley s management system includes regular on-going facility inspections to assure compliance with regulatory requirements, industry best practice and safety. As part of the current expansion project at the Terminal we are eliminating all underground pipelines. Crowley keeps the GHCC informed and up to date with activities at the Terminal through attendance at regularly held council meetings and presentations/briefings as requested or needed. Crowley can provide annual updates to the GHCC reflecting operational integrity and regulatory compliance. Crowley is affiliated with several national and international industry organizations, including the National Institute for Storage Tank Management, the American Petroleum Institute, and the International Facility Maintenance Association. Through these many professional connections Crowley takes advantage of ongoing educational opportunities, resources, and training seminars about the operation, regulation, and management of tank farm systems, industry standards, and best practices.