Failure to Protect Life Safety by Kinder Morgan Canada’s Chief Operating Officer by the Indiscriminate Use of the Company Cost-Cutting Policy

Evidence of Kinder Morgan Canada’s Chief Operating Officer’s use of the Trans Mountain Company “No Seismic Upgrades of Existing Tanks” policy to ignore all Structural Design Upgrades and specific warnings of premature tank failures under earthquake loading that occur after the original tank construction. (ie: The Structural Design Code in 1953 is also the last structural design requirements for the 1953 tanks.)

Evidence of Kinder Morgan Canada’s Chief Operating Officer’s responding to alleged serious deficiencies in the company’s structural assessment of the existing Burnaby Terminal oil storage tanks while not qualified by his registration or License to Practice in British Columbia as a Structural Engineer.

Evidence of Kinder Morgan Canada’s Chief Operating Officer’s refusal to identify the Firm’s Structural Engineer responsible for the design of the TMEP Expanded Burnaby Terminal and refusal to forward alleged serious design deficiencies to that Engineer. This refusal policy started with my Nov 2017 “Questionnaire” extending to Apr 2019 by refusal to respond to Access to Information Requests I made to Trans Mountain Corporation, “answered” by Trans Mountain Canada Inc, a Company not governed by Federal ATI legislation.

We add as evidence Kinder Morgan Canada’s Chief Operating Officer’s 400+ page “letter” to the National Energy Board dated _____ for relief from the Fire Protection Requirements in the PLC Report titled ” ” – rejecting the Industry Best Practice Fire Protection Requirements for clearly legislated requirements at the time the tank was constructed. The Company’s clearly expressed policy was that any subsequent upgrades to the Fire Protection Requirements after tank construction do not apply for existing tanks. An indiscriminately applied policy to every upgrade without consideration whether it was a life safety issue. I am not qualified to comment on each relief claim against the PLC Report but I’m positive an engineer can’t claim indiscriminately for relief from every fire protection upgrade. Kinder Morgan Canada’s Chief Operating Officer used the same policy for structural code upgrades after the tanks were constructed.