Kinder Morgan’s Expansion Project will triple the storage capacity of the existing Burnaby Mountain Tank Farm to over 5 million barrels, stored in 12 existing and 14 new oil storage tanks. Nine of the existing 1953 tanks are now 66-years-old, designed to American Petroleum Institute (API) requirements for internal water pressure only, similar to a water tank. No lateral wind or seismic loads. Seismic or earthquake loading wasn’t introduced until the API 1980 Edition.

Six of the 9 – 1953 tanks are external floating roof (EFR) type. The remaining 3 are internal floating roof (IFR) type. The EFR tanks don’t have metal roofs and deflect horizontally during earthquakes, inducing additional sloshing forces. Failure of EFR tanks occurs as the tank deforms, when oil is ejected onto the floating roof or over the tank wall. Serious petroleum fires can be ignited by sparks from impact of the floating roof against tank walls. The IFR tanks have fixed metal roofs and much lower horizontal deflection during earthquakes and lower sloshing forces. Failure of IFR tanks occurs when the tank walls buckle, usually just above the foundation and in the wall below the roof.

The last 3 existing tanks are IFR type, added in 1988.

Kinder Morgan’s (KM) Structural Design Engineer ignored all the possible deficiencies of the 1953 tanks – to verify the seismic capacity of the tanks and foundations, the capacity of existing welds, steel material yields, whether the steel was weld-able and verifying the capacity of the original soils cut and fill foundation under earthquake loading. Instead KM’s Structural Engineer followed Trans Mountain Company policy to ignore seismic capacity requirements of existing tanks and all the other possible deficiencies listed above. He or she designed only the new tanks that tripled the Tank Farm storage capacity. KM’s Structural Engineer didn’t consider the Life-Safety risk for the surrounding residents, the students and staff at SFU and Forest Grove Elementary and the residents of UniverCity. KM’s Structural Engineer chose to increase the hazardous material storage capacity while ignoring EFR tank failures in seven earthquakes between 1964 and 2011 and five serious fires ignited during these earthquakes.

KM’s Structural Engineer’s most serious structural design error: To ignore specific warnings that all pre1970 design EFR tanks on the US West Coast be investigated for possible sloshing failure. (Pacific Earthquake Engineering Research Centre (PEERC), California, Dec 2000 Report) The warning was issued after the initial failure of 6 1961 EFR tanks in the 1999 M7.4 Kocaeli Earthquake at the Tupras Refinery in Turkey that started a near catastrophic 5-day fire that destroyed over 30 petroleum storage tanks. This warning also applied to the West Coast of North America and was repeated in the proceedings of the 2004 World Conference on Earthquake Engineering (WCEE).

The 1961 tanks at the Tupras Refinery were designed by a Californian Structural Engineering firm for seismic design loading of either the 1956 City of Los Angeles Code for 0.133g or 1959/60 SEAOC for 0.10g. The Tupras EFR tanks failed by excessive sloshing at 0.322g over a 45 second duration. The warning applied to the 6 1953 EFR tanks in the Burnaby Mt. Tank Farm that were not designed for seismic loading. The 1953 EFR tanks were definitely a serious seismic risk that had to be investigated by Kinder Morgan’s Structural Engineer to protect the Life-Safety of the population in the surrounding community.

The 1961 tank failures also led to development of a computer design analysis and Site testing procedures that replicated the Tupras EFR tank failure by excessive sloshing. This new design procedure for EFR tanks was issued in the proceedings of the 2008 WCEE by Yazici and Cili. Kinder Morgan Canada’s Management refused to forward to their Structural Engineer, the questions I raised in Nov 2017 about the 1999 Tupras Refinery EFR tank failures and the PEERC warnings. I’ve made the obvious assumption that Kinder Morgan’s Structural Engineer ignored the serious seismic risk of the 1953 EFR tanks in the existing Burnaby Mt. Tank Farm and designed the new TMEP tanks to increase storage capacity from approx. 1.6 Million to over 5.0 Million barrels of hazardous material.

Kinder Morgan Canada (including Trans Mountain Canada Inc) failure to act on their 1953 EFR tank failure warning and failure to notify the City of Burnaby, Burnaby’s Fire Chief, Simon Fraser University and the NEB of the possible serious seismic risk is unconscionable. But to propose a three fold expansion in the TMEP is far beyond unconscionable.

The second serious structural error by Kinder Morgan and their Structural Engineer: is, I believe, the falsification of the Seismic Risk Assessment for the Burnaby Terminal (Burnaby Mt. Tank Farm) in Kinder Morgan’s TMEP Appendix B2, issued in Feb 2017. Kinder Morgan claims that they analyzed all existing and new storage tanks in their TMEP App. B2 Seismic Assessment Report, a report that concludes only a minor seismic risk of a tank explosion during an earthquake (Fig 13-9, page 124). Yet Kinder Morgan’s Structural Engineer ignored the warnings for 1953 EFR tank failure and followed the Trans Mountain policy to ignore the seismic capacities of existing tanks. Kinder Morgan’s Chief Operating Officer for the TMEP Mr. Hugh Harden, PEng, verified on a 12 Dec 2017 email that ” the focus of the risk assessment is structural failure resulting in loss of primary containment, rather than on sloshing effects. As corroborated by the assessments of damage from the Kocaeli earthquake, sloshing damage does not typically result in loss of primary containment and over-topping spills resulting from sloshing are much smaller than those resulting from shell or piping failures”.

Mr. Harden, in his 12 Dec email, describes the structural failure of IFR tanks, not EFR tanks. The analysis in the TMEP Appendix B2 shows KM only analyzed the seismic risk of the new IFR tanks. KM Appendix B2 ignored the sloshing failure analysis for the 6 1953 EFR tanks plus the seismic risk of the 6 existing IFR tanks (3 1953 and 3 1988 IFR tanks).

Kinder Morgan’s claim that Appendix B2 Burnaby Terminal Seismic Risk Assessment included all existing and new tanks is FALSE. Kinder Morgan has manipulated the seismic risk to minimize the clear and potentially substantial seismic risk of the 1953 EFR tanks. Contrary to Mr. Harden’s opinion, EFR tanks failed by sloshing in 7 earthquakes (1964 – 2011) with devastating fires burning out-of-control for 2 to 14 days and toxic smoke. The emergency fire response for the Tupras Tank Farm fire included airplane drops of foam, 98 fire trucks, an evacuation of everyone except fire response for a 3 km radius and the flames were visible on satellite photos.

(See the Section on Tupras Tank Failures in the 1999 Mw7.4 Kocaeli Earthquake)

The third serious error, this time by Kinder Morgan Canada’s Management, was challenging Canada’s National Fire Code requirements for the expanded Burnaby Terminal that included the 9 – 1953 Oil Storage Tanks. Kinder Morgan requested and received approval to instead install a minimum level of fire protection while ignoring the serious seismic and fire risks of 1953 EFR tank failure under sloshing during an earthquake and the other deficiencies of 1953 tanks outlined below. (More on this when the PLC Report is released to the Public.)

Other Serious Structural Errors:

4. Failure to investigate and test existing welded joint connections in all 9 1953 tanks to verify whether the steel tank erector ordered weld-able steel plate – by special order for A7 material until 1957. Otherwise, the welds could be defective with cracks liable to fail under cyclical earthquake shaking and sloshing, unless the steel was pre-heated and held within a specified temperature range while welding.

5. Failure to investigate possible deficiencies in the original site preparation for the 1953 tanks. The existing cut and fill was designed for gravity load only and the tank foundation is likely a perimeter concrete ring beam. Excavated soil may have been used for the tank foundation. The sixty-six year-old drainage system to divert slope drainage and creeks may no longer divert water away from the tank bases. If excavated soil was used for the tank base, a geo-technical engineer needs to review possible liquefaction under seismic.

6. Failure to investigate the existing floating roofs on all 1953 tanks whether they are modified to mitigate sinking during earthquake loading (exposing the full surface of petroleum) and whether the perimeter seals are metallic and need to be replaced.


The structural investigation, opinions and structural conclusions are Gordon Dunnet’s alone.

Gordon Dunnet, Retired P.Eng., 40+ years of structural design experience and for 13 years, a Principal of a Burnaby Consulting Structural Engineering firm. Experience includes new schools, recreation centres, arenas, seismic upgrades of secondary schools, libraries, colleges, highway bridges, an airport terminal and industrial projects/upgrades of pulp and paper plants and plywood plants. Also updating of Structural Drawing Notes and Specifications for the firm for each new NBC of Canada Edition.

Note that references to Kinder Morgan’s Structural Engineer and KM’s Structural Design Engineer are to the engineer in the firm responsible for the structural design and field review for the Burnaby Terminal Project. This Engineer would normally sign and seal both Issued for Tender and Issued for Construction documents.

Additional Support:

Dr. John Clague, P.Geo., Professor Emeritus, SFU Department of Earth Science and former president of APEGBC, now EG BC.

David Huntley, Professor Emeritus, SFU Department of Physics.

Karl Perrin, Spokesperson for B.R.O.K.E., resident of UniverCity.

Svend Robinson, Federal Candidate for Burnaby North Seymour Riding, 2019 Election.


Gordon L Dunnet, retired P.Eng.

Structural Engineer