Tank Farms—Linnton’s Two-Year Update

By Nancy Hiser 

Two years ago, the Linnton Neighborhood Association endorsed a statement that the Critical Energy Infrastructure (CEI) Hub (known by many as the “tank farms”) must decentralize and relocate to stable bedrock areas. This position was based on information in the 2013 Oregon Resiliency Plan published by the Oregon Seismic Safety Policy Advisory Commission (OSSPAC) and by input from other noted authorities. LNA’s statement has been endorsed by 20 other NAs and local organizations. 

WHAT’S HAPPENED SINCE THEN? 

Peter Dusicka, a civil engineer at Portland State University with more than 2 decades of studying earthquake impacts on infrastructure, prepared a report for Portland Bureau of Emergency 

Management (PBEM) in 2019. Dr. Dusicka’s report cited tank failures in past earthquakes, presented significant data on the CEI Hub tanks, then reviewed multiple potential mitigation options and recommended steps to better understand resiliency and refine cost estimates. The state is expected to announce new funding soon for Dusicka and his colleagues to begin a hazard mitigation study and to gain a better understanding of potential spill in order to explore containment strategies. Their goal is evaluate scenarios in an effort to quantify both the risk of a seismic event and mitigation strategies. In support of this study, Oregon Solutions will be conducting an assessment of key stakeholders, including Linnton residents, to inform any future avenues for collaborative action to increase resiliency in the CEI Hub. 

The Oregon Department of Energy (ODOE) estimates CEI Hub fuel imports at 3 billion gallons annually via pipeline, barges, and trucks. In a 2019 interview, Mike Myers, Director of PBEM, stated that an oil spill at the CEI Hub could be likened to “a Pandora’s box.” OSSPAC’s 12/20/19 report states, “Past earthquakes have damaged or destroyed facilities like those at the CEI Hub. Some fuel tanks at the CEI Hub are more than 100 years old; the majority were built 50 or more years ago, constructed before the region’s earthquake risk was understood and before the soil beneath the CEI Hub was found to be highly susceptible to liquefaction and lateral spreading. The vast majority of CEI Hub tanks, piers, pipelines, and wharves were built to older codes, and they are not required to be updated to current codes.” 

OSSPAC’s major finding: “The Critical Energy Infrastructure Hub is a major threat to safety, environment, and recovery after a Cascadia Subduction Zone earthquake on par with the 2011 Fukushima nuclear meltdown in Japan.” They state, “A release of just a small portion of the liquid fuels at the CEI Hub would cause a spill of national significance, larger than any previous oil spill in US history”, and create an unparalleled environmental disaster “taking decades and tens of millions of dollars to clean up.” Damaged and destroyed roads, bridges, utilities, and communication systems would obstruct emergency responses. 

Per the EPA, if refined petroleum fuel products, crude oils, gases, and fuel additives spill or mix, they can ignite and release toxic chemicals. Also, some tanks contain non-petroleum hazardous chemicals such as ammonia and chlorine that are lethal, if released. These chemicals are also transported through the local area on possibly a daily basis. This presents grave danger to people working or living near the CEI Hub. 

Mike Harryman, Oregon’s State Resilience Officer, says “fuel is our Achilles’ heel” in the recovery process. The CEI Hub usually contains a 3- to 5-day supply of fuel. A Cascadia event would devastate the region’s petroleum supply and distribution system as pipelines carrying the normal incoming fuel will have sustained breaks and leaks. Similarly, ODOE testified, “. . . there will be NO incoming fuel and no transportation corridors due to widespread damage of pipelines, the secondary source via tankers will not function due to bridge damage, and tanker trucks will be non-functional due to transportation disruptions.” ODOE and OSSPAC support efforts to diversify instate fuel supplies geographically to decrease our vulnerability at the CEI Hub. One OSSPAC recommendation was to develop a small-scale CEI Hub at an alternate site. No city or county organization has opted to support this. (continued on the next page) 

Aerial view of Linnton tank farms Nov 23, 1945, OHS, 001048

WHO CAN ACT? 

A 2019 state Senate Bill would have required owners and operators of bulk petroleum terminals to conduct and submit seismic vulnerability assessments to DEQ. This important first step toward regulating mitigation efforts did not pass. 

The City of Portland and Multnomah County “have more direct control over the Hub than the state, but they have not used their authority to include seismic mitigation enforcement or require retrofits” per OSSPAC. Three City agencies can review new tank designs by adopting standards, inspect existing tanks, and plan for and coordinate disaster responses. “Currently, none of these agencies regulates the seismic performance of existing structures or compels mandatory seismic mitigation.” 

In the Fall of 2019, Multnomah County passed a resolution to conduct a full risk assessment of the tank farms. John Wasiutynski, Multnomah County Director of Sustainability, said that we must hold the tank farm owners “accountable for the risks they pose to the community.” The county pledged $50,000 for the study and the city of Portland added another $50,000. A contract was awarded in early August to assess the risk and monetary costs of a Cascadia event at the CEI Hub—an initial step toward a policy that makes companies pay upfront for the damages that their infrastructure is likely to impose. This study is expected to be released in summer 2021. Of course, 

these companies could voluntarily lower their risk and liability by seismically upgrading their tanks and infrastructure. 

WHO HAS REGULATED TANK FARMS? (OR, ARE TANK FARMS REGULATED ELSEWHERE?) 

The Florida Department of Environmental Protection passed strict permitting and compliance regulations for liquid fuel storage in 1983 due to hurricane risks. These remain among the strictest laws in the US for both underground and above ground storage tank systems. Japan has successfully used mitigation strategies along shorelines. PSU is studying technology to stabilize soils with high liquefaction risk. Mitigation of tank farm storage in New York include constructing reinforced concrete containment walls around tanks at a facility which processes 1 million gallons of liquid fuel a day. Austin, Texas relocated its tank farms after community organizing pressure in 1993. In the fall of 2019, a Boise, Idaho developer was negotiating with oil and gas companies to relocate “massive tank farms” because that property has become valuable for development. 

Aware of our extreme vulnerability, the Linnton Neighborhood Association and LNA Environmental Committee will continue to do everything in our power to reduce the risks associated with living near the CEI Hub.