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HomeMy WebLinkAboutReg 2011-10-03 Item 6A - Blue Star - Attachment G - Letter from Blue Star Gas to City Dated 8/31/2011August 31, 2011 Brandon J. Miles, Senior Planner Don Tomaso, Fire Marshal City of Tukwila 6300 Southcenter Blvd., Suite 100 Tukwila, WA 98188 RE: Proposed Blue Star Gas Propane Fueling Facilitv at 10802 E. Marginal Wav Dear Brandon and Don: I write to address the compliance issues raised in Sound Transit's letter to Brandon dated, August 23, 2011. At this time we are choosing not to send a letter directly to Sound Transit but, we are interested in speaking with you both on your thoughts related to this matter. Sound Transit's letter correctly point out that Section 6104.3 of the 2012 International Fire Code (the "Code requires a fifty feet minimum separation between our above ground LP tank "and buildings, public ways, or lot lines of adjoining property lines that can be built upon." The Code defines building to be "any structure used or intended for supporting or sheltering any use or occupancy" and defines public way as "a street, ally, or other parcel of land open to the outside air leading to a street, that has been deeded, dedicated, or otherwise permanently appropriated to the public for public use and which has a clear width and height of at less than 10 feet." As you are aware, the location of our above ground tank achieves this separation well over the fifty feet minimum. Further, as you are also aware, we are in compliance with section 6.3.2 of 2012 NFPA 58 (allowing for the separation distance to be reduced by one half when Redundant Fail Safe Product Control and Low Emission Product Transfers are being utilized, which our project will be utilizing), and are also in compliance with the requirements set forth in the recorded Guideway Easement document. Sound Transit's letter also discusses our compliance with section 6.6 of NFPA 130 but, it lacks specifics as to how we do not comply. In any case, we have conducted a review of this section and it is clear that this section does not apply. We shall continue to ensure our project is in compliance with the Code, NFPA 58, and any other applicable regulations and, we will consider all recommendations from both of your Departments. Since the Planning and Fire Departments have exclusive jurisdiction on these matters, we have been working closely with you both, and have addressed and incorporated your suggestions in our plans to date. Specifically, in working with Don, we carefully considered the BR0DKINGS o CRESCENT CITY o MEDFORD e MT. SHASTA a GARBERVILLE GRANTS PASS SANTA ROSA a UPPER LAKE s REDDING o MCMINNVILLE a EUGENE Attachment G placement of the tanks on the site in relation to the Guideway and at no point was a requirement for a blast analysis raised. We strongly feel that a blast analysis is not warranted under the circumstances and we will not conduct one. Sound Transit's suggestion to paint the limits of the Sound Transit easement is a good one, and we will certainly incorporate that into our final plan for the project Please let us know if you have any additional concerns or questions. As you are aware, numerous attempts were made to contact Sound Transit to discuss the easement and the project during the planning phase. There was no response provided by Sound Transit to those inquiries. I can be reached via email at cili.asti. or via telephone at 707 -573 -3130. Sincerer Chris Mastrup Director of Safety and Training