2015-01-16 FW: Temporary LPG (Propane) Tank and Piping at Point Ruston- 5005 Main Street Saturday, March 7, 2015 4:45 AM Subject FW: Temporary LPG (Propane) Tank and Piping at Point Ruston- 5005 Main Street From Erickson, Ryan To Green, Tory; Meinecke, Joe; Duggan, Jim Cc McElligott, Patrick Sent Friday, January 16, 2015 3:39 PM Attachments Fw Propane Piping at ... Hello Chiefs and Joe, Below is an email that I sent to Mike Cohen regarding the propane distribution located on the Point Ruston site. I wanted to make you aware of this email. Regards, RYAN ERICKSON, P.E. Fire Code Official Tacoma Fire Department Prevention Division 901 Fawcett Avenue Tacoma, WA 98402 253.591.5739 rerickson@cityoftacoma.org From: Erickson, Ryan Sent: Friday, January 16, 2015 3:38 PM To: Mike Cohen (MikeC@mcconstruction.com); Joe Harrison (joe@pointruston.com); Joe Harrison (jmharrison1950@yahoo.com) Cc: Loren Cohen (Loren@mcconstruction.com); McElligott, Patrick; Johnson, David (PDS) Subject: RE: Temporary LPG (Propane) Tank and Piping at Point Ruston- 5005 Main Street Mike and Joe, Thank you for meeting with Pat McElligott (Assistant Chief/Fire Marshal), David Johnson (Building Official) and me on Tuesday, January 13, 2015, to discuss the use of liquid propane gas (LPG) on the Point Ruston Development site. The issues surrounding the use of LPG on this site are complicated. We appreciate your continued communication and sharing of information as you receive it from the Office of the Utilities and Transportation Commission (UTC). The Tacoma Fire Department (TFD) in partnership with Tacoma’s Planning and Development Services (PDS) is committed to work with you and your staff throughout this process while fulfilling TFDs mission of protecting people, property and the environment. Some Findings of the Tacoma Fire Department: Ruston Documents from emails Page 1 Some Findings of the Tacoma Fire Department: 1. A 1,000 gallon LPG tank permit #13000008776 was issued by TFD to MC Construction on 05/01/2013 to 2. 3. 4. 5. 6. 7. 8. provide gas service to common areas within Copperline building 2A. The tank was inspected by TFD on 05/13/2013. The tank was removed by AmeriGas on an unknown date. The permitted 1,000 gallon tank was replaced by a 3,000 gallon LPG tank without a permit being issued by TFD. AmeriGas installed the 3,000 gallon tank. The tank currently provides LPG to buildings 2A and 2B East via two separate underground gas pipelines. Point Ruston confirmed that no permit was issued for this tank. Two underground pipelines were installed without being inspected by TFD. Point Ruston confirmed TFD did not inspect the installation or testing of these pipelines. Point Ruston confirmed the UTC determined by inspection that the existing LPG system (tank and pipelines) serves 10 or more customers which is considered a jurisdictional gas distribution system. The pipelines were installed by subcontractors DM Kelly (pipe installation and welding) and Olson Brothers (excavation, bedding, backfill, and compaction) and were inspected by the engineering firm Hydrometrics. a. Unlike the 3-inch underground LPG piping serving Building 2A, the underground pipeline that serves building 2B East was not shown on the permit application drawings submitted to TFD when the 1000 gallon LPG tank permit was issued. The UTC sent a letter on December 19, 2014 to Mike Cohen, Point Ruston LLC, listing probable violations of Title 49 CFR Part 192 and WAC 480-93 related to the LPG system. Mike Cohen stated at Tuesday’s meeting he is fully cooperating with the UTC and plans to submit a proposal to the UTC within 30 days. Hence, the probable violations have not yet been resolved. TFD was notified by PDS that required EIS/SEPA environmental permits were not obtained by Point Ruston for the LPG piping that was installed. TFD was notified by PDS that a foundation permit is necessary if a permanent LPG tank is installed on the site. A foundation permit is not required for a temporary LPG tank installation. To date, Point Ruston LLC has cooperated with TFD by responding to our requests for information pertaining to the LPG distribution system being utilized at the Point Ruston development. At this time, TFD is not aware of any imminent dangers to fire and life safety with regard to the LPG distribution system. Tacoma Fire Department’s Temporary Work Plan Order to Point Ruston LLC Based on the above findings, TFD will temporary allow Point Ruston LLC to continue to operate the existing onsite LPG gas distribution system (tank and piping) serving buildings 2A and 2B East until a final determination by the UTC has been issued. This is a temporary work plan and TFD reserves the right in accordance with the adopted Fire Code to reconsider this decision at any time. Once the UTC issues a final decision, TFD will then review this situation and may reconsider this temporary work plan. In order for Point Ruston LLC to continue operation of the LPG distribution system, the following items shall be completed by no later than 5:00 PM on January 30, 2015: 1. Submit a letter and report, stamped and signed, from a licensed professional engineer of the State of Washington certifying this temporary gas distribution system has been designed, installed and tested in accordance with the adopted Fire Code (2012 International Fire Code with adopted state and local amendments) requirements and including but not limited to NFPA 58, 2011 edition. The letter shall include as-built drawings of the gas distribution system, inspection reports/logs/photos, installer certifications, product submittals, and all relevant test results. a. In lieu of submitting the certification letter, the gas pipelines can be exposed to allow for the proper inspection process with TFD. All relevant pipe tests would also be required at this time. 2. The existing 3,000 gallon LPG tank may temporarily remain but the following shall occur by the deadline: a. No more than 1,000 gallons of LPG material shall be allowed within the tank at any time. Adequate gas filling records shall be maintained and made readily available at the request of the Fire Department to confirm this maximum volume is adhered to. b. Provide adequate vehicular impact protection for the temporary LPG tank and piping manifold(s). Since this is a temporary installation there is potential that concrete ecology blocks properly located may be acceptable. Tacoma Fire Department can meet with Point Ruston LLC on the site to resolve this item. Please contact Ryan Erickson, Fire Code Official, to setup a time to Ruston Documents from emails Page 2 the site to resolve this item. Please contact Ryan Erickson, Fire Code Official, to setup a time to meet on the site. 3. If this gas distribution system is deemed acceptable to remain as a permanent installation by all regulatory agencies, easements shall be recorded for the LPG piping system since its crosses multiple property lines. The easements are not required to be completed by the deadline listed above but will be required if the system is allowed to be a permanent installation. 4. This temporary work plan issued by TFD does not exempt Point Ruston from obtaining all other required federal, state or local permits or approvals for the installation of a LPG distribution system. Such approvals may include but are not limited to any environmental and land use permits (EIS/SEPA) or foundation permits for LPG tanks from PDS. TFD and PDS are here to discuss any questions or comments you may have related to the temporary work plan or any other topic. Best Regards, RYAN ERICKSON, P.E. Fire Code Official Tacoma Fire Department Prevention Division 901 Fawcett Avenue Tacoma, WA 98402 253.591.5739 rerickson@cityoftacoma.org From: Erickson, Ryan Sent: Tuesday, December 16, 2014 4:45 PM To: Joe Harrison (joe@pointruston.com) Cc: Boczar, Sue; Seaman, Chris; Mike Cohen (MikeC@mcconstruction.com); Johnson, David (PDS); Kinlow, Charla Subject: RE: Temporary LPG (Propane) Tank and Piping at Point Ruston- 5005 Main Street Joe, Thanks for your email response below and our phone conversation today. Today you confirmed that the existing LPG tank at Point Ruston development is actually a 3,000 gallon capacity and was installed by Amerigas to replace the 1,000 gallon capacity tank that was originally permitted as a temporary tank by TFD. You stated that Amerigas is currently planning to quickly remove the 3,000 gallon tank and replace it with another a 1,000 gallon capacity tank. As I stated, please make sure Amerigas coordinates this work with Deputy Fire Marshal Sue Boczar since a new temporary LPG tank permit application is required to install any additional LPG tank on this site. For a temporary installation, ecology blocks are sometimes approved but the blocks must be located an adequate distance from the tank. Ecology blocks can easily slide across smooth surfaces (i.e. asphalt, concrete) upon vehicular impact which can actually result in damage to the LPG tank, valves, and piping. Therefore, the temporary vehicular impact protection must be reviewed and approved by the Fire Department. Also, I was verbally notified by Lex Vinsel, UTC Pipeline Safety Engineer, on Friday December 12, 2014 that the UTC has regulatory authority over the temporary LPG gas distribution system since there are 10 or more customers being served by the gas utility plant. Therefore, both TFD and Point Ruston need to closely coordinate our permitting efforts with the UTC from here forward. You stated that Point Ruston is still looking to respond to my request for inspection records for the underground LPG piping by Tacoma Fire Department. It is also my understanding that the UTC will also have some detailed input into the design, installation and inspection of the underground LPG gas distribution system; the UTC may become the lead permitting agency for the gas system. Please contact Lex Vinsel to begin working Ruston Documents from emails Page 3 may become the lead permitting agency for the gas system. Please contact Lex Vinsel to begin working with the UTC and meet their requirements and regulations as well. Please note that any further LPG permits will also require close coordination with Tacoma’s Planning and Development Services Department (PDS) to ensure all environmental permitting requirements/regulations are met and EIS amendments, if any, are approved and executed. We will need to further discuss any necessary easements for the piping as more information is received from the UTC regarding the underground pipeline requirements. For the time being, the easements are the least critical concern from TFD’s standpoint since our immediate concern is with overall safety of the LPG pipeline and tank installation. Let’s discuss this as a follow up item in the near future once we get further direction from the UTC. As you requested, here is the excerpt from the adopted International Fire Code (IFC) Section 6104.2 that relates to the maximum tank capacity. IFC Section 6104.2 Within the limits established by law restricting the storage of liquefied petroleum gas for the protection of heavily populated or congested areas, the aggregate capacity of any one installation shall not exceed a water capacity of 2,000 gallons (7570 L). Exception: In particular installations, this capacity limit shall be determined by the fire code official, after consideration of special features such as topographical conditions, nature of occupancy, and proximity to buildings, capacity of proposed LP-gas containers, degree of fire protection to be provided and capabilities of the local fire department. Please keep me and the Fire Department abreast of any relevant issues/items that arise with the UTC. I’m available for questions or comments as well. Regards, RYAN ERICKSON, P.E. Fire Code Official Tacoma Fire Department Prevention Division 901 Fawcett Avenue Tacoma, WA 98402 253.591.5739 rerickson@cityoftacoma.org From: Joe Harrison [mailto:jmharrison1950@yahoo.com] Sent: Thursday, December 11, 2014 10:54 AM To: Erickson, Ryan Cc: Boczar, Sue Subject: Re: Temporary LPG (Propane) Tank and Piping at Point Ruston- 5005 Main Street Good morning Ryan, Since Sue is out of the office I'll respond back to you. 1. Pt. Ruston will deploy some ecology blocks around the tank in question. 2. We are researching if there were inspections. 3. Would you direct me to the municipal code that is specific to tanks and size ? 4. Pt. Ruston will furnish easements. (Size or any other specifics) If Amerigas becomes the operator of the system should the easements be granted to them instead of Tacoma ? Ruston Documents from emails Page 4 Thank you From: "Erickson, Ryan" To: "Mike Cohen (MikeC@mcconstruction.com)" Cc: "Boczar, Sue" ; "Joe Harrison (joe@pointruston.com)" ; "Seaman, Chris" Sent: Friday, December 5, 2014 10:30 AM Subject: Temporary LPG (Propane) Tank and Piping at Point Ruston- 5005 Main Street Dear Mr. Cohen, At our recent meeting with you, Joe Harrison, Planning and Development Services (PDS) and Tacoma Fire Department (TFD) you mentioned that the temporary permitted 1,000 gallon LPG (propane) tank at Point Ruston Development may have been replaced with a 3,000 gallon tank by Amerigas. At the meeting I stated that TFD had no record of a permit to install a 3,000 gallon tank but there was a permit record for a 1,000 gallon tank installation. As a result of this brief discussion, TFD staff recently visited the Point Ruston site to check into the tank. Based on a visual inspection it appears the tank may not be large enough to be 3,000 gallons but we really couldn’t confirm that. Please note that the maximum LPG tank allowed within heavily populated/congested areas of Tacoma shall not exceed a water capacity of 2,000 gallons. Point Ruston development is considered a heavily populated/congested area by the Tacoma Fire Department. Some issues, listed below, with the temporary LPG tank installation were recognized and must be addressed. Please contact Sue Boczar, Deputy Fire Marshal, to discuss these issues. DFM Boczar can be reached by email at sboczar@cityoftacoma.org or at 253.594.7929 Please follow up with TFD by December 19, 2014 (2-weeks). 1. Provide adequate vehicular impact protection for the temporary LP tank and piping manifold(s). Since this is a temporary installation there is potential that concrete ecology blocks properly located may be acceptable. 2. TFD has no record of inspecting the LPG gas piping from the temporary tank to the building(s) being served. If you believe this is in error, please submit the inspection documentation for review. 3. Easements will be required for the LPG gas piping system since its crosses multiple property lines. Regards, RYAN ERICKSON, P.E. Fire Code Official Tacoma Fire Department Prevention Division 901 Fawcett Avenue Tacoma, WA 98402 253.591.5739 rerickson@cityoftacoma.org Ruston Documents from emails Page 5