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LLi 0 Lawrence Livermore National Laboratory Emergency Management Department 5 February 2009 EMD -09-02-003 Ms. Michelle Henry, Senior Registered Environmental Health Specialist San Joaquin County Environmental Health Department 600 E. Main Street Stockton, CA 95202-3029 - J -J) Subject: Lawrence Livermore National Laboratory �hA_, Site 300 Building 879 EVR Upgrade Project '-"``'''°i 1/SERVI(. ES Healy Vapor Recovery Tank Installation Dear Ms. Henry, This letter will confirm our fire protection review of the modifications at the above subject location. This project includes the installation of a five foot extension to the existing dispensing island and the installation of a Healy Vapor Recovery Tank. During submission of the permit to install the Healy Vapor Recovery Tank, you requested that the Fire Department review the proposed tank location due to the close proximity to the fuel dispensing devices. We understand there is concern as to whether the Vapor recovery tank is required to be separated from the dispensing devices by a distance of at least 20 feet. The reference cited is NFPA 30A — Code for Motor Fuel Dispensing Facilities and Repair Garages. (We used the 2008 Edition of this Code for the information contained in this letter.) The specific section for this 20 foot separation requirement is 10.1.6. The code provides definitions for two types of systems; Vapor Processing, section 3.3.17 and Vapor Recovery, section 3.3.18. (See Attachment A with these definitions from the code). The difference is that the vapors in a processing system are captured and processed by use of mechanical or chemical means. In a vapor recovery system the vapors are captured and retained, without processing. This system recycles the vapors back into the storage tanks. Our review consisted of the Wayne Healy Vac brochure, the installation instructions and associated plans, and the Office of the State Fire Marshal "Vapor recovery Certification No. GVRC005:063:029, revised November 15, 2007 — Vapor Recovery Certification" (Attachment B). Underwriters Laboratories has also issued Certification YUNT.MH15389 Vapor Recover System Accessories, Flammable Liquid for this tank Amk 11�v Recycle 7600.81230 An Equal Opportunity Employer • Lawrence Livermore National Security, LLC - Operated for the US Department of Energy P.O. Box 808 Livermore, California 94551-0808 • Telephone (925) 422-1100 • http:/twww.11nl.gov