20210407Western Aircraft to Staff 1-5.pdf

DAVID H. LEROY
Attorney At Law
802 West Bannock Street, Suite 201
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
Idaho State Bar No. 1359
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
WESTERN AIRCRAFT, INC,
Complainant,
VS.
SUEZ WATER IDAHO, INC,
Respondent.
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Case No. SUZ-W-21-01
COMPLAINANT'S RESPONSES TO THE
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
WESTERN AIRCRAFT, INC.
COMES Now Complainant, Western Aircraft, Inc., by and through its attorney of record
David H. Leroy, and to the First Production Requests of the Commission Staff hereby responds,
replies and provides documentation as follows:
REQUEST NO. 1: In its Complaint, Western asks the Commission to provide relief by
allowing "a temporary domestic water connection to Hangar O from the existing Hangar 1 water
line, pending the final resolution of this matter .. " Complaint at 6. Please provide the following
information:
a. Please provide a drawing showing the routing, size, ad capacity of the proposed
temporary connection.
RESPONSE l(a) Attachment "A" shows the location and installation of a new two inch
domestic service line forty two feet in length from the existing Suez main line to serve Hangar 0.
COMPLAINANT'S RESPONSES -l
RECEIVED
2021April 2, PM 4:56
IDAHO PUBLIC
UTILITIES COMMISSION
b. ls it Western 's intent that this temporary line provide water for fire service? If so, will
the proposed temporary line be able to provide the necessary fire flows?
RESPONSE l(b) No. The temporary line will provide only domestic water service to
Hangar 0.
c. Will Western be able to occupy Hangar O without it receiving fire service?
RESPONSE I (c): Fire service to Hangar O is provided solely from the private fire tank
onsite. Note that Hangar O contains a 300,000 gallon fire tank located and illustrated on
Attachment "A". This tank is fed from an existing 4" Suez line off Kennedy Street. The feed to
the tank from Suez is needed, but there is no new direct connection from Suez to Hangar 0
required for fire flow.
d. If this temporary connection were made, does Western intend to continue construction
of the covered walkway connecting Hangars O and I?
RESPONSE NO. l(d): Yes. The 42 foot long by 11 foot wide walkway is not a
"building," but we intend to work with the Commission and Suez to resolve the issues.
REQUEST NO. 2: What are the fire flow requirements for Hangar O and Hangar 1?
RESPONSE NO. 2: Per Clarence McLain of Tribal Fire Systems, the fire system is a
combined system that covers Hangars 0, 1, and 2. The sizing is determined by the building with
the largest demand. Hangar O is the largest. However, system sizing is greatly reduced by the
on-site storage tank and adds a 500 GMP hose allowance. For Hangar O this calculates to a need
for 1,750 GPM (1,250 sprinklers+ 500 hose) at 20 psi. Thi s would be 5,500 GPM without using
the storage tank to meet the 120-minute duration. See also Attachment "C."
REQUEST NO. 3: In its Complaint (2B), Western asks the Commission to either approve
COMPLAINANT'S RESPONSES - 2
the revised connection plan prepared by T.O. Engineers on August 20, 2020, or to "indicate
which of the (other) previously proposed alternative solutions it endorses so as to allow a water
service connection to Hangar 0 ... " Please provide a list and descriptions of the solutions that
Western would like the Commission to consider.
RESPONSE NO. 3: In light of new information developed over recent weeks, Western
Aircraft would like to purpose a new alternative plan to reach a compromise with Suez. See
Attachment "B" illustrating the same. The plan is contingent upon two approvals from the City
of Boise:
1. Western Aircraft needs approval from the City of Boise to reconfigure the existing fire
system in Hangar 1 which would allow the 4" fire service from the Suez main line in Boeing to
be abandoned.
2. Western Aircraft needs approval to relocate the proposed fire hydrant from the
location adjacent to the fire room in Hangar I to a new location at the NE corner of the proposed
concrete apron with a connection to the Suez main line in Ingalls.
Following these approvals from the City of Boise building department, Western Aircraft
proposes the following solutions as shown on Attachment "B":
1. Reconfigure the private fire system in Hangar l and abandon the fire service line from
Suez.
2. Install a new fire hydrant at the NE corner of the new apron as required by the Boise
City Fire Department.
3. Cap and abandon the 8" Suez main line in Boeing just east of the building service line
connection.
COMPLAINANT'S RESPONSES -3
4. Construct the Western Aircraft enclosed walkway as proposed between Hangar 1 and
Hangar 0.
REQUEST NO. 4: Regarding the non-potable lines encountered during Western's
excavation for the Hangar O project:
a. What is the purpose of these lines and whom do they serve?
RESPONSE 4(a): It is assumed this question is in regard to the fire water line that runs
from the storage tank to the fire room in Hangar 1. The original line was installed in a straight
line from the tank to the fire room. The line was re-rerouted around the footprint of the new
hangar as part of this project. The lines are privately owned and maintained to serve the fire
system of the Western Aircraft facility.
b. Who installed these lines?
RESPONSE 4(b): Both the original and new lines were installed by Western Aircraft
contractors.
c. Were these lines installed before, or after the Suez main on Boeing?
RESPONSE 4(c) The original lines were installed in roughly 1990 based on a date from
drawings provided by the owner. The new fire line was installed in the summer of 2020 as part
of this project. The installation date of Suez main on Boeing is unknown.
d. Please provide a drawing showing the location of these lines. Are they above
or below the Suez main?
RESPONSE 4(d): See Attachment "B."
REQUEST NO. 5: Regarding the sewer line encountered dw-ing Western's excavation for
the Hangar O project:
COMPLAINANT'S RESPONSES -4
a. Whom does this sewer line serve?
RESPONSE 5(a): This sewer line was originally a City of Boise mainline sewer which
served the Western Aircraft building. As part of this development, we abandoned the "mainline"
sewer and replaced it with a sewer "service" line that would continue to serve the existing
hangars in addition to the new Hangar 0. The new sewer lines were installed at the same depth
and alignment as the existing sewer main, but located a few feet West for phasing purposes. See
Attachment "D" consisting of three pages the illustrating the various historical lines.
b. Who installed this line?
RESPONSE 5(b ): The original sewer main was owned by the City of Boise. The new
sewer line was installed by Western Aircraft.
c. Was this line installed before or after the Suez main on Boeing?
RESPONSE 5(c): The original sewer line install date is unknown. The new service line
was installed in Summer of 2020 as a replacement to maintain service to the existing building.
d. Please provide a drawing showing the location of this line. ls it above or below the
Suez main?
RESPONSE 5(d): See Attachments "Band "D." There are two sewer line locations in
question:
i. Location A-North of new Hangar 0
ii. Location B-South of new Hangar 0
As to Location A -The sewer service was installed below the Suez waterline. Vertical
separation is not compliant with IDEQ regulations. The project was intended and planned to
relocate and lower the waterline in this area to meet IDEQ standards, but such waterline work
COMPLAINANT'S RESPONSES -5
was put on hold by Suez. As to Location B-The sewer mainline is above the Suez "lowered
main" water line. This crossing is existing and was not modified as part of this project.
REQUEST NO. 6: IDENTIFICATION OF PERSON PREPARING RESPONSES:
RESPONSE NO. 6: Brendon Daniels, T-O Engineers and Louie Gravel, Western
Aircraft.
REQUEST NO. 7: IDENTIFICATION OF RECORD HOLDERS:
RESPONSE NO. 7: Same as Response 6 above.
DA TED THIS~ day of April, 2021.
David H. Leroy, Attorne for the Complainant
COMPLAINANT'S RESPONSES -6
CERTIFICATE OF SERVICE
I hereby certify that on this .,J V'c{ day of April, 2021, I caused a true and correct copy of
the within instrument to be sent to:
John R. Hammond Jr.
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
email: [e-mail]
David H. Leroy
Defense Counsel
P.O. Box 193
Boise, Idaho 83 702
email: [e-mail]
COMPLAINANT'S RESPONSES -7
Preston N. Carter
Blake W. Ringer
Givens Purs ley LLP
Boise, Idaho 83701-2720
email: [e-mail]
email: [e-mail]
Davalee Davis, Executive Assistant
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TEMPORARY SERVICE APPROVAL NEEDED FOR BUILDING
OCCUPANCY:
1. INSTALL FIRE HYDRANT ON KENNEDY ST. AT SW
CORNER OF NEW OFFICE BUILDING.
2. INSTALL 2" DOMESTIC SERVICE TO NEW OFFICE
BUILDING, LOCATED ON NORTH SIDE OF BUILDING.
ii:J T•O ENGINEERS
1998 W. JUDITH LANE
I ~ PHONE (208}~33-1900 WWW TO-ENGINEERS.COM
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WESTERN AIRCRAFT
TEMPORARY WATER LINE EXHIBIT BOISE. IDAHO 83705
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TO: Coleen Baker
Glancey Rockwell & Associates
EMAIL: [e-mail]
DATE: April 19, 2019
SUBJECT: 4300 S. Kennedy St.
COMMENTS:
SUEZ
8248 West Victory Rd.
Boise, ID 83709
Phone: 2o8. 362. 7354
Fa><: 2o8. 362. 3858
[e-mail]
Our records indicate the following water pressure and volume at: 4300 S. Kennedy St.:
Pressure at average demand is 55 psi
Flow of 2,000 gpm at 20 psi residual pressure
At fire hydrant 2937 at corner of Boeing & Kennedy
This information represents the water system under maximum-day conditions. The
pressures and flows are subject to change, however, depending on system demand and
changes in system operations. This document shall be attached to the architectural
plan sets, both for "Fire Department reviewed" and "Construction Approved" sets. It is
provided for uniformity in fire sprinkler design criteria.
If you have further questions or need information on the volume of water for a
conditional use application or design review, please feel free to call.
Sincerely,
SUEZ
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