FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE COMMITTEE MEMORANDUM TO: NFPA 30 Technical Committee on Tank Storage and Piping Systems FROM: R. P. Benedetti DATE: June 6, 2013 SUBJECT: Agenda for NFPA 30 Second Draft Meeting June 18, 2013 — 8:00 AM to 5:00 PM June 19, 2013, — 8:00 AM to 12:00 PM _________________________________________________________________________________ Ladies and Gentlemen: Attached is the Agenda for the NFPA 30, Flammable and Combustible Liquids Code, Second Draft meeting of the NFPA 30 Technical Committee on Tank Storage and Piping Systems, to be held 8:00 AM to 5:00 PM, Tuesday, June 18, 2013, and 8:00 AM to Noon, Wednesday, June 19, 2013, at the Doubletree Hotel – San Antonio Downtown, San Antonio TX. This Agenda will also be posted to the NFPA 30 Document Information Page at http://www.nfpa.org/aboutthecodes/list_of_codes_and_standards.asp If you have additional items for the Agenda, please bring them with you to the meeting. rpb/ cc FLCC Meeting Folder FLCTAN/NM FLCTAN.2013-06 Agenda.doc FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE COMMITTEE AGENDA — NFPA 30 Second Draft Meeting NFPA 30 Technical Committee on Tank Storage and Piping Systems Doubletree Hotel – San Antonio Downtown San Antonio TX Tuesday, June 18, 2013, 8:00 AM to 5:00 PM Wednesday, June 19, 2013, 8:00 AM to 12:00 PM 1. Call to Order. 2. Introduction of Attendees. 3. Approval of Minutes of Last Meeting. [Attachment № A2] 4. Report of Committee Chair. 5. Report of Staff Liaison. Update of Committee Roster. [Attachment № A1] [August, 2012, NFPA Headquarters, Quincy MA] Technical Committee Scope. Technical Committee Membership Status. Document Revision Schedule for Annual 2014 Cycle. [Attachment № A3] 6. Member Reports on Current Issues. [As Necessary] 7. Address Committee Input № 16 – Security for Unsupervised Tanks – Recommendation from CSB. [Attachment № A4] 8. Address Committee Inputs №s 11 and 12 – Pressure Limitations. [Attachment № A5] [NOTE: It is the Task Group’s recommendation to defer this to the next revision cycle and to establish a new Task Group to study the historical record and then recommend more appropriate pressure limitations and test pressure criteria.] 9. Address Committee Input № CI13 – Table for Emergency Vent Reduction Factors. [Attachment № A6] [NOTE: It is the Task Group’s recommendation to leave the current text as is.] 10. Address Committee Input № 15 – Capacity Limitations for Secondary Containment-type Tanks. [Attachment № A7] [NOTE: It is the Task Group’s recommendation to eliminate the capacity limitations, based on the fact that the real protective measures are inherent in the ancillary components of the system. However, the text should be qualified to apply only to shop-fabricated tanks. In addition, the Task FLCTAN.2013-06 Agenda.doc Group recommends that a new Task Group be established to study application of the concept of secondary containment to field-erected tanks.] 11. Address Committee Input № 17 – Low-melting Point Piping Materials – Recommendation from CSB. [Attachment № A8] 12. Address Committee Input № 2 – Materials of Construction for Tanks. 13. Recent Correspondence. 14. Old Business. 15. New Business. [Attachment № A9] [NONE] [NONE] Federal Regulatory Agency Task Group [Work w/ CSB, OSHA, etc. to Develop Recommendations in NFPA Format.) Tank Spacing Task Group [Review Section 22.4 of NFPA 30 vis a vis LASTFire Project and Other Data.] Research Projects : - Fire Incident History of Small Tanks - Heat Transfer Modeling to Confirm Current Spacing New Globally Harmonized Standard for Liquids Classification (OSHA). Action Plan for 2018 edition of NFPA 30 – Identify Work Areas. 16. Schedule Next Meeting(s). 17. Adjournment. FLCTAN.2013-06 Agenda.doc ATTACHMENT No. A1 05/20/2013 Robert P. Benedetti FLC-TAN Address List No Phone Tank Storage and Piping Systems Flammable and Combustible Liquids Stephen W. Haines Chair Haines Fire & Risk Consulting Corp. 1 Linda Lane, Suite B Southampton, NJ 08088 Alternate: Anthony M. Ordile John H. Bagnall Principal Burns & McDonnell Engineering Company PO Box 419173 Kansas City, MO 64141 SE 08/09/2012 Steven P. Allwein FLC-TAN Principal Morrison Brothers Company 570 East Seventh Street Dubuque, IA 52001 SE 1/15/2004 Gregory P. Bareta FLC-TAN Principal Wisconsin Department of Commerce 141 NW Barstow Street Waukesha, WI 53188-3789 Tim D. Blackford Principal Chevron Energy Technology Company 3901 Briarpark Drive Houston, TX 77042 American Petroleum Institute Alternate: Richard S. Kraus U 3/1/2011 John V. Cignatta FLC-TAN Principal Datanet Engineering, Inc. 11416 Reisterstown Road Owings Mills, MD 21117 Sullivan D. Curran Principal Fiberglass Tank & Pipe Institute 11150 South Wilcrest Drive, Suite 101 Houston, TX 77099-4343 Alternate: Patrick A. McLaughlin M 1/1/1994 Charles A. Davis FLC-TAN Principal URS Corporation 7650 West Courtney Campbell Causeway Tampa, FL 33607-1462 Claire V. De Taeye Principal Travelers Insurance Company 75 Town Centre Drive Rochester, NY 14623 I 3/1/2011 Michael Doxey FLC-TAN Principal HMT Inc. 24 Waterway Avenue, Suite 400 The Woodlands, TX 77380 Wayne B. Geyer Principal Steel Tank Institute (STI/SPFA) 944 Donata Court Lake Zurich, IL 60047 Alternate: Jeffrey M. Shapiro M 1/1/1986 Edward S. Goldhammer FLC-TAN Principal Aon Fire Protection 11770 Bernardo Plaza San Diego, CA 92128 Alternate: Thomas S. Lentz Dwight H. Havens Principal Bechtel Marine Propulsion Corporation Knolls Atomic Power Laboratory 20 Bellflower Road Malta, NY 12020-4431 U 7/24/1997 David C. Kirby FLC-TAN Principal Baker Engineering & Risk Consultants, Inc. 1560 Clearview Heights Charleston, WV 25312 Alternate: Duane L. Rehmeyer M 7/16/2003 FLC-TAN E 3/4/2008 FLC-TAN SE 8/2/2010 FLC-TAN SE 10/1/1996 FLC-TAN M 08/09/2012 FLC-TAN I 8/5/2009 FLC-TAN SE 1/1/1991 FLC-TAN 1 05/20/2013 Robert P. Benedetti FLC-TAN Address List No Phone Tank Storage and Piping Systems Flammable and Combustible Liquids Gregory D. Kirby Principal CYTEC Industries, Inc. 1 Heilman Avenue Willow Island, WV 26134 U 1/17/1997 David P. Nugent FLC-TAN Principal Valspar Corporation 8725 West Higgins Road, Suite 1000 Chicago, IL 60631 U 3/21/2006 FLC-TAN Marcia Jo Poxson E 10/29/2012 Niall Ramsden SE 10/29/2012 Principal FLC-TAN Principal FLC-TAN Michigan Department of Environmental Quality Resource Protection International PO Box 30426 Walker House Lansing, MI 48909-7926 George Street Aylesbury, Bucks, HP20 2HU United Kingdom Alternate: R. Jeff Tanner Robert N. Renkes Principal Petroleum Equipment Institute 6514 East 69th Street Tulsa, OK 74133 M 1/1/1984 John W. Richmond, Sr. FLC-TAN Principal Eastman Chemical Company PO Box 511 (B-18) Kingsport, TN 37663 U 4/14/2005 FLC-TAN Roland A. Riegel Principal UL LLC 1285 Walt Whitman Road Melville, NY 11747-3085 Alternate: Alfredo M. Ramirez RT 4/15/2004 James R. Rocco U 3/21/2006 FLC-TAN Principal FLC-TAN Sage Risk Solutions, LLC 360 Heritage Road Aurora, OH 44202 Petroleum Marketers Association of America Alternate: Charles R. Plummer Tim G. Schroeder Principal Husky Corporation 2325 Husky Way Pacific, MO 63069 M 10/18/2011 Clark D. Shepard FLC-TAN Principal ExxonMobil Corporation Research & Engineering 3225 Gallows Road, Room 3A2111 Fairfax, VA 22037 Alternate: David W. Owen U 1/12/2000 FLC-TAN Beth Tate Principal Office of the Fire Marshal Community Safety & Correctional Services 5775 Yonge Street, 7th Floor Toronto, ON M2M 4J1 Canada E 7/29/2005 David B. Wechsler FLC-TAN Principal 27706 Dalton Bluff Court Katy, TX 77494 American Chemistry Council U 10/27/2009 FLC-TAN Peter J. Willse Principal XL Global Asset Protection Services 100 Constitution Plaza, 12th Floor Hartford, CT 06103 Alternate: Luis F. Arango I 3/21/2006 Jack Woycheese FLC-TAN Principal Hughes Associates, Inc. 2195 Overlook Drive Walnut Creek, CA 94597 Alternate: Joseph L. Scheffey SE 1/1/1996 FLC-TAN 2 05/20/2013 Robert P. Benedetti FLC-TAN Address List No Phone Tank Storage and Piping Systems Flammable and Combustible Liquids Luis F. Arango Alternate XL Global Asset Protection Services 21707 Shallow Glen Lane Katy, TX 77450 Principal: Peter J. Willse I 7/16/2003 Richard S. Kraus FLC-TAN Alternate API/Petroleum Safety Consultants 210 East Fairfax Street, Apt. 600 Falls Church, VA 22046-2909 American Petroleum Institute Principal: Tim D. Blackford U 4/5/2001 FLC-TAN Thomas S. Lentz Alternate Aon Risk Services, Inc. 200 East Randolph Street Chicago, IL 60014 Principal: Edward S. Goldhammer I 3/2/2010 Patrick A. McLaughlin FLC-TAN Alternate McLaughlin & Associates 2070 South Fox Glen Way Eagle, ID 83616 Fiberglass Tank & Pipe Institute Principal: Sullivan D. Curran M 4/1/1994 FLC-TAN Anthony M. Ordile Alternate Haines Fire & Risk Consulting Corporation 1 Linda Lane, Suite B Southampton, NJ 08088 Principal: Stephen W. Haines SE 10/1/1993 David W. Owen FLC-TAN Alternate ExxonMobil Corporation Research and Engineering 2800 Decker Drive MOB 541 Baytown, TX 77520 Principal: Clark D. Shepard U 7/12/2001 FLC-TAN Charles R. Plummer U 4/14/2005 Alfredo M. Ramirez Alternate FLC-TAN Alternate PPM Consultants, Inc. UL LLC 1600 Lamy Lane 333 Pfingsten Road Monroe, LA 71201-3736 Northbrook, IL 60062-2096 Petroleum Marketers Association of America Principal: Roland A. Riegel Principal: James R. Rocco Duane L. Rehmeyer Alternate Baker Engineering & Risk Consultants, Inc. 709 Highspire Road Glenmore, PA 19343 Principal: David C. Kirby SE 8/2/2010 Joseph L. Scheffey FLC-TAN Alternate Hughes Associates, Inc. 3610 Commerce Drive, Suite 817 Baltimore, MD 21227-1652 Principal: Jack Woycheese Jeffrey M. Shapiro M 10/10/1997 Alternate FLC-TAN International Code Consultants 8207 Asmara Drive Austin, TX 78750 Steel Tank Institute/Steel Plate Fabricators Association Principal: Wayne B. Geyer RT 4/15/2004 FLC-TAN SE 03/07/2013 FLC-TAN R. Jeff Tanner Alternate Michigan Department of Environmental Quality PO Box 30426 Lansing, MI 48909-7926 Principal: Marcia Jo Poxson 10/29/2012 FLC-TAN 3 05/20/2013 Robert P. Benedetti FLC-TAN Address List No Phone Tank Storage and Piping Systems Flammable and Combustible Liquids Jeffrey J. Wanko Nonvoting Member US Department of Labor Occupational Safety & Health Administration 200 Constitution Ave. NW, Room N3119 Washington, DC 20210 Donald M. Johnson Member Emeritus 3333 Rossmoor Parkway, #1 Walnut Creek, CA 94595 Brooke B. Smith, Jr. Member Emeritus 114 Parkview Drive Woodland Park, CO 80863 E 03/05/2012 David L. Blomquist FLC-TAN Member Emeritus Blomquist Fire Protection Engineering 114 Golden Ridge Road Alamo, CA 94507-2869 1/1/1964 Orville M. Slye, Jr. FLC-TAN Member Emeritus Loss Control Associates, Inc. 79 Sweetgum Road Levittown, PA 19056 SE 1/1/1982 Robert P. Benedetti FLC-TAN Staff Liaison National Fire Protection Association 1 Batterymarch Park Quincy, MA 02169-7471 10/1/1993 FLC-TAN 1/1/1988 FLC-TAN FLC-TAN 4 ATTACHMENT No. A2 FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE COMMITTEE Minutes of NFPA 30 First Draft Meetings NFPA 30 Technical Committee on Tank Storage and Piping Systems National Fire Protection Association Offices Quincy, MA Thursday, August 30, 2012 The meeting was preceded by an introduction to the new NFPA standards development system by A. Cronin, Secretary-NFPA Standards Council. I. Participation S. P. Allwein, Morrison Brothers Company J. H. Bagnall, Burns & McDonnell Engineering Company J. V. Cignatta, Datanet Engineering Inc. C. V. De Taeye, Travelers Insurance Company W. B. Geyer, Steel Tank Institute S. W. Haines, Haines Fire & Risk Consulting Corp., CHAIR D. H. Havens, Bechtel Marine Propulsion Corporation / Knowles Atomic Power Laboratory D. C. Kirby, Baker Engineering & Risk Consultants, Inc. G. D. Kirby, CYTEC Industries, Inc. D. W. Owen, ExxonMobil Corporation D. L. Rehmeyer, Baker Engineering & Risk Consultants, Inc. R. N. Renkes, Petroleum Equipment Institute J. W. Richmond, Sr., Eastman Chemical Company R. A. Riegel, UL LLC J. R. Rocco, Sage Risk Solutions, LLC (Rep. Petroleum Marketers Association of America) T. G. Schroeder, Husky Corporation J. M. Shapiro, International Code Consultants (Rep. Steel Tank Institute) C. D. Shepard, ExxonMobil Corporation J. J. Wanko, U. S. Occupational Safety and Health Administration J. Woycheese, Hughes Associates, Inc. R. P. Benedetti, National Fire Protection Association, STAFF LIAISON GUESTS: None Members Not in Attendance L. F. Arango, XL Global Asset Protection Services G. P. Bareta, Wisconsin Department of Commerce T. D. Blackford, Chevron Energy Technology Company (Rep. American Petroleum Institute) S. D. Curran, Fiberglass Tank & Pipe Institute C. A. Davis, URS Corporation E. S. Goldhammer, Aon Fire Protection R. S. Kraus, PSC Petroleum Safety Consultants (Rep. American Petroleum Institute) T. S. Lentz, Aon Risk Services, Inc. FLCTAN.2012-08 Minutes.doc P. A. McLaughlin, McLaughlin & Associates (Rep. Fiberglass Tank & Pipe Institute) D. P. Nugent, Valspar Corporation A. M. Ordile, Haines Fire & Risk Consulting Corp. C. R. Plummer, PPM Consultants, Inc. (Rep Petroleum Marketers Association of America) A. M. Ramirez, UL LLC B. Tate, Office of the Fire Marshal – Ontario D. B. Wechsler, Lake Jackson TX (Rep. American Chemistry Council) P. J. G. Willse, XL Global Asset Protection Services II. Minutes 1. The meeting was called to order at 1:15 PM on Thursday, August 30, 2012 by Technical Committee Chair Steve Haines. 2. Attendees introduced themselves. 3. The Minutes of the previous meeting (September 2010, Rosemont IL) were unanimously approved as issued. 4. The Technical Committee Chair welcomed attendees and briefly reviewed the Agenda. 5. The Staff Liaison reported on the following: The Technical Committee roster was corrected as needed. Technical Committee Scope Statement. The Technical Committee agreed to the need for a revised scope that accurately reflects the Technical Committee’s responsibilities. The Staff Liaison was directed to circulate a revised scope statement to the Technical Committee for ballot. Membership Status. The Staff Liaison reported on recent changes to committee membership and on the balance of interests on the committees. He also briefed the Technical Committee on emphasis programs to recruit alternate members (for those Principal members who do not have one) and enforcing officials. Document Revision Schedule for NFPA 30-2012. The Staff Liaison reviewed the Annual 2014 revision schedule for the 2015 edition of NFPA 30. 6. Roland Riegel presented an update on relevant UL LLC standards. There were no reports on current topics. There were no issues that needed to be reported to the Technical Correlating Committee. 7. The Technical Committee reviewed and took action on 9 Public Inputs to amend the 2012 edition of NFPA 30. Five First Revisions to NFPA 30 were created. No correlation issues were evident. In addition, six Committee Inputs were generated. The Staff Liaison was directed to circulate the First Revisions for letter ballot. 8. Under “Recent Correspondence”, the Technical Committee discussed the following items: 9. Recommendation from U. S. Chemical Safety and Hazard Investigation Board to mandate fullyautomated, API Standard 2350-compliant level control systems for all storage tanks. The Technical Committee made no firm decision on this item. Recommendation from U. S. Chemical Safety and Hazard Investigation Board for enhanced protection from trespassing for isolated tanks. The Technical Committee drafted a Committee Input to seek additional input. Recommendation from U. S. Chemical Safety and Hazard Investigation Board for prohibition against the use of low-melting point piping materials for aboveground storage tanks. The Technical Committee drafted a Committee Input to seek additional input. Under “Old Business”, the Technical Committee discussed the following items and took the indicated action: Reformatting the Emergency Vent Reduction factors in the Form of a Table. The Technical Committee drafted a Committee Input to seek additional input. FLCTAN.2012-08 Minutes.doc 10. Special Grounding Provisions for Aboveground Tanks at Sites with Impervious Liners. The Technical Committee determined there was no evidence that this was necessary. Separation Distances between Tanks and Rail Sidings. The Technical Committee determined there was no evidence that this was necessary. Table 22.4.2 Shell-to-Shell Spacing Provisions Applied to Tanks in Buildings. The Technical Committee determined that this should be studied during the next document revision cycle. Application of Chapter 24 to Any Tank Inside a Building. The Technical Committee determined that this should be studied during the next document revision cycle. [NOTE: Tanks installed per NFPA 30A, NFPA 31, and NFPA 37 would be exempt.] Provision in Chapter 24 for Mandatory Sprinkler Protection – Extra Hazard Group 2. The Technical Committee determined that this should be studied during the next document revision cycle. Under “New Business”, the Technical Committee discussed the following items and decided to defer all for study during the next document revision cycle. Should Chapter 21 contain an exemption for liquids with flash points, but no fire points? Subsection 21.7.1.5: Revise to require only one of the three options. Section 22.4: Add statement that a multi-compartment tank is treated the same as a single compartment tank for purposes of siting. In 22.7.3.4, should “M” be defined as the relative molecular weight of the vapor being relieved? Should Chapter 23 mandate that all pipe risers and vent pipes be electrically bonded and grounded? [NOTE: This is based on recent explosion incidents involving lightning strikes at underground storage tanks] Situation: underground tank located on one side of a building and supplying fuel to a stationary engine on the other side of the building. Can piping be run through the basement? Chapter 25: revise Scope to include Class III liquids. Subsection 25.13.1 conflicts with 27.8.2.6/7 for Class II and Class III liquids. Section 27.4: does it apply to all valves, regardless of whether they connect to the top of the tank or below the liquid level? Paragraph 27.4.4.1(1): What is the criteria for “resistant to fire”? Equivalent to steel? Should not the provisions of 27.8.2.3 through 27.8.2.12.1 apply to aboveground tanks as well as underground tanks? Subsection 28.4.1: Clarify to indicate these are fixed unloading stations. What is appropriate distance for “direct transfer from tank vehicle to storage tank”? 11. The NFPA 30 Second Draft meeting was tentatively scheduled for Thursday, May 23, 2013, in San Antonio TX. 12. The meeting adjourned at 5:45 PM. FLCTAN.2012-08 Minutes.doc ATTACHMENT No. A3 2014 ANNUAL REVISION CYCLE *Public Input Dates may vary according to documents and schedules for Revision Cycles may change. Please check the NFPA Website for the most up‐to‐date information on Public Input Closing Dates and schedules at www.nfpa.org/document # (i.e. www.nfpa.org/101) and click on the Next Edition tab Process Stage Public Input Stage (First Draft) Comment Stage (Second Draft) Dates for TC Dates for TC with CC Public Input Closing Date* Final Date for TC First Draft Meeting Posting of First Draft and TC Ballot Final date for Receipt of TC First Draft ballot Final date for Receipt of TC First Draft ballot ‐ recirc Posting of First Draft for CC Meeting Final date for CC First Draft Meeting Posting of First Draft and CC Ballot Final date for Receipt of CC First Draft ballot Final date for Receipt of CC First Draft ballot ‐ recirc Post Final First Draft for Public Comment 6/22/2012 11/30/2012 1/18/2013 2/8/2013 2/15/2013 2/22/2013 6/22/2012 8/31/2012 10/12/2012 11/2/2012 11/9/2012 11/16/2012 12/28/2012 1/18/2013 2/8/2013 2/15/2013 2/22/2013 Public Comment closing date Final Date to Publish Notice of Consent Documents (Documents that received no Comments) Appeal Closing Date for Consent Documents (Documents that received no Comments) Final date for TC Second Draft Meeting Posting of Second Draft and TC Ballot Final date for Receipt of TC Second Draft ballot Final date for receipt of TC Second Draft ballot ‐ recirc Posting of Second Draft for CC Meeting Final date for CC Second Draft Meeting Posting of Second Draft for CC Ballot Final date for Receipt of CC Second Draft ballot Final date for Receipt of CC Second Draft ballot ‐ recirc Post Final Second Draft for NITMAM Review 5/3/2013 5/10/2013 5/3/2013 5/10/2013 5/24/2013 5/24/2013 10/18/2013 11/29/2013 12/20/2013 12/27/2013 1/3/2014 7/12/2013 8/23/2013 9/13/2013 9/20/2013 9/27/2013 11/8/2013 11/29/2013 12/20/2013 12/27/2013 1/3/2014 2/7/2014 4/4/2014 2/7/2014 4/4/2014 4/18/2014 5/9/2014 4/18/2014 5/9/2014 6/9‐12/2014 6/9‐12/2014 6/24/2014 8/14/2014 6/24/2014 8/14/2014 Process Step Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date Preparation Posting of Certified Amending Motions (CAMs) and Consent Documents (& Issuance) Appeal Closing Date for Consent Documents SC Issuance Date for Consent Documents Tech Session Association Meeting for Documents with CAMs Appeals and Appeal Closing Date for Documents with CAMs Issuance Council Issuance Date for Documents with CAMs National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... ATTACHMENT No. A4 Committee Input No. 16-NFPA 30-2012 [ Section No. 21.7.2.2 ] 21.7.2.2 Security for Unsupervised Storage Tanks. Unsupervised, isolated aboveground storage tanks shall be secured and shall be marked to identify the fire hazards of the tank and the tank’s contents to the general public. Where necessary to protect the tank from tampering or trespassing, the area where the tank is located shall be secured. Submitter Information Verification Submitter Full Name: [ Not Specified ] Organization: [ Not Specified ] Submittal Date: Thu Sep 27 11:43:15 EDT 2012 Committee Statement and Meeting Notes Committee Statement: In response to Recommendation 2011-H-1-6, made by the U. S. Chemical Safety and Hazard Investigation Board, the NFPA 30 Technical Committee on Tank Storage and Piping Systems is considering revising the provisions for unsecured isolated storage tanks and is soliciting input for possible Technical Committee action at the second draft meeting. Response Message: Ballot Results This item has not been balloted 1 of 1 6/11/2013 10:11 AM From D. Havens, 5‐17‐2013 Action by sub – retain current 21.7.2.2 and add new appendix. Current Language: 21.7.2.2 Security for Unsupervised Storage Tanks. Unsupervised, isolated aboveground storage tanks shall be secured and shall be marked to identify the fire hazards of the tank and the tank’s contents to the general public. Where necessary to protect the tank from tampering or trespassing, the area where the tank is located shall be secured. Proposed language, showing changes: 21.7.2.2* Security for Unsupervised Storage Tanks. Unsupervised, isolated aboveground storage tanks that are accessible to the general public, shall be secured and shall be marked to identify the fire hazards of the tank and the tank’s contents to the general public. Where necessary to protect the tank from tampering or trespassing, the area where the tank is located shall be posted against trespassing. Where the tank is located in an area requiring protection from tampering, the tank shall be secured in a manner to resist tampering. Add an appendix item, as follows: A 21.7.2.2 The committee recognizes that the tank owner has a responsibility to maintain the tank in a safe manner, including appropriate notification of the fire and deflagration hazards associated with the tank contents, to the public, when the tank is readily accessible to the public. The committee also recognizes that the public has a responsibility to behave appropriately when notified of the hazards associated with the tank's contents, or when notified not to trespass, or when the tank owner has taken measures to prevent the public from tampering with the tank. Wechsler proposal A21.7.2.2 The committee is in general agreement with findings in the September 2011 CSB final report that three explosions in Mississippi, Oklahoma, and Texas in unsupervised remotely isolated above ground storage tanks perhaps could have been prevented or made less likely by actions of the responsible tank owner to restrict access to the facilities, to provide warning signage to identify the fire hazards of the tank contents (See NFPA 704) , by securing the hatches on the tanks, or utilizing inherently safer tank design at these facilities. These are all important aspects which are addressed in this requirement which when properly implemented could prevent additional such incidents. From: To: Subject: Date: Hiscott Jr, David J "Krumpolc, Judith A"; Benedetti, Bob; Geyer, Wayne; Haines, Steve; Havens, Dwight; Kraus, Dick; Paplawski, Robert; Renkes, Bob; Wechsler, Dave RE: NFPA 30 Group 1 sub team appendix Tuesday, June 11, 2013 9:12:11 AM My concern is that we are listing specific measures in the annex. I realize that the annex is non – mandatory but sometimes these things creep into the code in later revisions. We are also proposing to use several key “undefined” words such as “ unsupervised” and “remote” and these terms will have different meanings to different AHJ’s and operators. If we do not define these terms then the standard dictionary definition applies and that will not provide guidance. Each tank may pose a different hazard and to provide flexibility, we should consider defaulting to allowing operators to conduct an assessment. My proposal: The committee is in general agreement with findings in the September 2011 CSB final report that three explosions in Mississippi, Oklahoma, and Texas in unsupervised remotely isolated above ground storage tanks. Storage tanks should be protected from tampering or trespassing by warning signage that identify the fire hazards of the tank contents. Additional security measures should be developed based on fire and security risk assessments conducted by the operator and petroleum industry practices. Additional security measures could include providing a latched gate at the stairs leading to the tank platform and recommendations from the CSB report. David Hiscott CSP, CPP Phillips 66 Transportation Emergency Preparedness Response and Security 3010 Briarpark Dr, PWC - 7330-29 Houston, TX 77042 Office - 832-765-1689 Cell - 817-715-8951 NOTE: New Contact information From: Krumpolc, Judith A [mailto:[email protected]] Sent: Monday, June 10, 2013 4:05 PM To: Benedetti, Bob; Geyer, Wayne; Haines, Steve; Havens, Dwight; Hiscott Jr, David J; Kraus, Dick; Paplawski, Robert; Renkes, Bob; Wechsler, Dave Subject: [EXTERNAL]RE: NFPA 30 Group 1 sub team appendix Bob and Task Group Members: My concern with the Wechsler proposal A21.7.2.2 is for the tanks that are remotely located, isolated, but not threatened by the public as much as in southern states, such as in remote places in Alaska. It is important to note that the biggest companies in the oil and gas industry are working together with API to develop an annex for API RP 12R1, to include a requirement for a latched gate at the stairs leading to the platform for such remote tanks to respond to the same CSB report cited in the annex referenced by NFPA. Should NFPA should do similarly to avoid confusion? I suggest we include a statement allowing the tank owner to make the decision when to add protective measures and give examples of additional protective measures. The signage should be mandatory, but the additional protection should be added “when necessary” as determined by the operator when public access is a relevant threat as measured by risk assessment. I propose the following for the annex: The committee is in general agreement with findings in the September 2011 CSB final report that three explosions in Mississippi, Oklahoma, and Texas in unsupervised remotely isolated above ground storage tanks. Storage tanks should be protected from tampering or trespassing by warning signage that identify the fire hazards of the tank contents. When public access is a relevant threat, obvious protective measures should be implemented to help prevent the public from tampering with the unsupervised, remotely located tanks by providing a latched gate at the stairs leading to the platform. In highly susceptible areas, unsupervised, remotely located tanks require additional protective measures which includes any or all the following: securing the hatches on the tanks, restricting access to the entire facility, or utilizing inherently safer tank design at these facilities. I welcome any feedback. Judy Krumpolc Technical Authority- Fire and Explosion Analysis Safety + Operational Risk, Deployed R&M 150 W. Warrenville Rd. Naperville, IL 60563 Office 630 536-2804; Mobile 630 815-2098; Fax 630 420-4501 Confidentiality Notice: This electronic transmission and any documents sent with it constitute confidential, inside or non-public information. If you are not the intended recipient or have received this communication in error, please resend this communication to the sender and delete it from your computer system. Any use or disclosure of the contents of this communication by anyone other than an intended recipient is strictly prohibited and may be unlawful. Thank you. From: Benedetti, Bob [mailto:[email protected]] Sent: Monday, June 10, 2013 10:08 AM To: Geyer, Wayne; Haines, Steve; Havens, Dwight; Hiscott, Dave; Kraus, Dick; Krumpolc, Judith A; Paplawski, Robert; Renkes, Bob; Wechsler, Dave Subject: NFPA 30 Group 1 sub team appendix TO: NFPA 30 FLCTAN Task Group 1 Please see attached proposed new annex text from Dave Wechsler and provide comment. From: David Wechsler [mailto:[email protected]] Sent: Monday, June 10, 2013 10:27 AM To: Benedetti, Bob Subject: Re: NFPA 30 Group 1 sub team appendix Bob, I pulled up a copy of the final CSB Jan 2011 report on the tank incidents. While there is a lot in this report, I attempted rather than to repeat the information, simply summarize it within the context of our existing statement. Hopefully this accomplishes the sub team objective and still gives the CSB a means to show that our Committee is supporting their efforts. Please look this over, make inputs as you feel might be good, and then send this out to the sub team for additional comment and review. Thanks. National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... ATTACHMENT No. A5 Committee Input No. 11-NFPA 30-2012 [ Section No. 22.4 ] 22.4 * Location of Aboveground Storage Tanks. 22.4.1 Location with Respect to Property Lines, Public Ways, and Important Buildings. 1 of 8 6/3/2013 10:37 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... 22.4.1.1 2 of 8 6/3/2013 10:37 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... Tanks storing Class I, Class II, or Class IIIA stable liquids whose internal pressure is not permitted to exceed a gauge pressure of 2.5 psi (17 kPa) shall be located in accordance with Table 22.4.1.1(a) and Table 22.4.1.1(b). Where tank spacing is based on a weak roof-to-shell seam design, the user shall present evidence certifying such construction to the authority having jurisdiction upon request. Table 22.4.1.1(a) Location of Aboveground Storage Tanks Storing Stable Liquids — Internal Pressure Not to Exceed a Gauge Pressure of 2.5 psi (17 kPa) Minimum Distance (ft) Type of Tank Floating roof Protection Protected aboveground tank From Nearest Side of Any Public Way or from Nearest Important Building on the Same a Property Protection for b exposures 1 None Diameter of tank but need 1 ?6 × diameter of tank not exceed 175 ft Approved foam or c Vertical with weak roof-to-shell inerting system on seam tanks not exceeding d 150 ft in diameter Horizontal and vertical tanks with emergency relief venting to limit pressures to 2.5 psi (gauge pressure of 17 kPa) From Property Line That Is or Can Be Built Upon, Including the Opposite Side of a a Public Way 1 ?2 × diameter of tank ?2 × diameter of tank 1 ?6 × diameter of tank 1 ?6 × diameter of tank Protection for b exposures Diameter of tank 1 ?3 × diameter of tank None 2 × diameter of tank but need not exceed 350 ft 1 ?3 × diameter of tank Approved inerting 1 b system on the tank or ?2 × value in Table approved foam system 22.4.1.1(b) on vertical tanks 1 ?2 × value in Table 22.4.1.1(b) Protection for b exposures Value in Table 22.4.1.1(b) Value in Table 22.4.1.1(b) None 2 × value in Table 22.4.1.1(b) Value in Table 22.4.1.1(b) 1 1 ?2 × value in Table 22.4.1.1(b) None ?2 × value in Table 22.4.1.1(b) For SI units, 1 ft = 0.3 m. a b c The minimum distance cannot be less than 5 ft (1.5 m). See definition 3.3.46, Protection for Exposures. See NFPA 69, Standard on Explosion Prevention Systems. d For tanks over 150 ft (45 m) in diameter, use “Protection for Exposures” or “None,” as applicable. Table 22.4.1.1(b) Reference Table for Use with Tables 22.4.1.1(a), 22.4.1.3, and 22.4.1.5 Minimum Distance (ft) 3 of 8 Tank Capacity (gal) From Property Line that Is or Can Be Built Upon, Including the Opposite Side of a Public Way From Nearest Side of Any Public Way or from Nearest Important Building on the Same Property 275 or less 5 5 276 to 750 10 5 6/3/2013 10:37 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... Minimum Distance (ft) Tank Capacity (gal) From Property Line that Is or Can Be Built Upon, Including the Opposite Side of a Public Way From Nearest Side of Any Public Way or from Nearest Important Building on the Same Property For SI units, 1 ft = 0.3 m; 1 gal = 3.8 L. 22.4.1.2 Vertical tanks with weak roof-to-shell seams (see 22.7.2) that store Class IIIA liquids shall be permitted to be located at one-half the distances specified in Table 22.4.1.1(a), provided the tanks are not within the same diked area as, or within the drainage path of, a tank storing a Class I or Class II liquid. 22.4.1.3 Tanks storing Class I, Class II, or Class IIIA stable liquids and operating at pressures that exceed a gauge pressure of 2.5 psi (17 kPa), or are equipped with emergency venting that will permit pressures to exceed a gauge pressure of 2.5 psi (17 kPa), shall be located in accordance with Table 22.4.1.3 and Table 22.4.1.1(b). Table 22.4.1.3 Location of Aboveground Storage Tanks Storing Stable Liquids — Internal Pressure Permitted to Exceed a Gauge Pressure of 2.5 psi (17 kPa) Minimum Distance (ft) Type of Tank Any type Protection From Property Line that Is or Can Be From Nearest Side of Any Public Way Built Upon, Including the Opposite or from Nearest Important Building on Side of a Public Way the Same Property Protection for * exposures 1 1?2 × value in Table 22.4.1.1(b) but not 1 1?2 × value in Table 22.4.1.1(b) but not less than 25 ft less than 25 ft None 3 × value in Table 22.4.1.1(b) but not be 1 1?2 × value in Table 22.4.1.1(b) but not less than 25 ft less than 50 ft For SI units, 1 ft = 0.3 m. * 4 of 8 See definition 3.3.46, Protection for Exposures. 6/3/2013 10:37 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... 22.4.1.4 Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22.4.1.4. Liquids with boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter, unless an approved inerting system is provided on the tank. Table 22.4.1.4 Location of Aboveground Storage Tanks Storing Boil-Over Liquids Minimum Distance (ft) Type of Tank Floating roof Fixed roof From Property Line that Is or Can Be Built Upon, Including the a Opposite Side of a Public Way Protection Protection for b exposures 1 None From Nearest Side of Any Public Way or from Nearest Important a Building on the Same Property 1 ?6 × diameter of tank Diameter of tank 1 ?6 × diameter of tank Approved foam or c Diameter of tank inerting system 1 ?3 × diameter of tank Protection for b exposures 2 × diameter of tank 2 ?3 × diameter of tank None 4 × diameter of tank but need not exceed 350 ft 2 ?3 × diameter of tank ?2 × diameter of tank For SI units, 1 ft = 0.3 m. a b c 5 of 8 The minimum distance cannot be less than 5 ft. See definition 3.3.46, Protection for Exposures. See NFPA 69, Standard on Explosion Prevention Systems. 6/3/2013 10:37 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... 22.4.1.5 Tanks storing unstable liquids shall be located in accordance with Table 22.4.1.5 and Table 22.4.1.1(b). Table 22.4.1.5 Location of Aboveground Storage Tanks Storing Unstable Liquids Minimum Distance (ft) Type of Tank From Nearest Side of From Property Line Any Public Way or that Is or Can Be from Nearest Built Upon, Including Important Building on the Opposite Side of a a Public Way the Same Property Protection Tank protected with any one of Horizontal and vertical tanks the following: approved water Value in Table with emergency relief a 22.4.1.1(b) but not less Not less than 25 ft venting to permit pressure spray, approved inerting, approved insulation and than 25 ft not in excess of a gauge pressure of 2.5 psi (17 kPa) refrigeration, approved barricade Protection for exposures b 2 1?2 × value in Table 22.4.1.1(b) but not less Not less than 50 ft than 50 ft 5 × value in Table 22.4.1.1(b) but not less Not less than 100 ft than 100 ft None Tank protected with any one of Horizontal and vertical tanks the following: approved water 2 × value in Table with emergency relief a 22.4.1.1(b) but not less Not less than 50 ft venting to permit pressure spray, approved inerting, approved insulation and than 50 ft over a gauge pressure of refrigeration, approved 2.5 psi (17 kPa) barricade Protection for exposures b None 4 × value in Table 22.4.1.1(b) but not less Not less than 100 ft than 100 ft 8 × value in Table 22.4.1.1(b) but not less Not less than 150 ft than 150 ft For SI units, 1 ft = 0.3 m. a b 6 of 8 See NFPA 69, Standard on Explosion Prevention Systems. See definition 3.3.46, Protection for Exposures. 6/3/2013 10:37 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... 22.4.1.6 Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22.4.1.6. Table 22.4.1.6 Location of Aboveground Storage Tanks Storing Class IIIB Liquids Minimum Distance (ft) Tank Capacity (gal) From Property Line that Is or Can Be Built Upon, Including the Opposite Side of a Public Way 12,000 or less 5 From Nearest Side of Any Public Way or from Nearest Important Building on the Same Property 5 12,001 to 30,000 10 5 30,001 to 50,000 10 10 50,001 to 100,000 15 10 100,001 or more 15 15 For SI units, 1 ft = 0.3 m; 1 gal = 3.8 L. Exception : If located within the same diked area as, or within the drainage path of, a tank storing a Class I or Class II liquid, the tank storing Class IIIB liquid shall be located in accordance with 22.4.1.1. 22.4.1.7 Where two tank properties of diverse ownership have a common boundary, the authority having jurisdiction shall be permitted, with the written consent of the owners of the two properties, to substitute the distances provided in 22.4.2 for the minimum distances set forth in 22.4.1.1. 22.4.1.8 Where end failure of a horizontal pressure tank or vessel can expose property, the tank or vessel shall be placed with its longitudinal axis parallel to the nearest important exposure. 22.4.2 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks. 22.4.2.1 * Tanks storing Class I, Class II, or Class IIIA stable liquids shall be separated by the distances given in Table 22.4.2.1 . Table 22.4.2.1 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks Fixed or Horizontal Tanks Tank Diameter Floating Roof Tanks 1 All tanks not over 150 ft (45 m) in diameter Class I or II Liquids 1 Class IIIA Liquids 1 ?6 × sum of adjacent tank ?6 × sum of adjacent tank ?6 × sum of adjacent tank diameters but not less than diameters but not less than diameters but not less than 3 ft (0.9 m) 3 ft (0.9 m) 3 ft (0.9 m) Tanks larger than 150 ft (45 m) in diameter: ?If remote impounding is provided in accordance with 22.11.1 1 ?6 × sum of adjacent tank 1?4 × sum of adjacent tank 1?6 × sum of adjacent tank diameters diameters diameters ?If open diking is provided 1?4 × sum of adjacent tank 1?3 × sum of adjacent tank 1?4 × sum of adjacent tank diameters diameters in accordance with 22.11.2 diameters Note: The “sum of adjacent tank diameters” means the sum of the diameters of each pair of tanks that are adjacent to each other. See also A.22.4.2.1. 22.4.2.1.1 3 Tanks that store crude petroleum, have individual capacities not exceeding 3000 bbl [126,000 gal (480 m )], and are located at production facilities in isolated locations shall not be required to be separated by more than 3 ft (0.9 m). 7 of 8 6/3/2013 10:37 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... 22.4.2.1.2 Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (0.9 m) provided they are not within the same diked area as, or within the drainage path of, a tank storing a Class I or Class II liquid. If located within the same diked area as, or within the drainage path of, a tank storing a Class I or Class II liquid, the tank storing Class IIIB liquid shall be spaced in accordance with the requirements for Class IIIA liquids in Table 22.4.2.1 . 22.4.2.2 A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or a Class I, II, or III liquid by a distance not less than one-half the sum of their diameters. 22.4.2.3 Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or Class II liquids and are compacted in three or more rows or in an irregular pattern, greater spacing or other means shall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the pattern accessible for fire-fighting purposes. 22.4.2.4 The minimum horizontal separation between an LP-Gas container and a Class I, Class II, or Class IIIA liquid storage tank shall be 20 ft (6 m). 22.4.2.4.1 Means shall be provided to prevent Class I, Class II, or Class IIIA liquids from accumulating under adjacent LP-Gas containers by means of dikes, diversion curbs, or grading. 22.4.2.4.2 Where flammable or combustible liquid storage tanks are within a diked area, the LP-Gas containers shall be outside the diked area and at least 3 ft (0.9 m) away from the centerline of the wall of the diked area. 22.4.2.5 If a tank storing a Class I, Class II, or Class IIIA liquid operates at pressures exceeding a gauge pressure of 2.5 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gauge pressure of 2.5 psi (17 kPa), it shall be separated from an LP-Gas container by the appropriate distance given in Table 22.4.2.1. 22.4.2.6 The requirements of 22.4.2.4 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity are installed adjacent to fuel oil supply tanks of 660 gal (2500 L) or less capacity. Submitter Information Verification Submitter Full Name: [ Not Specified ] Organization: [ Not Specified ] Submittal Date: Thu Sep 27 10:17:59 EDT 2012 Committee Statement and Meeting Notes Committee Statement: The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need for further regulation of the pressure limitations on the outer shell of aboveground secondary containment-type tanks under emergency venting conditions. Public comments are sought to provide input for possible Technical Committee action at the second draft meeting. See also Committee Input #12 on Section 22.7. Response Message: Ballot Results This item has not been balloted 8 of 8 6/3/2013 10:37 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... Committee Input No. 12-NFPA 30-2012 [ Section No. 22.7 ] 22.7 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks. 22.7.1 General. 22.7.1.1 Every aboveground storage tank shall have emergency relief venting in the form of construction or a device or devices that will relieve excessive internal pressure caused by an exposure fire. 22.7.1.1.1 This requirement shall apply to each compartment of a compartmented tank, the interstitial space (annulus) of a secondary containment–type tank, and the enclosed space of tanks of closed-top dike construction. 22.7.1.1.2 This requirement shall also apply to spaces or enclosed volumes, such as those intended for insulation, membranes, or weather shields, that are capable of containing liquid because of a leak from the primary vessel. The insulation, membrane, or weather shield shall not interfere with emergency venting. 22.7.1.1.3 Tanks storing Class IIIB liquids that are larger than 12,000 gal (45,400 L) capacity and are not within the diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet the requirements of 22.7.1.1. 22.7.1.2 For vertical tanks, the emergency relief venting construction referred to in 22.7.1.1 shall be permitted to be a floating roof, a lifter roof, a weak roof-to-shell seam, or another approved pressure-relieving construction. 22.7.1.3 If unstable liquids are stored, the effects of heat or gas resulting from polymerization, decomposition, condensation, or self-reactivity shall be taken into account. 22.7.1.4 If two-phase flow is anticipated during emergency venting, an engineering evaluation shall be conducted in order to size the pressure-relieving devices. 22.7.2 Weak Roof-to-Shell Seam Construction. If used, a weak roof-to-shell seam shall be constructed to fail preferential to any other seam and shall be designed in accordance with API Standard 650, Welded Steel Tanks for Oil Storage, or ANSI/UL 142, Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids. 22.7.3 Pressure-Relieving Devices. 22.7.3.1 * Where entire dependence for emergency relief venting is placed upon pressure-relieving devices, the total venting capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell or bottom of a vertical tank or of the shell or heads of a horizontal tank. 22.7.3.2 1 of 5 6/3/2013 10:39 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... Except as provided for in 22.7.3.5, 22.7.3.6 and 22.7.3.7, the total emergency relief venting capacity of both normal and emergency venting devices shall be not less than that determined in Table 22.7.3.2. (See Annex B for the square footage of typical tank sizes.) Table 22.7.3.2 Required Emergency Relief Venting — Cubic Feet of Free Air per Hour (CFH) versus Wetted Area of Tank Shell (ft2) 2 ft CFH 2 ft CFH ft 2 CFH 20 21,100 160 168,000 900 493,000 30 31,600 180 190,000 1000 524,000 40 42,100 200 211,000 1200 557,000 50 52,700 250 239,000 1400 587,000 60 63,200 300 265,000 1600 614,000 70 73,700 350 288,000 1800 639,000 80 84,200 400 312,000 2000 662,000 90 94,800 500 354,000 2400 704,000 100 105,000 600 392,000 2800 742,000 120 126,000 700 428,000 140 147,000 800 462,000 and over 2 2 3 3 For SI units, 10 ft = 0.93 m ; 36 ft = 1.0 m . Notes: (1) Interpolate for intermediate values not specified in the table. (2) CFH is flow capacity at absolute pressure of 14.7 psi (101 kPa) and 60°F (15.6°C). See 22.7.3.10.2. 22.7.3.2.1 Emergency relief vent devices shall be vaportight and shall be permitted to be any one of the following: (1) Self-closing manway cover (2) Manway cover provided with long bolts that permit the cover to lift under internal pressure (3) Additional or larger relief valve or valves 22.7.3.2.2 The wetted area of the tank shall be calculated as follows: (1) Fifty-five percent of the total exposed area of a sphere or spheroid (2) Seventy-five percent of the total exposed area of a horizontal tank (3) One hundred percent of the exposed shell and floor area of a rectangular tank, but excluding the top surface of the tank (4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank 2 of 5 6/3/2013 10:39 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... 22.7.3.3 * The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressures above a gauge pressure of 1.0 psi (6.9 kPa) shall be as follows: (1) 2 2 For tanks whose wetted area does not exceed 2800 ft (260 m ), not less than that determined in Table 22.7.3.2 (2) 2 2 For tanks whose wetted area exceeds 2800 ft (260 m ), not less than that determined in Table 22.7.3.3 or not less than that calculated by the following formula: where: CFH = 3 venting capacity requirement (ft of free air per hour) A= 2 wetted area (ft ) Table 22.7.3.3 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) and Operating at Gauge Pressure over 1 psi (6.9 kPa) — Cubic Feet of Free Air per Hour (CFH) versus Wetted Area of Tank Shell (ft2) 2 ft 2 ft CFH CFH 2,800 742,000 9,000 1,930,000 3,000 786,000 10,000 2,110,000 3,500 892,000 15,000 2,940,000 4,000 995,000 20,000 3,720,000 4,500 1,100,000 25,000 4,470,000 5,000 1,250,000 30,000 5,190,000 6,000 1,390,000 35,000 5,900,000 7,000 1,570,000 40,000 6,570,000 8,000 1,760,000 2 2 3 3 For SI units, 10 ft = 0.93 m ; 36 ft = 1.0 m . Notes: (1) Interpolate for intermediate values not specified in the table. (2) CFH is flow capacity at absolute pressure of 14.7 psi (101 kPa) and 60°F (15.6°C). See 22.7.3.10.2. 22.7.3.4 The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined by the following formula: where: CFH = 3 venting capacity requirement (ft of free air per hour) V= 3 ft of free air per hour (CFH) value from Table 22.7.3.2 L = latent heat of vaporization of specific liquid (Btu/lb) M = molecular weight of specific liquids 3 of 5 6/3/2013 10:39 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... 22.7.3.5 Except as provided for in 22.7.3.6 and 22.7.3.7, for tanks containing stable liquids, the required emergency relief venting capacity determined by 22.7.3.2, 22.7.3.3, or 22.7.3.4 shall be permitted to be multiplied by one of the following reduction factors when protection is provided as indicated. Only one of the following factors shall be used for any one tank: (1) 2 2 A reduction factor of 0.5 shall be allowed for tanks with wetted area greater than 200 ft (19 m ) that are provided with drainage that meets the requirements of 22.11.1 . (2) A reduction factor of 0.3 shall be allowed for tanks that are protected with a water spray system that meets the requirements of NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection, and that are provided with drainage that meets the requirements of 22.11.1. (3) A reduction factor of 0.3 shall be allowed for tanks that are protected with an automatically actuated water spray system that meets the requirements of NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection. (4) A reduction factor of 0.3 shall be allowed for tanks protected with insulation that meets the requirements of 22.7.3.8. (5) A reduction factor of 0.15 shall be allowed for tanks that are protected with a water spray system that meets the requirements of NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection, and that have insulation that meets the requirements of 22.7.3.8. 22.7.3.6 * Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than those of ethyl alcohol (ethanol) are stored, processed, or handled and where there is no potential fire exposure from liquids other than these liquids, the emergency relief venting capacity shall be permitted to be reduced by an additional 50 percent. Drainage shall not be required to obtain this reduction. In no case shall the factors in 22.7.3.5 (1) through 22.7.3.5 (5) be reduced to less than 0.15. 22.7.3.7 * Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to or less than those of ethyl alcohol (ethanol) are stored, processed, or handled and where there is no potential fire exposure from liquids other than these liquids, the emergency relief venting capacity determined by 22.7.3.5 (1) or 22.7.3.5 (3) shall be permitted to be reduced by an additional 50 percent. No further reduction shall be allowed for protection by means of water spray. Drainage shall not be required to obtain this reduction. In no case shall the factors in 22.7.3.5 (1) through 22.7.3.5 (5) be reduced to less than 0.15. 22.7.3.8 Insulation for which credit is taken in 22.7.3.5 (4) and 22.7.3.5 (5) shall meet the following performance criteria: (1) The insulation shall remain in place under fire exposure conditions. (2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fire exposure. (3) 2 2 The insulation shall maintain a maximum conductance value of 4.0 Btu/hr/ft /°F (2.3 W/m /°C) when the outer insulation jacket or cover is at a temperature of 1660°F (904°C) and when the mean temperature of the insulation is 1000°F (538°C). Exception : The requirement of 22.7.3.8 (2) need not apply where use of solid hose streams is not contemplated or would not be practical. 22.7.3.9 The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressures to exceed a gauge pressure of 2.5 psi (17.2 kPa) shall be arranged to discharge so that localized overheating of or flame impingement on any part of the tank will not occur if vapors from the vents are ignited. 22.7.3.10 4 of 5 6/3/2013 10:39 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... Each commercial tank venting device shall have the following information either stamped or cast into the metal body of the device or included on a metal nameplate permanently affixed to it. (1) Start-to-open pressure (2) Pressure at which the valve reaches the full open position (3) Flow capacity at the pressure indicated by 22.7.3.10 (2) 22.7.3.10.1 If the start-to-open pressure is less than a gauge pressure of 2.5 psi (17.2 kPa) and the pressure at the full open position is greater than a gauge pressure of 2.5 psi (17.2 kPa), the flow capacity at a gauge pressure of 2.5 psi (17.2 kPa) shall also be stamped on the venting device. 22.7.3.10.2 The flow capacity shall be expressed in cubic feet per hour of air at 60°F (15.6°C) and an absolute pressure of 14.7 psi (101 kPa). 22.7.3.10.3 The flow capacity of tank venting devices less than 8 in. (200 mm) in nominal pipe size shall be determined by actual test. These tests shall be permitted to be conducted by a qualified, impartial outside agency or by the manufacturer if certified by a qualified, impartial observer. 22.7.3.10.4 * The flow capacity of tank venting devices equal to or greater than 8 in. (200 mm) nominal pipe size, including manway covers with long bolts, shall be determined by test or by calculation. If determined by calculation, the opening pressure shall be measured by test, the calculation shall be based on a flow coefficient of 0.5 applied to the rated orifice, the rating pressure and corresponding free orifice area shall be stated, and the word calculated shall appear on the nameplate. 22.7.4 * Extension of Emergency Vent Piping. Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized to provide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by the design of the tank. Piping to or from approved emergency vent devices for pressure vessels shall be sized in accordance with the ASME Boiler and Pressure Vessel Code. Submitter Information Verification Submitter Full Name: [ Not Specified ] Organization: [ Not Specified ] Submittal Date: Thu Sep 27 10:18:37 EDT 2012 Committee Statement and Meeting Notes Committee Statement: The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need for further regulation of the pressure limitations on the outer shell of aboveground secondary containment-type tanks under emergency venting conditions. Public comments are sought to provide input for possible Technical Committee action at the second draft meeting. See also Committee Input #11 on Section 22.4. Response Message: Ballot Results This item has not been balloted 5 of 5 6/3/2013 10:39 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... Public Comment No. 20-NFPA 30-2013 [ Section No. 21.4.2.1.4 ] 21.4.2.1.4 Horizontal cylindrical and rectangular tanks built according to any of the standards specified in 21.4.2.1.1 shall be permitted to operate at pressures from atmospheric to a gauge pressure of 1.0 psi (6.9 kPa) and shall be limited to a shall not exceed a gauge pressure of 2.5 psi (17 kPa) under emergency venting conditions. The same requirement applies to every compartment and any interstitial space of such tanks. Additional Proposed Changes File Name Description Approved ✓ 30_Grainawi.pdf Statement of Problem and Substantiation for Public Comment Related Items 11 and 12. There is confusion on what is intended in NFPA 30 regarding emergency venting. The purpose of this proposal is to clarify that: 1) Table 22.4.1.1(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 2.5 psi. 2) Section 21.4.2.1.4 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 2.5 psi. 3) Clarify that the same emergency venting requirements are required for all areas of the tank the primary tank, each compartment of the primary tank, any interstitial spaces, etc. as outlined in 22.7.1.1.1 and 22.7.1.1.2. 4) If the same emergency venting requirements are used for all areas, then it follows that the emergency venting of the secondary tank (interstitial space) must function at a maximum 2.5 psi. Applying the same emergency relief venting requirements, which is that the venting mechanism must operate at a maximum 2.5 psig, is the easiest and safest way to assure that atmospheric tanks do not create any additional hazards in a fire situation. The concerns are twofold. First, is the need to assure that any area of the tank not rupturing in an unintended manner (keeping in mind that tanks vented by form of construction will rupture at an intended point on the tank). Second, is the need to assure that the primary tank not buckle or collapse which could push product out of the tank into an ongoing fire. The decision to use 2.5 as the maximum venting pressure was chosen a long time ago. It is a tried and true method. Tanks that have ruptured in fire situations have done so because they did not meet the requirements of this code. Shop fabricated atmospheric tanks, because of their smaller size than field erected tanks, have a greater wetted surface area to volume ratio, which in itself creates a higher potential for emergency venting operation. Another consideration is the structural strength of the primary tank. If the interstitial space were to overpressurize, the primary tank at some pressure will collapse or buckle which could force product out of the tank, into the fire, further igniting the hazard. This again, is not a condition that has been encountered in double wall shop fabricated tanks. UL 142, since the introduction of double wall tanks, has required that venting of the secondary tank meet the same requirements as the primary tank. Table 8.1 in UL 142, Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks, uses Table 22.7.3.2, which suggests that NFPA should adopt the same policy. Further, I have deleted the reference to the UL 142 standard in 22.7.2 because the weak roof to shell joint as a form of emergency venting is no longer allowed in UL 142. UL 2085 does, however, have a performance test for venting by form of construction, so I am proposing to add the UL 2085 standard. I am also suggesting editorial corrections to the language for the purpose of making sections 22.4.1.1 and 22.7.1.1 easier to read. In section 22.4.1.1, I am proposing to change, “is not permitted to”, to, “shall not” because the first is generally considered to be permissive language. Also, an AHJ does not certify “such” anything, but rather certifies “the construction”. Submitter Information Verification Submitter Full Name: Lorri Grainawi 1 of 2 Organization: Steel Tank Institute Submittal Date: Wed May 08 15:11:35 EDT 2013 6/3/2013 10:48 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... Public Comment No. 21-NFPA 30-2013 [ Section No. 22.4.1.1 ] 1 of 5 6/3/2013 10:49 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... 22.4.1.1 2 of 5 6/3/2013 10:49 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... Tanks storing Class I, Class II, or Class IIIA stable liquids whose internal pressure is not permitted to exceed pressure of every compartment of the tank and any interstitial space of the tank shall not exceed a gauge pressure of 2.5 psi (17 kPa) shall . The tanks shall be located in accordance with Table 22.4.1.1(a) and Table 22.4.1.1(b) . Where tank spacing is based on a weak roof-to-shell seam a venting by form of construction design, the user shall present evidence certifying such construction to the authority having jurisdiction upon request , certifying the construction complies with this requirement . Table 22.4.1.1(a) Location of Aboveground Storage Tanks Storing Stable Liquids — Internal Pressure Not to Exceed a Gauge Pressure of 2.5 psi (17 kPa) Minimum Distance (ft) Type of Tank Floating roof Vertical with weak roof-to-shell seam Horizontal and vertical tanks with emergency relief venting to limit pressures to 2.5 psi (gauge pressure of 17 kPa) Protected aboveground tank From Property Line That Is or Can Be Built Upon, Including the Opposite Side of a a Public Way Protection From Nearest Side of Any Public Way or from Nearest Important Building on the Same a Property Protection for b exposures 1 ⁄ 2 × diameter of tank None 1 ⁄ 6 × diameter of Diameter of tank but need not exceed 175 ft tank Approved foam or c inerting system on tanks not exceeding d 150 ft in diameter 1 ⁄ 2 × diameter of tank 1 ⁄ 6 × diameter of tank Protection for b exposures Diameter of tank 1 ⁄ 3 × diameter of tank None 2 × diameter of tank but need not exceed 350 ft 1 ⁄ 3 × diameter of tank Approved inerting b system on the tank or approved foam system on vertical tanks 1 ⁄ 2 × value in Table 22.4.1.1(b) 1 ⁄ 2 × value in Table 22.4.1.1(b) Protection for b exposures Value in Table 22.4.1.1(b) Value in Table 22.4.1.1(b) None 2 × value in Table 22.4.1.1(b) Value in Table 22.4.1.1(b) None 1 ⁄ 2 × value in Table 22.4.1.1(b) 1 ⁄ 2 × value in Table 22.4.1.1(b) 1 ⁄ 6 × diameter of tank For SI units, 1 ft = 0.3 m. a b c d The minimum distance cannot be less than 5 ft (1.5 m). See definition 3.3.46, Protection for Exposures. See NFPA 69, Standard on Explosion Prevention Systems . For tanks over 150 ft (45 m) in diameter, use “Protection for Exposures” or “None,” as applicable. Table 22.4.1.1(b) Reference Table for Use with Tables 22.4.1.1(a), 22.4.1.3, and 22.4.1.5 Minimum Distance (ft) 3 of 5 6/3/2013 10:49 PM National Fire Protection Association Report Tank Capacity (gal) http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... From Property Line that Is or Can Be Built Upon, Including the Opposite Side of a Public Way From Nearest Side of Any Public Way or from Nearest Important Building on the Same Property 275 or less 5 5 276 to 750 10 5 751 to 12,000 15 5 12,001 to 30,000 20 5 30,001 to 50,000 30 10 50,001 to 100,000 50 15 100,001 to 500,000 80 25 500,001 to 1,000,000 100 35 1,000,001 to 2,000,000 135 45 2,000,001 to 3,000,000 165 55 3,000,001 or more 175 60 For SI units, 1 ft = 0.3 m; 1 gal = 3.8 L. Additional Proposed Changes File Name 30_Grainawi.pdf Description Approved ✓ Statement of Problem and Substantiation for Public Comment Related to Items 11 and 12 There is confusion on what is intended in NFPA 30 regarding emergency venting. The purpose of this proposal is to clarify that: 1) Table 22.4.1.1(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 2.5 psi. 2) Section 21.4.2.1.4 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 2.5 psi. 3) Clarify that the same emergency venting requirements are required for all areas of the tank the primary tank, each compartment of the primary tank, any interstitial spaces, etc. as outlined in 22.7.1.1.1 and 22.7.1.1.2. 4) If the same emergency venting requirements are used for all areas, then it follows that the emergency venting of the secondary tank (interstitial space) must function at a maximum 2.5 psi. Applying the same emergency relief venting requirements, which is that the venting mechanism must operate at a maximum 2.5 psig, is the easiest and safest way to assure that atmospheric tanks do not create any additional hazards in a fire situation. The concerns are twofold. First, is the need to assure that any area of the tank not rupturing in an unintended manner (keeping in mind that tanks vented by form of construction will rupture at an intended point on the tank). Second, is the need to assure that the primary tank not buckle or collapse which could push product out of the tank into an ongoing fire. The decision to use 2.5 as the maximum venting pressure was chosen a long time ago. It is a tried and true method. Tanks that have ruptured in fire situations have done so because they did not meet the requirements of this code. Shop fabricated atmospheric tanks, because of their smaller size than field erected tanks, have a greater wetted surface area to volume ratio, which in itself creates a higher potential for emergency venting operation. Another consideration is the structural strength of the primary tank. If the interstitial space were to overpressurize, the primary tank at some pressure will collapse or buckle which could force product out of the tank, into the fire, further igniting the hazard. This again, is not a condition that has been encountered in double wall shop fabricated tanks. UL 142, since the introduction of double wall tanks, has required that venting of the secondary tank meet the same requirements as the primary tank. Table 8.1 in UL 142, Emergency venting capacity for primary tanks and interstitial 4 of 5 6/3/2013 10:49 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... space of secondary containment tanks, uses Table 22.7.3.2, which suggests that NFPA should adopt the same policy. Further, I have deleted the reference to the UL 142 standard in 22.7.2 because the weak roof to shell joint as a form of emergency venting is no longer allowed in UL 142. UL 2085 does, however, have a performance test for venting by form of construction, so I am proposing to add the UL 2085 standard. I am also suggesting editorial corrections to the language for the purpose of making sections 22.4.1.1 and 22.7.1.1 easier to read. In section 22.4.1.1, I am proposing to change, “is not permitted to”, to, “shall not” because the first is generally considered to be permissive language. Also, an AHJ does not certify “such” anything, but rather certifies “the construction”. Submitter Information Verification Submitter Full Name: Lorri Grainawi Organization: Steel Tank Institute Submittal Date: Thu May 09 11:44:07 EDT 2013 Copyright Assignment I, Lorri Grainawi, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Lorri Grainawi, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature 5 of 5 6/3/2013 10:49 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... Public Comment No. 27-NFPA 30-2013 [ New Section after 22.7 ] TITLE OF NEW CONTENT No recommendation provided. Additional Proposed Changes File Name Description Approved 30_Holmes.pdf ✓ Statement of Problem and Substantiation for Public Comment Yes, 2.5 psi limit should be mandated for the interstice. This will give a safety factor of 2 for venting (5 psi test pressure of the tank)(we know steel tanks can handle more than 5 psi). Emergency vents are rated a 2.5 psi, any other rating will require testing of the e vent for airflow. When large AST's have properly installed safety accessories, additional diking should not be necessary. The OPV, etc. are sufficient to prevent spills or accidental liquid discharges, thus additional measures such as dikes are not necessary. Submitter Information Verification Submitter Full Name: Bradford Holmes Organization: Clay & Bailey Mfg. Co. Submittal Date: Thu May 09 14:30:41 EDT 2013 Copyright Assignment I, Bradford Holmes, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Bradford Holmes, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature 1 of 1 6/3/2013 10:50 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... Public Comment No. 22-NFPA 30-2013 [ Section No. 22.7.1.1 ] 22.7.1.1 Every aboveground storage tank shall have emergency relief venting designed for use when the tank is exposed to a fire. The vent shall be in the form of construction in accordance with 22.7.2 or a device or devices that will relieve excessive internal pressure caused by an exposure fire. above the limits defined in 22.4.1.1(s), or 22.4.1.3, as applicable. 22.7.1.1.1 This requirement shall apply to each compartment of a compartmented tank, the interstitial space (annulus) of a secondary containment–type tank, and the enclosed space of tanks of closed-top dike construction. 22.7.1.1.2 This requirement shall also apply to spaces or enclosed volumes, such as those intended for insulation, membranes, or weather shields, that are capable of containing liquid because of a leak from the primary vessel. The insulation, membrane, or weather shield shall not interfere with emergency venting. 22.7.1.1.3 Tanks storing Class IIIB liquids that are larger than 12,000 gal (45,400 L) capacity and are not within the diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet the requirements of 22.7.1.1 . Additional Proposed Changes File Name 30_Grainawi.pdf Description Approved ✓ Statement of Problem and Substantiation for Public Comment Related to Items 11 and 12 There is confusion on what is intended in NFPA 30 regarding emergency venting. The purpose of this proposal is to clarify that: 1) Table 22.4.1.1(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 2.5 psi. 2) Section 21.4.2.1.4 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 2.5 psi. 3) Clarify that the same emergency venting requirements are required for all areas of the tank the primary tank, each compartment of the primary tank, any interstitial spaces, etc. as outlined in 22.7.1.1.1 and 22.7.1.1.2. 4) If the same emergency venting requirements are used for all areas, then it follows that the emergency venting of the secondary tank (interstitial space) must function at a maximum 2.5 psi. Applying the same emergency relief venting requirements, which is that the venting mechanism must operate at a maximum 2.5 psig, is the easiest and safest way to assure that atmospheric tanks do not create any additional hazards in a fire situation. The concerns are twofold. First, is the need to assure that any area of the tank not rupturing in an unintended manner (keeping in mind that tanks vented by form of construction will rupture at an intended point on the tank). Second, is the need to assure that the primary tank not buckle or collapse which could push product out of the tank into an ongoing fire. The decision to use 2.5 as the maximum venting pressure was chosen a long time ago. It is a tried and true method. Tanks that have ruptured in fire situations have done so because they did not meet the requirements of this code. Shop fabricated atmospheric tanks, because of their smaller size than field erected tanks, have a greater wetted surface area to volume ratio, which in itself creates a higher potential for emergency venting operation. Another consideration is the structural strength of the primary tank. If the interstitial space were to overpressurize, the primary tank at some pressure will collapse or buckle which could force product out of the tank, into the fire, further igniting the hazard. This again, is not a condition that has been encountered in double wall shop fabricated tanks. UL 142, since the introduction of double wall tanks, has required that venting of the secondary tank meet the same 1 of 2 6/3/2013 10:51 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... requirements as the primary tank. Table 8.1 in UL 142, Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks, uses Table 22.7.3.2, which suggests that NFPA should adopt the same policy. Further, I have deleted the reference to the UL 142 standard in 22.7.2 because the weak roof to shell joint as a form of emergency venting is no longer allowed in UL 142. UL 2085 does, however, have a performance test for venting by form of construction, so I am proposing to add the UL 2085 standard. I am also suggesting editorial corrections to the language for the purpose of making sections 22.4.1.1 and 22.7.1.1 easier to read. In section 22.4.1.1, I am proposing to change, “is not permitted to”, to, “shall not” because the first is generally considered to be permissive language. Also, an AHJ does not certify “such” anything, but rather certifies “the construction”. Submitter Information Verification Submitter Full Name: Lorri Grainawi Organization: Steel Tank Institute Submittal Date: Thu May 09 11:54:11 EDT 2013 Copyright Assignment I, Lorri Grainawi, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Lorri Grainawi, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature 2 of 2 6/3/2013 10:51 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... Public Comment No. 25-NFPA 30-2013 [ Section No. 22.7.1.1 ] 22.7.1.1 Every aboveground storage tank shall tank and every compartment or interstitial space of an aboveground tank shall have emergency relief venting in the form of construction or a device or devices that will relieve excessive internal pressure caused by an exposure fire. This requirement shall be verifiable by the ability to test any compartment or interstitial space for integrity and measure its volume for capacity. Each compartment of the primary tank, and any secondary containment or interstice, shall be vented at 2.5 psig. 22.7.1.1.1 This requirement shall apply to each compartment of a compartmented tank, the interstitial space (annulus) of a secondary containment–type tank, and the enclosed space of tanks of closed-top dike construction. 22.7.1.1.2 This requirement shall also apply to spaces or enclosed volumes, such as those intended for insulation, membranes, or weather shields, that are capable of containing liquid because of a leak from the primary vessel. The insulation, membrane, or weather shield shall not interfere with emergency venting. 22.7.1.1.3 Tanks storing Class IIIB liquids that are larger than 12,000 gal (45,400 L) capacity and are not within the diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet the requirements of 22.7.1.1 . Additional Proposed Changes File Name Description Approved ✓ 30_Greer_2.pdf Statement of Problem and Substantiation for Public Comment Emergency venting is singly the most important safety feature of an aboveground tank. Ensuring the fact that all compartments or interstices are testable, therefore not leaking into other spaces, is critical to the tank's integrity. Then insuring that each specific volume has been individually protected with emergency venting capability will ensure the safety of all personnel and property. Related Items from the Public Input Stage for This Document Related Item Public Input No. 12-NFPA 30-2012 [Chapter 1] Submitter Information Verification Submitter Full Name: Carl Greer 1 of 2 Organization: Service Welding & Machine Co. Submittal Date: Thu May 09 12:59:14 EDT 2013 6/3/2013 10:52 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... Public Comment No. 10-NFPA 30-2013 [ Section No. 22.7.1.1.1 ] 22.7.1.1.1 This requirement shall apply to each compartment of a compartmented tank, the interstitial space (annulus) of a secondary containment–type tank, and the enclosed space of tanks of closed-top dike construction and shall be limited to a gauge pressure of 2 .5 psi under emergency venting conditions in the primary tank as well as in the interstice of the secondary containment tanks.. Additional Proposed Changes File Name 30_22.7.1.1.1.docx Description Approved Cover Sheet ✓ Statement of Problem and Substantiation for Public Comment Not inserting this phrase will allow the interstice to reach pressures in excess of the primary of 2.5 psi. This could result in the failure of the tank top or shell resulting in injury or damage to any persons or property in the vicinity of the tank. Submitter Information Verification Submitter Full Name: ALEX RALSTON Organization: PETCON INC Submittal Date: Wed Apr 24 08:06:10 EDT 2013 Copyright Assignment I, ALEX RALSTON, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am ALEX RALSTON, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature 1 of 1 6/3/2013 10:53 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... Public Comment No. 23-NFPA 30-2013 [ Section No. 22.7.2 ] 22.7.2 Weak Roof-to-Shell Seam Construction Venting by Form of Construction . If used, a weak roof-to-shell seam shall be constructed to fail preferential to any other seam and shall be designed in accordance with API Standard 650, Welded Steel Tanks for Oil Storage. If used, the secondary containment of Protected Tanks labeled UL 2085, shall be constructed to fail preferentially above the liquid level, as evidenced by the UL required marking. Additional Proposed Changes File Name Description Approved ✓ 30_Grainawi.pdf Statement of Problem and Substantiation for Public Comment Related to Items 11 and 12 There is confusion on what is intended in NFPA 30 regarding emergency venting. The purpose of this proposal is to clarify that: 1) Table 22.4.1.1(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 2.5 psi. 2) Section 21.4.2.1.4 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 2.5 psi. 3) Clarify that the same emergency venting requirements are required for all areas of the tank the primary tank, each compartment of the primary tank, any interstitial spaces, etc. as outlined in 22.7.1.1.1 and 22.7.1.1.2. 4) If the same emergency venting requirements are used for all areas, then it follows that the emergency venting of the secondary tank (interstitial space) must function at a maximum 2.5 psi. Applying the same emergency relief venting requirements, which is that the venting mechanism must operate at a maximum 2.5 psig, is the easiest and safest way to assure that atmospheric tanks do not create any additional hazards in a fire situation. The concerns are twofold. First, is the need to assure that any area of the tank not rupturing in an unintended manner (keeping in mind that tanks vented by form of construction will rupture at an intended point on the tank). Second, is the need to assure that the primary tank not buckle or collapse which could push product out of the tank into an ongoing fire. The decision to use 2.5 as the maximum venting pressure was chosen a long time ago. It is a tried and true method. Tanks that have ruptured in fire situations have done so because they did not meet the requirements of this code. Shop fabricated atmospheric tanks, because of their smaller size than field erected tanks, have a greater wetted surface area to volume ratio, which in itself creates a higher potential for emergency venting operation. Another consideration is the structural strength of the primary tank. If the interstitial space were to overpressurize, the primary tank at some pressure will collapse or buckle which could force product out of the tank, into the fire, further igniting the hazard. This again, is not a condition that has been encountered in double wall shop fabricated tanks. UL 142, since the introduction of double wall tanks, has required that venting of the secondary tank meet the same requirements as the primary tank. Table 8.1 in UL 142, Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks, uses Table 22.7.3.2, which suggests that NFPA should adopt the same policy. Further, I have deleted the reference to the UL 142 standard in 22.7.2 because the weak roof to shell joint as a form of emergency venting is no longer allowed in UL 142. UL 2085 does, however, have a performance test for venting by form of construction, so I am proposing to add the UL 2085 standard. I am also suggesting editorial corrections to the language for the purpose of making sections 22.4.1.1 and 22.7.1.1 easier to read. In section 22.4.1.1, I am proposing to change, “is not permitted to”, to, “shall not” because the first is generally considered to be permissive language. Also, an AHJ does not certify “such” anything, but rather certifies “the construction”. Submitter Information Verification Submitter Full Name: Lorri Grainawi 1 of 2 Organization: Steel Tank Institute Submittal Date: Thu May 09 12:03:55 EDT 2013 6/3/2013 10:54 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... ATTACHMENT No. A6 Committee Input No. 13-NFPA 30-2012 [ Section No. 22.7.3.5 ] 22.7.3.5 Except as provided for in 22.7.3.6 and 22.7.3.7, for tanks containing stable liquids, the required emergency relief venting capacity determined by 22.7.3.2, 22.7.3.3 , or 22.7.3.4 shall be permitted to be multiplied by one of the following reduction factors when protection is provided as indicated. Only one of the following factors shall be used for any one tank: (1) 2 A reduction factor of 0.5 shall be allowed for tanks with wetted area greater than 200 ft (19 2 m ) that are provided with drainage that meets the requirements of 22.11.1. (2) A reduction factor of 0.3 shall be allowed for tanks that are protected with a water spray system that meets the requirements of NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection, and that are provided with drainage that meets the requirements of 22.11.1 . (3) A reduction factor of 0.3 shall be allowed for tanks that are protected with an automatically actuated water spray system that meets the requirements of NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection. (4) A reduction factor of 0.3 shall be allowed for tanks protected with insulation that meets the requirements of 22.7.3.8. (5) A reduction factor of 0.15 shall be allowed for tanks that are protected with a water spray system that meets the requirements of NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection, and that have insulation that meets the requirements of 22.7.3.8. Supplemental Information File Name Description Replacement_for_Emergency_Venting_Reduction_Factors.doc Replacement for Subsection 22.7.3.5. Submitter Information Verification Submitter Full Name: [ Not Specified ] Organization: [ Not Specified ] Submittal Date: Thu Sep 27 10:19:58 EDT 2012 Committee Statement and Meeting Notes Committee Statement: The Technical Committee on Tank Storage and Piping Systems is considering replacing the text of 22.7.3.5 with a table indicating the allowed reduction factors. (See Attachment.) The Technical Committee solicits input from the public during the Public Comment period. Response Message: Ballot Results This item has not been balloted 1 of 1 6/3/2013 10:40 PM Replacement for 22.7.3.5 Reduction Factors for Emergency Relief Venting 22.7.3.5 For tanks containing stable liquids, the required emergency relief venting capacity determined by 22.7.3.2, 22.7.3.3, or 22.7.3.4 shall be permitted to be multiplied by one of the reduction factors shown in Table 22.7.3.5 when protection is provided as indicated. Only one reduction factor shall be used for any one tank. Protection measures shall meet 22.7.3.5 (1) through (4), as appropriate. (1) Drainage shall meet the requirements of 22.11.1 and the reduction factor shall only be applicable to tanks with wetted area greater than 200 ft2 (19 m2). (2) A manually actuated water spray protection system shall meet the requirements of NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection and shall include drainage that meets the requirements of 22.11.1. (3) An automatically actuated water spray system shall meet the requirements of NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection. (4) Tank shell insulation shall meet the requirements of 22.7.3.8. 22.7.3.5.1* Water-miscible liquids whose heats of combustion and rates of burning are equal to or less than those of ethyl alcohol shall be allowed an additional 50 percent reduction in the required emergency relief venting capacity, as given in the appropriate column of Table 22.7.3.5. Drainage shall not be required to obtain this reduction. In no case shall the combined reduction factor be less than 0.15. There shall be no fire exposure from liquids other than from those liquids covered by this provision. 22.7.3.5.2* Liquids whose heats of combustion and rates of burning are equal to or less than those of ethyl alcohol (ethanol), but are not water-miscible shall be allowed an additional 50 percent reduction in the required emergency relief venting capacity, as given in the appropriate column of Table 22.7.3.5. No further reduction shall be allowed for protection by means of water spray. [Needs to be explained!] Drainage shall not be required to obtain this reduction. In no case shall the combined reduction factor be less than 0.15. There shall be no fire exposure from liquids other than from those liquids covered by this provision. Table 22.7.3.5 Emergency Relief Venting Reduction Factors Stable Liquids, Water-miscible Non-water-miscible water-miscible or Liquids that meet Liquids that meet non-water-miscible 22.7.3.5.1 22.7.3.5.2 Protection Measure(s) NONE 1.0 0.5 0.5 Drainage alone 0.5 0.25 0.25 Manual water spray 0.3 0.15 0.3 combined with drainage Automatically-actuated 0.3 0.15 0.3 water spray Insulation alone 0.3 0.15 0.3 Manual or automatically0.15 0.15 actuated water spray combined with insulation National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... ATTACHMENT No. A7 Committee Input No. 15-NFPA 30-2012 [ Section No. 22.11.4.1 ] 22.11.4.1 The capacity of the listed primary tank shall not exceed the capacities given in Table 22.11.4.1 . Table 22.11.4.1 Maximum Capacities for Secondary Containment–Type Aboveground Storage Tanks Capacity gal L I 12,000 45,400 II and IIIA 20,000 75,700 Liquid Classification Submitter Information Verification Submitter Full Name: [ Not Specified ] Organization: [ Not Specified ] Submittal Date: Thu Sep 27 11:40:27 EDT 2012 Committee Statement and Meeting Notes Committee Statement: The NFPA 30 Technical Committee on Tank Storage and Piping Systems is considering eliminating the limitation on capacity of the primary tank for listed secondary containment-type tanks, as set forth in Table 22.11.4.1, where the secondary containment is used to meet the spill control provisions of Section 22.11. The Technical Committee invites public comment on this issue. Response Message: Ballot Results This item has not been balloted 1 of 1 6/3/2013 10:41 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... Public Comment No. 9-NFPA 30-2013 [ Section No. 22.11.4.1 ] 22.11.4.1 The capacity of the listed primary tank shall not exceed the capacities given in Table 22.11.4.1 . Table 22.11.4.1 Maximum Capacities for Secondary Containment–Type Aboveground Storage Tanks Liquid Classification Capacity gal L I 12,000 45,400 II and IIIA 20,000 75,700 maximum capacity allowed by the listing for shop fabricated secondary containment tank construction. Additional Proposed Changes File Name 30_22.11.4.1.docx Description Approved Cover Sheet ✓ Statement of Problem and Substantiation for Public Comment I am recommending that NFPA follow the EPA SPCC Rules and the International Fire Code and not require diking with listed shop-fabricated aboveground tanks storing Class I liquids over 12, 000 gals and Class II & III liquids over 20,000 gals. The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacities. It doesn't make sense for a double-wall tank to also be inside a dike just because of its capacity. Submitter Information Verification Submitter Full Name: ALEX RALSTON Organization: PETCON INC Submittal Date: Tue Apr 23 08:24:07 EDT 2013 Copyright Assignment I, ALEX RALSTON, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am ALEX RALSTON, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature 1 of 1 6/3/2013 10:44 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... Public Comment No. 12-NFPA 30-2013 [ Section No. 22.11.4.1 ] 22.11.4.1 The capacity of the listed primary tank shall not exceed the capacities given in Table 22.11.4.1. Table 22.11.4.1 Maximum Capacities for Secondary Containment–Type Aboveground Storage Tanks Liquid Classification Capacity gal Capacity Gallons L Capacity Liters I 12 50 ,000 45 189 , 400 250 II and IIIA 20 50 ,000 75 189 , 700 250 Additional Proposed Changes File Name DOC043013-04302013120847.pdf Description Approved Cover Sheet ✓ Statement of Problem and Substantiation for Public Comment NFPA has recognized secondary containment tanks as a form of spill control since the 199X Edition. The requirements of 22.11.4.2 through 22.11.4.10 were promulgated to assure safe storage. Other fire codes (IFC) and environmental regulations (EPA SPCC) also recognize shop-fabricated secondary containment tanks as a form of spill control, particularly with the inclusion of safety controls during tank filling operations. The International Fire Code requires listed secondary containment tanks. Listed secondary containment tanks can be shop-fabricated in capacities as large as 50,000 gallons. Larger tanks will reduce the number of fill operations, thereby further reducing the risk of spills from overfills. Overfills are the most common cause of releases from shop-fabricated AST's. Submitter Information Verification Submitter Full Name: JASON GREER 1 of 2 Organization: GREER TANK & WELDING, INC. Submittal Date: Tue Apr 30 12:17:18 EDT 2013 6/3/2013 10:45 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... Public Comment No. 15-NFPA 30-2013 [ Section No. 22.11.4.1 ] 22.11.4.1 The capacity of the listed primary tank shall not exceed the capacities given in Table 22.11.4.1. Table 22.11.4.1 Maximum Capacities for Secondary Containment–Type Aboveground Storage Tanks Liquid Classification Capacity Gallons gal Capacity Liters L I 12 50 ,000 45 189 , 400 250 II and IIIA 20 50 ,000 75 189 , 700 250 Additional Proposed Changes File Name 30_Mott-Smith_MSCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Control.pdf Description Approved Cover Sheet ✓ Statement of Problem and Substantiation for Public Comment Many states that require secondary containment for shop-fabricated tanks have owners that are caught between the regulations of the State and NFPA with the current limitation on tank size. Data shows that double-wall tanks with overfill protection/shut-off devices have not been a problem. Larger tanks will reduce the number of fill operations and reduce the risk of overfills. The Florida Leak Autopsy Study demonstrated that overfills are the most common cause of releases from shop-fabricated AST’s. Submitter Information Verification Submitter Full Name: Marshall Mott-Smith 1 of 2 Organization: Mott-Smith Consulting Group Submittal Date: Thu May 02 07:55:14 EDT 2013 6/3/2013 10:45 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... Public Comment No. 24-NFPA 30-2013 [ Section No. 22.11.4.1 ] 22.11.4.1 The capacity of the listed primary tank shall not exceed the capacities given in Table 22.11.4.1 . Table 22.11.4.1 Maximum Capacities for Secondary Containment–Type Aboveground Storage Tanks Capacity gal Liquid Classification L I 12 50 ,000 45 189 , 400 250 II and IIIA 20 50 ,000 75 189 , 700 250 Additional Proposed Changes File Name Description Approved ✓ 30_Greer.pdf Statement of Problem and Substantiation for Public Comment NFPA has recognized secondary containment tanks as a form of spill control since the 199X Edition. The requirements of 22.11.4.2 through 22.11.4.10 were promulgated to assure safe storage. Other fire codes (IFC) and environmental regulations (EPA SPCC) also recognize shop-fabricated secondary containment tanks as a form of spill control, particularly with the inclusion of safety controls during tank filling operations. The International Fire Code requires listed secondary containment tanks. Listed secondary containment tanks can be shop-fabricated in capacities as large as 50,000 gallons. Larger tanks require measureably more heat input to heat the greater mass before problems will occur and therefore are not a detriment to safety. Related Items from the Public Input Stage for This Document Related Item Public Input No. 15-NFPA 30-2012 [New Section after 21.3.5] Submitter Information Verification Submitter Full Name: Carl Greer 1 of 2 Organization: Service Welding & Machine Co. Submittal Date: Thu May 09 12:44:44 EDT 2013 6/3/2013 10:46 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... Public Comment No. 26-NFPA 30-2013 [ Section No. 22.11.4.1 ] 22.11.4.1 The capacity of the listed primary tank shall not exceed the capacities given in Table 22.11.4.1 . Table 22.11.4.1 Maximum Capacities for Secondary Containment–Type Aboveground Storage Tanks Capacity gal Liquid Classification L I 12 50 ,000 45 189 , 400 250 II and IIIA III 20 50 ,000 75 189 , 700 250 Additional Proposed Changes File Name Description Approved ✓ 30_Roggelin.pdf Statement of Problem and Substantiation for Public Comment NFPA has recognized secondary containment tanks as a form of spill control since the 199X Edition. The requirements of 22.11.4.2 through 22.11.4.10 were promulgated to assure safe storage. Other fire codes (IFC) and environmental regulations (EPA SPCC) also recognize shop-fabricated secondary containment tanks as a form of spill control, particularly with the inclusion of safety controls during tank filling operations. The International Fire Code requires listed secondary containment tanks. Listed secondary containment tanks can be shop-fabricated in capacities as large as 50,000 gallons. Larger tanks will reduce the number of fill operations, thereby further reducing the risk of spills from overfills. Overfills are the most common cause of releases from shop-fabricated AST's. Submitter Information Verification Submitter Full Name: ERNEST M ROGGELIN 1 of 2 Organization: PINELLAS CHD Submittal Date: Thu May 09 13:26:14 EDT 2013 6/3/2013 10:46 PM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... ATTACHMENT No. A8 Committee Input No. 17-NFPA 30-2012 [ Section No. 27.4.4 ] 27.4.4 Low Melting Point Materials. Low melting point materials such as aluminum, copper, and brass; materials that soften on fire exposure such as plastics; or nonductile materials such as cast iron shall be permitted to be used underground within the pressure and temperature limitations of ASME B31, Code for Pressure Piping. 27.4.4.1 Such materials shall be permitted to be used outdoors above ground or inside buildings, provided they meet one of the following conditions: (1) They are resistant to damage by fire. (2) They are located so that any leakage resulting from failure will not expose persons, important buildings, or structures. (3) They are located where leakage can be controlled by operation of one or more accessible, remotely located valves. 27.4.4.2 The piping materials chosen shall be compatible with the liquids being handled. 27.4.4.3 Piping systems of these materials shall be designed and built in accordance with recognized standards of design for the particular materials chosen or with approved equivalent standards or shall be listed. Submitter Information Verification Submitter Full Name: [ Not Specified ] Organization: [ Not Specified ] Submittal Date: Thu Sep 27 11:53:20 EDT 2012 Committee Statement and Meeting Notes Committee In response to Recommendation 2006-3-I-FL-5, made by the U. S. Chemical Safety and Statement: Hazard Investigation Board, in its report on a storage tank explosion at the Bethune Point Wastewater Treatment Plant, the NFPA 30 Technical Committee on Tank Storage and Piping Systems is considering revising the provisions for use of low-melting point piping materials, as set forth in Subsection 27.4.4, to restrict or prohibit the use of thermoplastic piping in aboveground flammable liquids service. The Technical Committee invites public comment on this issue. Response Message: Ballot Results This item has not been balloted 1 of 1 6/3/2013 10:42 PM From: To: Subject: Date: Attachments: Stephen Haines Benedetti, Bob RE: NFPA 30 FLC-TAN Task Group Discussion Materials Friday, June 07, 2013 1:55:03 PM ext other Suggestion on Task Group 5 6-7-13 conference call (swh).pptx Bob, I bit the bullet and tries to word smith something for task Group 5 (Committee Input No. 17NFPA 30-2012 [ Section No. 27.4.4 ]). Please, take a look, word smith and circulate as you see fit. Thanks, Stephen W. Haines, PE (PA, NJ), CFEI President/Principal Consultant - II Haines Fire & Risk Consulting 1 Linda Lane, Suite B Southampton, NJ 08088 Phone: 609-388-4467 Fax: 609-388-4468 Cell: 609-661-2860 Skype: stephen.haines Website: http://www.hainesfire-risk.com Notice - Haines Fire & Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences of any actions taken on the basis of the opinions, recommendations or information provided unless they are confirmed in a written report prepared in accordance with its quality control procedures. If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited. See our website for info. on: TurboDraft Fire Eductor, WATERWAY FIRE HOSE TESTING From: Benedetti, Bob [mailto:[email protected]] Sent: Monday, June 03, 2013 11:10 PM To: Benedetti, Bob Cc: Matthews, Diane Subject: NFPA 30 FLC-TAN Task Group Discussion Materials To: NFPA 3O FLC-TAN Task Groups Attached are materials for the June 7, 2013 conference calls, arranged in Task Group order. Each consists of (in this order): - Original Committee Input (Potential Amendments / Research Items from NFPA 30 First Draft Meeting) - Public Comments received on the Committee Input, if any. - Relevant information, if any. - Proposed Second Draft Amendment, if any. Understand that you will have the discussion materials for all five Task Groups, so feel free to weigh in. the piping is not within the secondary containment area of a tank it is connected to and Low melting point materials may not be used within the secondary containment area of a tank it is connected to unless it is required by the properties of the material stored and: 1. It is not part of the tank’s normal or emergency venting. 2. It is connected above the normal operating liquid level of the tank. 3. It is connected below the normal operating liquid level of the tank and any of the following conditions are met: 1. The stored liquid is a Class IIIB liquid, the tank is located outdoors and the piping is not exposed to a potential spill or leak of Class I, Class II or Class IIIA liquid. 2. The material is protected from fire exposure, such as by materials having a fire resistance of not less than 2 hours. SWH – Eliminate potential pipe closure issue under fire conditions as brought up during call SWH – No significant impact on the fire situation SWH – consistent with 27.4.3.3 for valves SWH – consistent with 27.4.3.2 for valves SWH – I debated an alternative to allow these materials if a fire actuated, self closing valve was provided on the tank nozzle. However, this would be inconsistent with our requirements for valve materials in 27.4.3.3 From: To: Subject: Date: Attachments: Sully Curran Benedetti, Bob Re: NFPA 30 FLC-TAN Task Groups Conference Call Friday, June 07, 2013 4:32:59 PM NFPA 30 comment on FRP pipe 6-7-13.doc Bob: Sorry I missed the earlier conf call....My vote is in favor of prohibiting the use of "thermoplastic" piping in aboveground flammable liquid service.... but not reinforced fiberglass piping. Attached is a paper I developed describing the use of FRP pipe in marine vessels and off-shore platforms where there is a need to reduce weight. Sully Curran -----Original Message----From: Benedetti, Bob <[email protected]> To: Benedetti, Bob <[email protected]> Cc: Matthews, Diane <[email protected]> Sent: Mon, Jun 3, 2013 10:20 pm Subject: NFPA 30 FLC-TAN Task Groups Conference Call TO: NFPA 30 FLC-TAN Task Groups We will hold a conference call on Friday, June 7, 2013, beginning at 10:00 AM Eastern Time to discuss the five issues identified per previous emails. See the attached Excel file, which lists the five Task Groups and shows on which Task Group(s) you serve. Topics will be addressed in the following order: 3, 4, 5, 1, and 2; this is based on my estimate of duration of discussion. It is understood that not all will be able to participate in the call, so I ask you to review the material that will be sent by a separate email and provide me with whatever comments you deem advisable. If you have any questions, please call me at 617-984-7433 or respond to this email. Unprotected FRP pipe made with epoxy resin systems will be consumed when exposed to fire, but is self extinguishing when the flame is removed. Under continuous fire exposure and with water flowing through the pipe, it tends to degrade to a given level and then maintains that performance level. The movement of fluid inside the pipe remains cool (i. e., FRP is a low conductor of heat) and gives an extinguishing effect to the structural wall of the pipe. As a result, the FRP Fuel Contribution Index is zero. and there are marine and off‐shore petroleum platforms where unprotected FRP pipe is used for fire main systems. Intumescent coated piping has gained acceptance in the marine industry because it combines the corrosion resistance historically solved with stainless steel and copper‐nickel materials with the light weight important in marine construction. Material Flame Spread, Fuel Contribution and Smoke Generation requirements are established in the fire and building codes. To meet these codes, burning tests are conducted in accordance with ASTM E84‐81a, “Standard Method of Test for Surface Burning Characteristics of Building Materials” or other similar test methods specified in ANSI No. 2.5, NFPA 255, UL 723 and UBC 42‐1. Flame test results are expressed in terms of Indices for Flame Spread, Fuel Contribution and Smoke Developed during 10 minute exposure to flames. Consistent with Webester’s definition for intumescent, the coating when exposed to fire will blister and form a heat shield to reduce the rate at which fire will affect the pipe. The following table shows that coating the same epoxy resin pipe will reduce the Flame Spread and Smoke Developed Indexes significantly. Test Specimen FRP Pipe Coated FRP Pipe Indices Flame Spread Fuel Contribution Smoke Developed 40 0 755 5 0 30 35 0 725 Index Improvement Further, in a fire scenario, once intumescing occurs it must remain on the pipe when impacted by water hose streams used to fight the fire. New piping incorporates the intumescent coating into the filament winding process. This filament winding process provides an intumescent coating that is of consistent thickness, void free, smoother texture and cannot be removed inadvertently. The FRP pipe is capable of maintaining the serviceability of the piping in a fire for a minimum of three hours conditions. Currently intumescent piping is available in diameters up to 40 inches, with an operating pressure rating of 150 psi at 200F. Sully Curran, June 7, 2013 From: To: Cc: Subject: Date: Sully Curran Benedetti, Bob; [email protected]; [email protected]; [email protected]; [email protected] [email protected] Re: NFPA 30 FLC-TAN Task Group Discussion Materials Monday, June 10, 2013 2:24:21 PM Dear All: 1. Suggest revising 27.4.4 as follows: "Low melting point materials such as aluminum, copper, and brass: materials that soften on fire exposure such as (delete plastics) thermoplastics; etc. The US Chemical Safety and Hazard Investigation slide #15 identified that it was a thermoplastic pipe that failed, not a fiberglass thermosetplastic pipe. The resin in unprotected thermosetplastic pipe (fiberglass) will be consumed when exposed to fire, but is self extinguishing when the flame is removed. Thus, fiberglass pipe is used on marine & Navy vessels and off-shore petroleum platforms in salt water fire deluge protection systems that would be exposed to fire. It is also used on marine vessels in fuel piping systems to improve buoyancy by removing weight. 1. Agree with insertion of "the piping is not within the secondary containment area of a tank it is connected to and" in 27.4.4.1 2. Do not agree with deletion of 27.4.4.1 (1) "They are resistant to damage by fire." Instead would change (1) as follows: They are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a or other similar test; methods specified in ANSI No. 2.5, NFPA 255, UL 723 and UBC 42-1 that call for a flame spread rate of less than 200. 3. Also do not agree with deleting existing language #(2) & (3) 4. Do not agree with addition of new language #1, #2, & #3, all of which is redundant...thus confusing. Regards, Sully Curran Fiberglass Tank & Pipe Institute -----Original Message----From: Benedetti, Bob <[email protected]> To: Curran, Sully <[email protected]>; Geyer, Wayne <[email protected]>; Haines, Steve <[email protected]>; Kraus, Dick <[email protected]>; Renkes, Bob <[email protected]> Sent: Mon, Jun 10, 2013 11:12 am Subject: FW: NFPA 30 FLC-TAN Task Group Discussion Materials TO: NFPA 30 FLCTAN Task Group 5 Please review and provide me with your comments. From: Stephen Haines [mailto:[email protected]] Sent: Friday, June 07, 2013 1:55 PM To: Benedetti, Bob Subject: RE: NFPA 30 FLC-TAN Task Group Discussion Materials Bob, I bit the bullet and tries to word smith something for task Group 5 (Committee Input No. 17NFPA 30-2012 [ Section No. 27.4.4 ]). Please, take a look, word smith and circulate as you see fit. Thanks, Stephen W. Haines, PE (PA, NJ), CFEI From: To: Cc: Subject: Date: Wayne Geyer Sully Curran; Benedetti, Bob; [email protected]; [email protected]; [email protected] [email protected] RE: NFPA 30 FLC-TAN Task Group Discussion Materials Tuesday, June 11, 2013 1:30:04 AM As an fyi, the following is what appears in the International Fire Code: 5703.6.2 Design, fabrication and installation of piping systems and components. Piping system components shall be designed and fabricated in accordance with the applicable standard listed in Table 5703.6.2 and Chapter 27 of NFPA 30, except as modified by Section 5703.6.2.1. TABLE 5703.6.2 PIPING STANDARDS PIPING USE Power Piping Process Piping Pipeline Transportation Systems for Liquid Hydrocarbons and Other Liquids Building Services Piping STANDARD ASME B31.1 ASME B31.3 ASME B31.4 ASME B31.9 5703.6.2.1 Special materials. Low-melting-point materials (such as aluminum, copper or brass), materials that soften on fire exposure (such as nonmetallic materials) and nonductile material (such as cast iron) shall be acceptable for use underground in accordance with the applicable standard listed in Table 5703.6.2. When such materials are used outdoors in above-ground piping systems or within buildings, they shall be in accordance with the applicable standard listed in Table 5703.6.2 and one of the following: 1. Suitably protected against fire exposure. 2. Located where leakage from failure would not unduly expose people or structures. 3. Located where leakage can be readily controlled by operation of accessible remotely located valves. In all cases, nonmetallic piping shall be used in accordance with Section 27.4.6 of NFPA 30. Wayne Geyer From: Sully Curran [mailto:[email protected]] Sent: Monday, June 10, 2013 1:24 PM To: [email protected]; Wayne Geyer; [email protected]; [email protected]; [email protected] From: To: Cc: Subject: Date: Wayne Geyer Benedetti, Bob; Robert Renkes Curran, Sully; Haines, Steve; Kraus, Dick RE: NFPA 30 FLC-TAN Task Group Discussion Materials Tuesday, June 11, 2013 12:57:45 AM There are so many different types of aboveground storage tank installations. With this section, I’m sure most people are thinking of large terminal facilities, with the piping installed aboveground. But the CSB study was made upon a shop-fabricated AST storing methanol. The most popular types of shop-fabricated AST installations being made today are for bulk plants, for fleet fueling, and for fuel storage for emergency power. Aboveground shop-fab steel tanks used for motor vehicle fueling had to emulate a buried tank by code, and were tested for two hours at 2000 degrees. I think it used UL 1709 as its basis, and then became UL 2085. Wouldn’t it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallic pipe that is not fire resistant. A lot of these tanks are installed closer to buildings and property lines due to their construction. That being said, I have not seen non-metallic tank being used aboveground for these applications, but the Code does allow it. Wayne Geyer From: Benedetti, Bob [mailto:[email protected]] Sent: Monday, June 10, 2013 10:29 AM To: Robert Renkes Cc: Curran, Sully; Wayne Geyer; Haines, Steve; Kraus, Dick Subject: RE: NFPA 30 FLC-TAN Task Group Discussion Materials I know. That’s always bothered me. We should have some kind of definitive description or reference to a test. From: Robert Renkes [mailto:[email protected]] Sent: Monday, June 10, 2013 11:24 AM To: Benedetti, Bob Subject: RE: NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by “resistant” to damage by fire? We don’t define resistant. Bob Bob Renkes Executive Vice President/General Counsel PEI P. O. Box 2380, Tulsa, OK 74101 918-494-9696 Follow me on Twitter! From: Benedetti, Bob [mailto:[email protected]] National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/C... ATTACHMENT No. A9 Public Comment No. 2-NFPA 30-2013 [ Section No. 21.4.1.1 ] 21.4.1.1 The materials of construction for tanks and their appurtenances shall be compatible with the liquid to be stored. In case of doubt about the properties of the liquid to be stored, the supplier, producer of the liquid, or other competent authority shall be consulted. Piping materials of construction shall be in accordance with the requirements of Chapter 27, Section 27.4 of this code, Materials of Construction for Piping Systems. Statement of Problem and Substantiation for Public Comment This instructs the user where to find information regarding materials of construction approved by this code. Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Affilliation: API Submittal Date: Fri Mar 01 08:52:28 EST 2013 Copyright Assignment I, Richard Kraus, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Richard Kraus, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature 1 of 1 6/11/2013 11:49 AM
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