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57
FLCTAN.2013-06 Agenda.doc 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

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FLCTAN2013-06 Agendadoc

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 mdash 800 AM to 500 PM June 19 2013 mdash 800 AM to 1200 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 800 AM to 500 PM Tuesday June 18 2013 and 800 AM to Noon Wednesday June 19 2013 at the Doubletree Hotel ndash San Antonio Downtown San Antonio TX This Agenda will also be posted to the NFPA 30 Document Information Page at httpwwwnfpaorgaboutthecodeslist_of_codes_and_standardsasp If you have additional items for the Agenda please bring them with you to the meeting rpb cc FLCC Meeting Folder FLCTANNM

FLCTAN2013-06 Agendadoc

FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE COMMITTEE

AGENDA mdash NFPA 30 Second Draft Meeting

NFPA 30 Technical Committee on Tank Storage and Piping Systems

Doubletree Hotel ndash San Antonio Downtown San Antonio TX

Tuesday June 18 2013 800 AM to 500 PM Wednesday June 19 2013 800 AM to 1200 PM

1 Call to Order 2 Introduction of Attendees Update of Committee Roster [Attachment A1] 3 Approval of Minutes of Last Meeting [August 2012 NFPA Headquarters Quincy MA]

[Attachment A2] 4 Report of Committee Chair 5 Report of Staff Liaison

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 ndash Security for Unsupervised Tanks ndash Recommendation from CSB [Attachment A4] 8 Address Committee Inputs s 11 and 12 ndash Pressure Limitations [Attachment A5] [NOTE It is the Task Grouprsquos 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 ndash Table for Emergency Vent Reduction Factors [Attachment A6] [NOTE It is the Task Grouprsquos recommendation to leave the current text as is] 10 Address Committee Input 15 ndash Capacity Limitations for Secondary Containment-type Tanks [Attachment A7] [NOTE It is the Task Grouprsquos 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

FLCTAN2013-06 Agendadoc

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 ndash Low-melting Point Piping Materials ndash Recommendation from CSB [Attachment A8] 12 Address Committee Input 2 ndash Materials of Construction for Tanks [Attachment A9] 13 Recent Correspondence [NONE] 14 Old Business [NONE] 15 New Business

Federal Regulatory Agency Task Group [Work w CSB OSHA etc to Develop Recommendations in NFPA Format)

Tank Spacing Task Group [Review Section 224 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 ndash Identify Work Areas

16 Schedule Next Meeting(s) 17 Adjournment

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Stephen W Haines

ChairHaines Fire amp Risk Consulting Corp1 Linda Lane Suite BSouthampton NJ 08088Alternate Anthony M Ordile

SE 08092012FLC-TAN

Steven P Allwein

PrincipalMorrison Brothers Company570 East Seventh StreetDubuque IA 52001

M 7162003

FLC-TAN

John H Bagnall

PrincipalBurns amp McDonnell Engineering CompanyPO Box 419173Kansas City MO 64141

SE 1152004FLC-TAN

Gregory P Bareta

PrincipalWisconsin Department of Commerce141 NW Barstow StreetWaukesha WI 53188-3789

E 342008

FLC-TAN

Tim D Blackford

PrincipalChevron Energy Technology Company3901 Briarpark DriveHouston TX 77042American Petroleum InstituteAlternate Richard S Kraus

U 312011FLC-TAN

John V Cignatta

PrincipalDatanet Engineering Inc11416 Reisterstown RoadOwings Mills MD 21117

SE 822010

FLC-TAN

Sullivan D Curran

PrincipalFiberglass Tank amp Pipe Institute11150 South Wilcrest Drive Suite 101Houston TX 77099-4343Alternate Patrick A McLaughlin

M 111994FLC-TAN

Charles A Davis

PrincipalURS Corporation7650 West Courtney Campbell CausewayTampa FL 33607-1462

SE 1011996

FLC-TAN

Claire V De Taeye

PrincipalTravelers Insurance Company75 Town Centre DriveRochester NY 14623

I 312011FLC-TAN

Michael Doxey

PrincipalHMT Inc24 Waterway Avenue Suite 400The Woodlands TX 77380

M 08092012

FLC-TAN

Wayne B Geyer

PrincipalSteel Tank Institute (STISPFA)944 Donata CourtLake Zurich IL 60047Alternate Jeffrey M Shapiro

M 111986FLC-TAN

Edward S Goldhammer

PrincipalAon Fire Protection11770 Bernardo PlazaSan Diego CA 92128Alternate Thomas S Lentz

I 852009

FLC-TAN

Dwight H Havens

PrincipalBechtel Marine Propulsion CorporationKnolls Atomic Power Laboratory20 Bellflower RoadMalta NY 12020-4431

U 7241997FLC-TAN

David C Kirby

PrincipalBaker Engineering amp Risk Consultants Inc1560 Clearview HeightsCharleston WV 25312Alternate Duane L Rehmeyer

SE 111991

1

bbenedetti
Text Box
ATTACHMENT No A1

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Gregory D Kirby

PrincipalCYTEC Industries Inc1 Heilman AvenueWillow Island WV 26134

U 1171997FLC-TAN

David P Nugent

PrincipalValspar Corporation8725 West Higgins Road Suite 1000Chicago IL 60631

U 3212006

FLC-TAN

Marcia Jo Poxson

PrincipalMichigan Department of Environmental QualityPO Box 30426Lansing MI 48909-7926Alternate R Jeff Tanner

E 10292012FLC-TAN

Niall Ramsden

PrincipalResource Protection InternationalWalker HouseGeorge StreetAylesbury Bucks HP20 2HU United Kingdom

SE 10292012

FLC-TAN

Robert N Renkes

PrincipalPetroleum Equipment Institute6514 East 69th StreetTulsa OK 74133

M 111984FLC-TAN

John W Richmond Sr

PrincipalEastman Chemical CompanyPO Box 511 (B-18)Kingsport TN 37663

U 4142005

FLC-TAN

Roland A Riegel

PrincipalUL LLC1285 Walt Whitman RoadMelville NY 11747-3085Alternate Alfredo M Ramirez

RT 4152004FLC-TAN

James R Rocco

PrincipalSage Risk Solutions LLC360 Heritage RoadAurora OH 44202Petroleum Marketers Association of AmericaAlternate Charles R Plummer

U 3212006

FLC-TAN

Tim G Schroeder

PrincipalHusky Corporation2325 Husky WayPacific MO 63069

M 10182011FLC-TAN

Clark D Shepard

PrincipalExxonMobil CorporationResearch amp Engineering3225 Gallows Road Room 3A2111Fairfax VA 22037Alternate David W Owen

U 1122000

FLC-TAN

Beth Tate

PrincipalOffice of the Fire MarshalCommunity Safety amp Correctional Services5775 Yonge Street 7th FloorToronto ON M2M 4J1 Canada

E 7292005FLC-TAN

David B Wechsler

Principal27706 Dalton Bluff CourtKaty TX 77494American Chemistry Council

U 10272009

FLC-TAN

Peter J Willse

PrincipalXL Global Asset Protection Services100 Constitution Plaza 12th FloorHartford CT 06103Alternate Luis F Arango

I 3212006FLC-TAN

Jack Woycheese

PrincipalHughes Associates Inc2195 Overlook DriveWalnut Creek CA 94597Alternate Joseph L Scheffey

SE 111996

2

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Luis F Arango

AlternateXL Global Asset Protection Services21707 Shallow Glen LaneKaty TX 77450Principal Peter J Willse

I 7162003FLC-TAN

Richard S Kraus

AlternateAPIPetroleum Safety Consultants210 East Fairfax Street Apt 600Falls Church VA 22046-2909American Petroleum InstitutePrincipal Tim D Blackford

U 452001

FLC-TAN

Thomas S Lentz

AlternateAon Risk Services Inc200 East Randolph StreetChicago IL 60014Principal Edward S Goldhammer

I 322010FLC-TAN

Patrick A McLaughlin

AlternateMcLaughlin amp Associates2070 South Fox Glen WayEagle ID 83616Fiberglass Tank amp Pipe InstitutePrincipal Sullivan D Curran

M 411994

FLC-TAN

Anthony M Ordile

AlternateHaines Fire amp Risk Consulting Corporation1 Linda Lane Suite BSouthampton NJ 08088Principal Stephen W Haines

SE 1011993FLC-TAN

David W Owen

AlternateExxonMobil CorporationResearch and Engineering2800 Decker Drive MOB 541Baytown TX 77520Principal Clark D Shepard

U 7122001

FLC-TAN

Charles R Plummer

AlternatePPM Consultants Inc1600 Lamy LaneMonroe LA 71201-3736Petroleum Marketers Association of AmericaPrincipal James R Rocco

U 4142005FLC-TAN

Alfredo M Ramirez

AlternateUL LLC333 Pfingsten RoadNorthbrook IL 60062-2096Principal Roland A Riegel

RT 4152004

FLC-TAN

Duane L Rehmeyer

AlternateBaker Engineering amp Risk Consultants Inc709 Highspire RoadGlenmore PA 19343Principal David C Kirby

SE 822010FLC-TAN

Joseph L Scheffey

AlternateHughes Associates Inc3610 Commerce Drive Suite 817Baltimore MD 21227-1652Principal Jack Woycheese

SE 03072013

FLC-TAN

Jeffrey M Shapiro

AlternateInternational Code Consultants8207 Asmara DriveAustin TX 78750Steel Tank InstituteSteel Plate Fabricators AssociationPrincipal Wayne B Geyer

M 10101997FLC-TAN

R Jeff Tanner

AlternateMichigan Department of Environmental QualityPO Box 30426Lansing MI 48909-7926Principal Marcia Jo Poxson

10292012

3

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Jeffrey J Wanko

Nonvoting MemberUS Department of LaborOccupational Safety amp Health Administration200 Constitution Ave NW Room N3119Washington DC 20210

E 03052012FLC-TAN

David L Blomquist

Member EmeritusBlomquist Fire Protection Engineering114 Golden Ridge RoadAlamo CA 94507-2869

1011993

FLC-TAN

Donald M Johnson

Member Emeritus3333 Rossmoor Parkway 1Walnut Creek CA 94595

111964FLC-TAN

Orville M Slye Jr

Member EmeritusLoss Control Associates Inc79 Sweetgum RoadLevittown PA 19056

111988

FLC-TAN

Brooke B Smith Jr

Member Emeritus114 Parkview DriveWoodland Park CO 80863

SE 111982FLC-TAN

Robert P Benedetti

Staff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy MA 02169-7471

4

FLCTAN2012-08 Minutesdoc

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 amp 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 amp Risk Consulting Corp CHAIR D H Havens Bechtel Marine Propulsion Corporation Knowles Atomic Power Laboratory D C Kirby Baker Engineering amp Risk Consultants Inc G D Kirby CYTEC Industries Inc D W Owen ExxonMobil Corporation

D L Rehmeyer Baker Engineering amp 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 amp 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

bbenedetti
Text Box
ATTACHMENT No A2

FLCTAN2012-08 Minutesdoc

P A McLaughlin McLaughlin amp Associates (Rep Fiberglass Tank amp Pipe Institute) D P Nugent Valspar Corporation A M Ordile Haines Fire amp 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 ndash 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 115 PM on Thursday August 30 2012 by Technical Committee

Chair Steve Haines 2 Attendees introduced themselves The Technical Committee roster was corrected as needed 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

Technical Committee Scope Statement The Technical Committee agreed to the need for a revised scope that accurately reflects the Technical Committeersquos 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 ldquoRecent Correspondencerdquo the Technical Committee discussed the following items

Recommendation from U S Chemical Safety and Hazard Investigation Board to mandate fully-automated 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

9 Under ldquoOld Businessrdquo 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

FLCTAN2012-08 Minutesdoc

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 2242 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 ndash Extra Hazard Group 2 The Technical Committee determined that this should be studied during the next document revision cycle

10 Under ldquoNew Businessrdquo 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 21715 Revise to require only one of the three options Section 224 Add statement that a multi-compartment tank is treated the same as a single

compartment tank for purposes of siting In 22734 should ldquoMrdquo 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 25131 conflicts with 278267 for Class II and Class III liquids Section 274 does it apply to all valves regardless of whether they connect to the top of the

tank or below the liquid level Paragraph 27441(1) What is the criteria for ldquoresistant to firerdquo Equivalent to steel Should not the provisions of 27823 through 2782121 apply to aboveground tanks as well as

underground tanks Subsection 2841 Clarify to indicate these are fixed unloading stations What is appropriate

distance for ldquodirect transfer from tank vehicle to storage tankrdquo 11 The NFPA 30 Second Draft meeting was tentatively scheduled for Thursday May 23 2013 in San

Antonio TX 12 The meeting adjourned at 545 PM

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

wwwnfpaorgdocument (ie wwwnfpaorg101) and click on the Next Edition tab

Process Stage

Process Step

Dates for TC

Dates forTC with

CC Public Input Closing Date 6222012 6222012

Final Date for TC First Draft Meeting 11302012 8312012

Public Input Posting of First Draft and TC Ballot 1182013 10122012

Stage Final date for Receipt of TC First Draft ballot 282013 1122012

(First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 2152013 1192012

Posting of First Draft for CC Meeting 11162012

Final date for CC First Draft Meeting 12282012

Posting of First Draft and CC Ballot 1182013

Final date for Receipt of CC First Draft ballot 282013

Final date for Receipt of CC First Draft ballot ‐ recirc 2152013

Post Final First Draft for Public Comment 2222013 2222013

Public Comment closing date 532013 532013

Final Date to Publish Notice of Consent Documents (Documents that received no Comments)

5102013 5102013

Appeal Closing Date for Consent Documents (Documents that received no Comments)

5242013 5242013

Final date for TC Second Draft Meeting 10182013 7122013

Comment Posting of Second Draft and TC Ballot 11292013 8232013

Stage Final date for Receipt of TC Second Draft ballot 12202013 9132013

(Second Final date for receipt of TC Second Draft ballot ‐ recirc 12272013 9202013

Draft) Posting of Second Draft for CC Meeting 9272013

Final date for CC Second Draft Meeting 1182013

Posting of Second Draft for CC Ballot 11292013

Final date for Receipt of CC Second Draft ballot 12202013

Final date for Receipt of CC Second Draft ballot ‐ recirc 12272013

Post Final Second Draft for NITMAM Review 132014 132014

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 272014 272014

Preparation Posting of Certified Amending Motions (CAMs) and Consent Documents

442014 442014

(amp Issuance) Appeal Closing Date for Consent Documents 4182014 4182014

SC Issuance Date for Consent Documents 592014 592014

Tech Session Association Meeting for Documents with CAMs 69‐122014 69‐122014

Appeals and Appeal Closing Date for Documents with CAMs 6242014 6242014

Issuance Council Issuance Date for Documents with CAMs 8142014 8142014

bbenedetti
Text Box
ATTACHMENT No A3

Committee Input No 16-NFPA 30-2012 [ Section No 21722 ]

21722 Security for Unsupervised Storage Tanks

Unsupervised isolated aboveground storage tanks shall be secured and shall be marked toidentify the fire hazards of the tank and the tankrsquos contents to the general public Where necessaryto protect the tank from tampering or trespassing the area where the tank is located shall besecured

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114315 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2011-H-1-6 made by the U S Chemical Safety andHazard Investigation Board the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for unsecured isolated storage tanks and issoliciting input for possible Technical Committee action at the second draft meeting

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 6112013 1011 AM

bbenedetti
Text Box
ATTACHMENT No A4

From D Havens 5‐17‐2013

Action by sub ndash retain current 21722 and add new appendix

Current Language 21722 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 tankrsquos 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 21722 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 tankrsquos 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 21722 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 tanks 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 A21722

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 Hiscott Jr David JTo Krumpolc Judith A Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Kraus Dick Paplawski

Robert Renkes Bob Wechsler DaveSubject RE NFPA 30 Group 1 sub team appendixDate Tuesday June 11 2013 91211 AM

My concern is that we are listing specific measures in the annex I realize that the annex is non ndashmandatory but sometimes these things creep into the code in later revisions We are also proposingto use several key ldquoundefinedrdquo words such as ldquo unsupervisedrdquo and ldquoremoterdquo and these terms willhave different meanings to different AHJrsquos and operators If we do not define these terms then thestandard dictionary definition applies and that will not provide guidance Each tank may pose adifferent hazard and to provide flexibility we should consider defaulting to allowing operators toconduct an assessment My proposal The committee is in general agreement with findings in the September 2011 CSB final reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents Additional securitymeasures should be developed based on fire and security risk assessments conducted by theoperator and petroleum industry practices Additional security measures could includeproviding a latched gate at the stairs leading to the tank platform and recommendations fromthe CSB report David Hiscott CSP CPPPhillips 66 TransportationEmergency Preparedness Response and Security3010 Briarpark Dr PWC - 7330-29Houston TX 77042Office - 832-765-1689Cell - 817-715-8951 NOTE New Contact information From Krumpolc Judith A [mailtoJudithKrumpolcbpcom] Sent Monday June 10 2013 405 PMTo Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Hiscott Jr David J Kraus DickPaplawski Robert Renkes Bob Wechsler DaveSubject [EXTERNAL]RE NFPA 30 Group 1 sub team appendix Bob and Task Group Members My concern with the Wechsler proposal A21722 is for the tanks that are remotelylocated isolated but not threatened by the public as much as in southern states such as inremote places in Alaska It is important to note that the biggest companies in the oil and gasindustry are working together with API to develop an annex for API RP 12R1 to include arequirement for a latched gate at the stairs leading to the platform for such remote tanks torespond to the same CSB report cited in the annex referenced by NFPA Should NFPAshould do similarly to avoid confusion I suggest we include a statement allowing the tankowner to make the decision when to add protective measures and give examples of additionalprotective measures The signage should be mandatory but the additional protection should

be added ldquowhen necessaryrdquo as determined by the operator when public access is a relevantthreat 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 reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents When public access isa relevant threat obvious protective measures should be implemented to help prevent thepublic from tampering with the unsupervised remotely located tanks by providing a latchedgate at the stairs leading to the platform In highly susceptible areas unsupervised remotelylocated tanks require additional protective measures which includes any or all the followingsecuring the hatches on the tanks restricting access to the entire facility or utilizinginherently safer tank design at these facilities I welcome any feedback

Judy KrumpolcTechnical Authority- Fire and Explosion AnalysisSafety + Operational Risk Deployed RampM150 W Warrenville Rd Naperville IL 60563Office 630 536-2804 Mobile 630 815-2098 Fax 630 420-4501Confidentiality Notice This electronic transmission and any documents sent with it constitute confidential inside or non-public information Ifyou are not the intended recipient or have received this communication in error please resend this communication to the sender and delete it fromyour computer system Any use or disclosure of the contents of this communication by anyone other than an intended recipient is strictlyprohibited and may be unlawful Thank you

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1008 AMTo Geyer Wayne Haines Steve Havens Dwight Hiscott Dave Kraus Dick Krumpolc Judith APaplawski Robert Renkes Bob Wechsler DaveSubject 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 [mailtodbwechslerattnet] Sent Monday June 10 2013 1027 AMTo Benedetti BobSubject Re NFPA 30 Group 1 sub team appendix BobI pulled up a copy of the final CSB Jan 2011 report on the tank incidents While there is a lotin this report I attempted rather than to repeat the information simply summarize it withinthe context of our existing statement Hopefully this accomplishes the sub team objective andstill 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 thesub team for additional comment and review Thanks

Committee Input No 11-NFPA 30-2012 [ Section No 224 ]

224 Location of Aboveground Storage Tanks

2241 Location with Respect to Property Lines Public Ways and Important Buildings

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1 of 8 632013 1037 PM

bbenedetti
Text Box
ATTACHMENT No A5

22411

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

2 of 8 632013 1037 PM

Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is not permitted to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22411(a) and Table22411(b) Where tank spacing is based on a weak roof-to-shell seam design the user shall presentevidence certifying such construction to the authority having jurisdiction upon request

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Not toExceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Waya

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Propertya

Floating roofProtection for

exposuresb12 times diameter of tank 16 times diameter of tank

NoneDiameter of tank but neednot exceed 175 ft

16 times diameter of tank

Vertical with weak roof-to-shellseam

Approved foam or

inerting systemc ontanks not exceeding

150 ft in diameterd

12 times diameter of tank 16 times diameter of tank

Protection for

exposuresb Diameter of tank 13 times diameter of tank

None2 times diameter of tank butneed not exceed 350 ft

13 times diameter of tank

Horizontal and vertical tankswith emergency relief ventingto limit pressures to 25 psi(gauge pressure of 17 kPa)

Approved inerting

systemb on the tank orapproved foam systemon vertical tanks

12 times value in Table22411(b)

12 times value in Table22411(b)

Protection for

exposuresb Value in Table 22411(b) Value in Table 22411(b)

None2 times value in Table22411(b)

Value in Table 22411(b)

Protected aboveground tank None12 times value in Table22411(b)

12 times value in Table22411(b)

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft (15 m)

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

dFor tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

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Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

For SI units 1 ft = 03 m 1 gal = 38 L

22412

Vertical tanks with weak roof-to-shell seams (see 2272) that store Class IIIA liquids shall be permitted to belocated at one-half the distances specified in Table 22411(a) provided the tanks are not within the samediked area as or within the drainage path of a tank storing a Class I or Class II liquid

22413

Tanks storing Class I Class II or Class IIIA stable liquids and operating at pressures that exceed a gaugepressure of 25 psi (17 kPa) or are equipped with emergency venting that will permit pressures to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22413 and Table 22411(b)

Table 22413 Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Permittedto Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or Can BeBuilt Upon Including the Opposite

Side of a Public Way

From Nearest Side of Any Public Wayor from Nearest Important Building on

the Same Property

Any typeProtection for

exposures1 12 times value in Table 22411(b) but notless than 25 ft

1 12 times value in Table 22411(b) but notless than 25 ft

None3 times value in Table 22411(b) but not beless than 50 ft

1 12 times value in Table 22411(b) but notless than 25 ft

For SI units 1 ft = 03 m

See definition 3346 Protection for Exposures

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22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

ResponseMessage

Ballot Results

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8 of 8 632013 1037 PM

Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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1 of 5 632013 1039 PM

Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

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Ballot Results

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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2 of 5 632013 1049 PM

Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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3 of 5 632013 1049 PM

Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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1 of 1 632013 1042 PM

bbenedetti
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ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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ATTACHMENT No A9

FLCTAN2013-06 Agendadoc

FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE COMMITTEE

AGENDA mdash NFPA 30 Second Draft Meeting

NFPA 30 Technical Committee on Tank Storage and Piping Systems

Doubletree Hotel ndash San Antonio Downtown San Antonio TX

Tuesday June 18 2013 800 AM to 500 PM Wednesday June 19 2013 800 AM to 1200 PM

1 Call to Order 2 Introduction of Attendees Update of Committee Roster [Attachment A1] 3 Approval of Minutes of Last Meeting [August 2012 NFPA Headquarters Quincy MA]

[Attachment A2] 4 Report of Committee Chair 5 Report of Staff Liaison

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 ndash Security for Unsupervised Tanks ndash Recommendation from CSB [Attachment A4] 8 Address Committee Inputs s 11 and 12 ndash Pressure Limitations [Attachment A5] [NOTE It is the Task Grouprsquos 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 ndash Table for Emergency Vent Reduction Factors [Attachment A6] [NOTE It is the Task Grouprsquos recommendation to leave the current text as is] 10 Address Committee Input 15 ndash Capacity Limitations for Secondary Containment-type Tanks [Attachment A7] [NOTE It is the Task Grouprsquos 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

FLCTAN2013-06 Agendadoc

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 ndash Low-melting Point Piping Materials ndash Recommendation from CSB [Attachment A8] 12 Address Committee Input 2 ndash Materials of Construction for Tanks [Attachment A9] 13 Recent Correspondence [NONE] 14 Old Business [NONE] 15 New Business

Federal Regulatory Agency Task Group [Work w CSB OSHA etc to Develop Recommendations in NFPA Format)

Tank Spacing Task Group [Review Section 224 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 ndash Identify Work Areas

16 Schedule Next Meeting(s) 17 Adjournment

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Stephen W Haines

ChairHaines Fire amp Risk Consulting Corp1 Linda Lane Suite BSouthampton NJ 08088Alternate Anthony M Ordile

SE 08092012FLC-TAN

Steven P Allwein

PrincipalMorrison Brothers Company570 East Seventh StreetDubuque IA 52001

M 7162003

FLC-TAN

John H Bagnall

PrincipalBurns amp McDonnell Engineering CompanyPO Box 419173Kansas City MO 64141

SE 1152004FLC-TAN

Gregory P Bareta

PrincipalWisconsin Department of Commerce141 NW Barstow StreetWaukesha WI 53188-3789

E 342008

FLC-TAN

Tim D Blackford

PrincipalChevron Energy Technology Company3901 Briarpark DriveHouston TX 77042American Petroleum InstituteAlternate Richard S Kraus

U 312011FLC-TAN

John V Cignatta

PrincipalDatanet Engineering Inc11416 Reisterstown RoadOwings Mills MD 21117

SE 822010

FLC-TAN

Sullivan D Curran

PrincipalFiberglass Tank amp Pipe Institute11150 South Wilcrest Drive Suite 101Houston TX 77099-4343Alternate Patrick A McLaughlin

M 111994FLC-TAN

Charles A Davis

PrincipalURS Corporation7650 West Courtney Campbell CausewayTampa FL 33607-1462

SE 1011996

FLC-TAN

Claire V De Taeye

PrincipalTravelers Insurance Company75 Town Centre DriveRochester NY 14623

I 312011FLC-TAN

Michael Doxey

PrincipalHMT Inc24 Waterway Avenue Suite 400The Woodlands TX 77380

M 08092012

FLC-TAN

Wayne B Geyer

PrincipalSteel Tank Institute (STISPFA)944 Donata CourtLake Zurich IL 60047Alternate Jeffrey M Shapiro

M 111986FLC-TAN

Edward S Goldhammer

PrincipalAon Fire Protection11770 Bernardo PlazaSan Diego CA 92128Alternate Thomas S Lentz

I 852009

FLC-TAN

Dwight H Havens

PrincipalBechtel Marine Propulsion CorporationKnolls Atomic Power Laboratory20 Bellflower RoadMalta NY 12020-4431

U 7241997FLC-TAN

David C Kirby

PrincipalBaker Engineering amp Risk Consultants Inc1560 Clearview HeightsCharleston WV 25312Alternate Duane L Rehmeyer

SE 111991

1

bbenedetti
Text Box
ATTACHMENT No A1

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Gregory D Kirby

PrincipalCYTEC Industries Inc1 Heilman AvenueWillow Island WV 26134

U 1171997FLC-TAN

David P Nugent

PrincipalValspar Corporation8725 West Higgins Road Suite 1000Chicago IL 60631

U 3212006

FLC-TAN

Marcia Jo Poxson

PrincipalMichigan Department of Environmental QualityPO Box 30426Lansing MI 48909-7926Alternate R Jeff Tanner

E 10292012FLC-TAN

Niall Ramsden

PrincipalResource Protection InternationalWalker HouseGeorge StreetAylesbury Bucks HP20 2HU United Kingdom

SE 10292012

FLC-TAN

Robert N Renkes

PrincipalPetroleum Equipment Institute6514 East 69th StreetTulsa OK 74133

M 111984FLC-TAN

John W Richmond Sr

PrincipalEastman Chemical CompanyPO Box 511 (B-18)Kingsport TN 37663

U 4142005

FLC-TAN

Roland A Riegel

PrincipalUL LLC1285 Walt Whitman RoadMelville NY 11747-3085Alternate Alfredo M Ramirez

RT 4152004FLC-TAN

James R Rocco

PrincipalSage Risk Solutions LLC360 Heritage RoadAurora OH 44202Petroleum Marketers Association of AmericaAlternate Charles R Plummer

U 3212006

FLC-TAN

Tim G Schroeder

PrincipalHusky Corporation2325 Husky WayPacific MO 63069

M 10182011FLC-TAN

Clark D Shepard

PrincipalExxonMobil CorporationResearch amp Engineering3225 Gallows Road Room 3A2111Fairfax VA 22037Alternate David W Owen

U 1122000

FLC-TAN

Beth Tate

PrincipalOffice of the Fire MarshalCommunity Safety amp Correctional Services5775 Yonge Street 7th FloorToronto ON M2M 4J1 Canada

E 7292005FLC-TAN

David B Wechsler

Principal27706 Dalton Bluff CourtKaty TX 77494American Chemistry Council

U 10272009

FLC-TAN

Peter J Willse

PrincipalXL Global Asset Protection Services100 Constitution Plaza 12th FloorHartford CT 06103Alternate Luis F Arango

I 3212006FLC-TAN

Jack Woycheese

PrincipalHughes Associates Inc2195 Overlook DriveWalnut Creek CA 94597Alternate Joseph L Scheffey

SE 111996

2

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Luis F Arango

AlternateXL Global Asset Protection Services21707 Shallow Glen LaneKaty TX 77450Principal Peter J Willse

I 7162003FLC-TAN

Richard S Kraus

AlternateAPIPetroleum Safety Consultants210 East Fairfax Street Apt 600Falls Church VA 22046-2909American Petroleum InstitutePrincipal Tim D Blackford

U 452001

FLC-TAN

Thomas S Lentz

AlternateAon Risk Services Inc200 East Randolph StreetChicago IL 60014Principal Edward S Goldhammer

I 322010FLC-TAN

Patrick A McLaughlin

AlternateMcLaughlin amp Associates2070 South Fox Glen WayEagle ID 83616Fiberglass Tank amp Pipe InstitutePrincipal Sullivan D Curran

M 411994

FLC-TAN

Anthony M Ordile

AlternateHaines Fire amp Risk Consulting Corporation1 Linda Lane Suite BSouthampton NJ 08088Principal Stephen W Haines

SE 1011993FLC-TAN

David W Owen

AlternateExxonMobil CorporationResearch and Engineering2800 Decker Drive MOB 541Baytown TX 77520Principal Clark D Shepard

U 7122001

FLC-TAN

Charles R Plummer

AlternatePPM Consultants Inc1600 Lamy LaneMonroe LA 71201-3736Petroleum Marketers Association of AmericaPrincipal James R Rocco

U 4142005FLC-TAN

Alfredo M Ramirez

AlternateUL LLC333 Pfingsten RoadNorthbrook IL 60062-2096Principal Roland A Riegel

RT 4152004

FLC-TAN

Duane L Rehmeyer

AlternateBaker Engineering amp Risk Consultants Inc709 Highspire RoadGlenmore PA 19343Principal David C Kirby

SE 822010FLC-TAN

Joseph L Scheffey

AlternateHughes Associates Inc3610 Commerce Drive Suite 817Baltimore MD 21227-1652Principal Jack Woycheese

SE 03072013

FLC-TAN

Jeffrey M Shapiro

AlternateInternational Code Consultants8207 Asmara DriveAustin TX 78750Steel Tank InstituteSteel Plate Fabricators AssociationPrincipal Wayne B Geyer

M 10101997FLC-TAN

R Jeff Tanner

AlternateMichigan Department of Environmental QualityPO Box 30426Lansing MI 48909-7926Principal Marcia Jo Poxson

10292012

3

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Jeffrey J Wanko

Nonvoting MemberUS Department of LaborOccupational Safety amp Health Administration200 Constitution Ave NW Room N3119Washington DC 20210

E 03052012FLC-TAN

David L Blomquist

Member EmeritusBlomquist Fire Protection Engineering114 Golden Ridge RoadAlamo CA 94507-2869

1011993

FLC-TAN

Donald M Johnson

Member Emeritus3333 Rossmoor Parkway 1Walnut Creek CA 94595

111964FLC-TAN

Orville M Slye Jr

Member EmeritusLoss Control Associates Inc79 Sweetgum RoadLevittown PA 19056

111988

FLC-TAN

Brooke B Smith Jr

Member Emeritus114 Parkview DriveWoodland Park CO 80863

SE 111982FLC-TAN

Robert P Benedetti

Staff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy MA 02169-7471

4

FLCTAN2012-08 Minutesdoc

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 amp 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 amp Risk Consulting Corp CHAIR D H Havens Bechtel Marine Propulsion Corporation Knowles Atomic Power Laboratory D C Kirby Baker Engineering amp Risk Consultants Inc G D Kirby CYTEC Industries Inc D W Owen ExxonMobil Corporation

D L Rehmeyer Baker Engineering amp 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 amp 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

bbenedetti
Text Box
ATTACHMENT No A2

FLCTAN2012-08 Minutesdoc

P A McLaughlin McLaughlin amp Associates (Rep Fiberglass Tank amp Pipe Institute) D P Nugent Valspar Corporation A M Ordile Haines Fire amp 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 ndash 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 115 PM on Thursday August 30 2012 by Technical Committee

Chair Steve Haines 2 Attendees introduced themselves The Technical Committee roster was corrected as needed 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

Technical Committee Scope Statement The Technical Committee agreed to the need for a revised scope that accurately reflects the Technical Committeersquos 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 ldquoRecent Correspondencerdquo the Technical Committee discussed the following items

Recommendation from U S Chemical Safety and Hazard Investigation Board to mandate fully-automated 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

9 Under ldquoOld Businessrdquo 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

FLCTAN2012-08 Minutesdoc

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 2242 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 ndash Extra Hazard Group 2 The Technical Committee determined that this should be studied during the next document revision cycle

10 Under ldquoNew Businessrdquo 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 21715 Revise to require only one of the three options Section 224 Add statement that a multi-compartment tank is treated the same as a single

compartment tank for purposes of siting In 22734 should ldquoMrdquo 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 25131 conflicts with 278267 for Class II and Class III liquids Section 274 does it apply to all valves regardless of whether they connect to the top of the

tank or below the liquid level Paragraph 27441(1) What is the criteria for ldquoresistant to firerdquo Equivalent to steel Should not the provisions of 27823 through 2782121 apply to aboveground tanks as well as

underground tanks Subsection 2841 Clarify to indicate these are fixed unloading stations What is appropriate

distance for ldquodirect transfer from tank vehicle to storage tankrdquo 11 The NFPA 30 Second Draft meeting was tentatively scheduled for Thursday May 23 2013 in San

Antonio TX 12 The meeting adjourned at 545 PM

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

wwwnfpaorgdocument (ie wwwnfpaorg101) and click on the Next Edition tab

Process Stage

Process Step

Dates for TC

Dates forTC with

CC Public Input Closing Date 6222012 6222012

Final Date for TC First Draft Meeting 11302012 8312012

Public Input Posting of First Draft and TC Ballot 1182013 10122012

Stage Final date for Receipt of TC First Draft ballot 282013 1122012

(First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 2152013 1192012

Posting of First Draft for CC Meeting 11162012

Final date for CC First Draft Meeting 12282012

Posting of First Draft and CC Ballot 1182013

Final date for Receipt of CC First Draft ballot 282013

Final date for Receipt of CC First Draft ballot ‐ recirc 2152013

Post Final First Draft for Public Comment 2222013 2222013

Public Comment closing date 532013 532013

Final Date to Publish Notice of Consent Documents (Documents that received no Comments)

5102013 5102013

Appeal Closing Date for Consent Documents (Documents that received no Comments)

5242013 5242013

Final date for TC Second Draft Meeting 10182013 7122013

Comment Posting of Second Draft and TC Ballot 11292013 8232013

Stage Final date for Receipt of TC Second Draft ballot 12202013 9132013

(Second Final date for receipt of TC Second Draft ballot ‐ recirc 12272013 9202013

Draft) Posting of Second Draft for CC Meeting 9272013

Final date for CC Second Draft Meeting 1182013

Posting of Second Draft for CC Ballot 11292013

Final date for Receipt of CC Second Draft ballot 12202013

Final date for Receipt of CC Second Draft ballot ‐ recirc 12272013

Post Final Second Draft for NITMAM Review 132014 132014

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 272014 272014

Preparation Posting of Certified Amending Motions (CAMs) and Consent Documents

442014 442014

(amp Issuance) Appeal Closing Date for Consent Documents 4182014 4182014

SC Issuance Date for Consent Documents 592014 592014

Tech Session Association Meeting for Documents with CAMs 69‐122014 69‐122014

Appeals and Appeal Closing Date for Documents with CAMs 6242014 6242014

Issuance Council Issuance Date for Documents with CAMs 8142014 8142014

bbenedetti
Text Box
ATTACHMENT No A3

Committee Input No 16-NFPA 30-2012 [ Section No 21722 ]

21722 Security for Unsupervised Storage Tanks

Unsupervised isolated aboveground storage tanks shall be secured and shall be marked toidentify the fire hazards of the tank and the tankrsquos contents to the general public Where necessaryto protect the tank from tampering or trespassing the area where the tank is located shall besecured

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114315 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2011-H-1-6 made by the U S Chemical Safety andHazard Investigation Board the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for unsecured isolated storage tanks and issoliciting input for possible Technical Committee action at the second draft meeting

ResponseMessage

Ballot Results

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bbenedetti
Text Box
ATTACHMENT No A4

From D Havens 5‐17‐2013

Action by sub ndash retain current 21722 and add new appendix

Current Language 21722 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 tankrsquos 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 21722 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 tankrsquos 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 21722 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 tanks 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 A21722

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 Hiscott Jr David JTo Krumpolc Judith A Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Kraus Dick Paplawski

Robert Renkes Bob Wechsler DaveSubject RE NFPA 30 Group 1 sub team appendixDate Tuesday June 11 2013 91211 AM

My concern is that we are listing specific measures in the annex I realize that the annex is non ndashmandatory but sometimes these things creep into the code in later revisions We are also proposingto use several key ldquoundefinedrdquo words such as ldquo unsupervisedrdquo and ldquoremoterdquo and these terms willhave different meanings to different AHJrsquos and operators If we do not define these terms then thestandard dictionary definition applies and that will not provide guidance Each tank may pose adifferent hazard and to provide flexibility we should consider defaulting to allowing operators toconduct an assessment My proposal The committee is in general agreement with findings in the September 2011 CSB final reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents Additional securitymeasures should be developed based on fire and security risk assessments conducted by theoperator and petroleum industry practices Additional security measures could includeproviding a latched gate at the stairs leading to the tank platform and recommendations fromthe CSB report David Hiscott CSP CPPPhillips 66 TransportationEmergency Preparedness Response and Security3010 Briarpark Dr PWC - 7330-29Houston TX 77042Office - 832-765-1689Cell - 817-715-8951 NOTE New Contact information From Krumpolc Judith A [mailtoJudithKrumpolcbpcom] Sent Monday June 10 2013 405 PMTo Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Hiscott Jr David J Kraus DickPaplawski Robert Renkes Bob Wechsler DaveSubject [EXTERNAL]RE NFPA 30 Group 1 sub team appendix Bob and Task Group Members My concern with the Wechsler proposal A21722 is for the tanks that are remotelylocated isolated but not threatened by the public as much as in southern states such as inremote places in Alaska It is important to note that the biggest companies in the oil and gasindustry are working together with API to develop an annex for API RP 12R1 to include arequirement for a latched gate at the stairs leading to the platform for such remote tanks torespond to the same CSB report cited in the annex referenced by NFPA Should NFPAshould do similarly to avoid confusion I suggest we include a statement allowing the tankowner to make the decision when to add protective measures and give examples of additionalprotective measures The signage should be mandatory but the additional protection should

be added ldquowhen necessaryrdquo as determined by the operator when public access is a relevantthreat 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 reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents When public access isa relevant threat obvious protective measures should be implemented to help prevent thepublic from tampering with the unsupervised remotely located tanks by providing a latchedgate at the stairs leading to the platform In highly susceptible areas unsupervised remotelylocated tanks require additional protective measures which includes any or all the followingsecuring the hatches on the tanks restricting access to the entire facility or utilizinginherently safer tank design at these facilities I welcome any feedback

Judy KrumpolcTechnical Authority- Fire and Explosion AnalysisSafety + Operational Risk Deployed RampM150 W Warrenville Rd Naperville IL 60563Office 630 536-2804 Mobile 630 815-2098 Fax 630 420-4501Confidentiality Notice This electronic transmission and any documents sent with it constitute confidential inside or non-public information Ifyou are not the intended recipient or have received this communication in error please resend this communication to the sender and delete it fromyour computer system Any use or disclosure of the contents of this communication by anyone other than an intended recipient is strictlyprohibited and may be unlawful Thank you

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1008 AMTo Geyer Wayne Haines Steve Havens Dwight Hiscott Dave Kraus Dick Krumpolc Judith APaplawski Robert Renkes Bob Wechsler DaveSubject 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 [mailtodbwechslerattnet] Sent Monday June 10 2013 1027 AMTo Benedetti BobSubject Re NFPA 30 Group 1 sub team appendix BobI pulled up a copy of the final CSB Jan 2011 report on the tank incidents While there is a lotin this report I attempted rather than to repeat the information simply summarize it withinthe context of our existing statement Hopefully this accomplishes the sub team objective andstill 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 thesub team for additional comment and review Thanks

Committee Input No 11-NFPA 30-2012 [ Section No 224 ]

224 Location of Aboveground Storage Tanks

2241 Location with Respect to Property Lines Public Ways and Important Buildings

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bbenedetti
Text Box
ATTACHMENT No A5

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is not permitted to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22411(a) and Table22411(b) Where tank spacing is based on a weak roof-to-shell seam design the user shall presentevidence certifying such construction to the authority having jurisdiction upon request

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Not toExceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Waya

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Propertya

Floating roofProtection for

exposuresb12 times diameter of tank 16 times diameter of tank

NoneDiameter of tank but neednot exceed 175 ft

16 times diameter of tank

Vertical with weak roof-to-shellseam

Approved foam or

inerting systemc ontanks not exceeding

150 ft in diameterd

12 times diameter of tank 16 times diameter of tank

Protection for

exposuresb Diameter of tank 13 times diameter of tank

None2 times diameter of tank butneed not exceed 350 ft

13 times diameter of tank

Horizontal and vertical tankswith emergency relief ventingto limit pressures to 25 psi(gauge pressure of 17 kPa)

Approved inerting

systemb on the tank orapproved foam systemon vertical tanks

12 times value in Table22411(b)

12 times value in Table22411(b)

Protection for

exposuresb Value in Table 22411(b) Value in Table 22411(b)

None2 times value in Table22411(b)

Value in Table 22411(b)

Protected aboveground tank None12 times value in Table22411(b)

12 times value in Table22411(b)

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft (15 m)

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

dFor tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

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Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

For SI units 1 ft = 03 m 1 gal = 38 L

22412

Vertical tanks with weak roof-to-shell seams (see 2272) that store Class IIIA liquids shall be permitted to belocated at one-half the distances specified in Table 22411(a) provided the tanks are not within the samediked area as or within the drainage path of a tank storing a Class I or Class II liquid

22413

Tanks storing Class I Class II or Class IIIA stable liquids and operating at pressures that exceed a gaugepressure of 25 psi (17 kPa) or are equipped with emergency venting that will permit pressures to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22413 and Table 22411(b)

Table 22413 Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Permittedto Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or Can BeBuilt Upon Including the Opposite

Side of a Public Way

From Nearest Side of Any Public Wayor from Nearest Important Building on

the Same Property

Any typeProtection for

exposures1 12 times value in Table 22411(b) but notless than 25 ft

1 12 times value in Table 22411(b) but notless than 25 ft

None3 times value in Table 22411(b) but not beless than 50 ft

1 12 times value in Table 22411(b) but notless than 25 ft

For SI units 1 ft = 03 m

See definition 3346 Protection for Exposures

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22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

ResponseMessage

Ballot Results

This item has not been balloted

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Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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3 of 5 632013 1039 PM

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

ResponseMessage

Ballot Results

This item has not been balloted

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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1 of 2 632013 1048 PM

Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

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Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

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Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

FLCTAN2013-06 Agendadoc

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 ndash Low-melting Point Piping Materials ndash Recommendation from CSB [Attachment A8] 12 Address Committee Input 2 ndash Materials of Construction for Tanks [Attachment A9] 13 Recent Correspondence [NONE] 14 Old Business [NONE] 15 New Business

Federal Regulatory Agency Task Group [Work w CSB OSHA etc to Develop Recommendations in NFPA Format)

Tank Spacing Task Group [Review Section 224 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 ndash Identify Work Areas

16 Schedule Next Meeting(s) 17 Adjournment

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Stephen W Haines

ChairHaines Fire amp Risk Consulting Corp1 Linda Lane Suite BSouthampton NJ 08088Alternate Anthony M Ordile

SE 08092012FLC-TAN

Steven P Allwein

PrincipalMorrison Brothers Company570 East Seventh StreetDubuque IA 52001

M 7162003

FLC-TAN

John H Bagnall

PrincipalBurns amp McDonnell Engineering CompanyPO Box 419173Kansas City MO 64141

SE 1152004FLC-TAN

Gregory P Bareta

PrincipalWisconsin Department of Commerce141 NW Barstow StreetWaukesha WI 53188-3789

E 342008

FLC-TAN

Tim D Blackford

PrincipalChevron Energy Technology Company3901 Briarpark DriveHouston TX 77042American Petroleum InstituteAlternate Richard S Kraus

U 312011FLC-TAN

John V Cignatta

PrincipalDatanet Engineering Inc11416 Reisterstown RoadOwings Mills MD 21117

SE 822010

FLC-TAN

Sullivan D Curran

PrincipalFiberglass Tank amp Pipe Institute11150 South Wilcrest Drive Suite 101Houston TX 77099-4343Alternate Patrick A McLaughlin

M 111994FLC-TAN

Charles A Davis

PrincipalURS Corporation7650 West Courtney Campbell CausewayTampa FL 33607-1462

SE 1011996

FLC-TAN

Claire V De Taeye

PrincipalTravelers Insurance Company75 Town Centre DriveRochester NY 14623

I 312011FLC-TAN

Michael Doxey

PrincipalHMT Inc24 Waterway Avenue Suite 400The Woodlands TX 77380

M 08092012

FLC-TAN

Wayne B Geyer

PrincipalSteel Tank Institute (STISPFA)944 Donata CourtLake Zurich IL 60047Alternate Jeffrey M Shapiro

M 111986FLC-TAN

Edward S Goldhammer

PrincipalAon Fire Protection11770 Bernardo PlazaSan Diego CA 92128Alternate Thomas S Lentz

I 852009

FLC-TAN

Dwight H Havens

PrincipalBechtel Marine Propulsion CorporationKnolls Atomic Power Laboratory20 Bellflower RoadMalta NY 12020-4431

U 7241997FLC-TAN

David C Kirby

PrincipalBaker Engineering amp Risk Consultants Inc1560 Clearview HeightsCharleston WV 25312Alternate Duane L Rehmeyer

SE 111991

1

bbenedetti
Text Box
ATTACHMENT No A1

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Gregory D Kirby

PrincipalCYTEC Industries Inc1 Heilman AvenueWillow Island WV 26134

U 1171997FLC-TAN

David P Nugent

PrincipalValspar Corporation8725 West Higgins Road Suite 1000Chicago IL 60631

U 3212006

FLC-TAN

Marcia Jo Poxson

PrincipalMichigan Department of Environmental QualityPO Box 30426Lansing MI 48909-7926Alternate R Jeff Tanner

E 10292012FLC-TAN

Niall Ramsden

PrincipalResource Protection InternationalWalker HouseGeorge StreetAylesbury Bucks HP20 2HU United Kingdom

SE 10292012

FLC-TAN

Robert N Renkes

PrincipalPetroleum Equipment Institute6514 East 69th StreetTulsa OK 74133

M 111984FLC-TAN

John W Richmond Sr

PrincipalEastman Chemical CompanyPO Box 511 (B-18)Kingsport TN 37663

U 4142005

FLC-TAN

Roland A Riegel

PrincipalUL LLC1285 Walt Whitman RoadMelville NY 11747-3085Alternate Alfredo M Ramirez

RT 4152004FLC-TAN

James R Rocco

PrincipalSage Risk Solutions LLC360 Heritage RoadAurora OH 44202Petroleum Marketers Association of AmericaAlternate Charles R Plummer

U 3212006

FLC-TAN

Tim G Schroeder

PrincipalHusky Corporation2325 Husky WayPacific MO 63069

M 10182011FLC-TAN

Clark D Shepard

PrincipalExxonMobil CorporationResearch amp Engineering3225 Gallows Road Room 3A2111Fairfax VA 22037Alternate David W Owen

U 1122000

FLC-TAN

Beth Tate

PrincipalOffice of the Fire MarshalCommunity Safety amp Correctional Services5775 Yonge Street 7th FloorToronto ON M2M 4J1 Canada

E 7292005FLC-TAN

David B Wechsler

Principal27706 Dalton Bluff CourtKaty TX 77494American Chemistry Council

U 10272009

FLC-TAN

Peter J Willse

PrincipalXL Global Asset Protection Services100 Constitution Plaza 12th FloorHartford CT 06103Alternate Luis F Arango

I 3212006FLC-TAN

Jack Woycheese

PrincipalHughes Associates Inc2195 Overlook DriveWalnut Creek CA 94597Alternate Joseph L Scheffey

SE 111996

2

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Luis F Arango

AlternateXL Global Asset Protection Services21707 Shallow Glen LaneKaty TX 77450Principal Peter J Willse

I 7162003FLC-TAN

Richard S Kraus

AlternateAPIPetroleum Safety Consultants210 East Fairfax Street Apt 600Falls Church VA 22046-2909American Petroleum InstitutePrincipal Tim D Blackford

U 452001

FLC-TAN

Thomas S Lentz

AlternateAon Risk Services Inc200 East Randolph StreetChicago IL 60014Principal Edward S Goldhammer

I 322010FLC-TAN

Patrick A McLaughlin

AlternateMcLaughlin amp Associates2070 South Fox Glen WayEagle ID 83616Fiberglass Tank amp Pipe InstitutePrincipal Sullivan D Curran

M 411994

FLC-TAN

Anthony M Ordile

AlternateHaines Fire amp Risk Consulting Corporation1 Linda Lane Suite BSouthampton NJ 08088Principal Stephen W Haines

SE 1011993FLC-TAN

David W Owen

AlternateExxonMobil CorporationResearch and Engineering2800 Decker Drive MOB 541Baytown TX 77520Principal Clark D Shepard

U 7122001

FLC-TAN

Charles R Plummer

AlternatePPM Consultants Inc1600 Lamy LaneMonroe LA 71201-3736Petroleum Marketers Association of AmericaPrincipal James R Rocco

U 4142005FLC-TAN

Alfredo M Ramirez

AlternateUL LLC333 Pfingsten RoadNorthbrook IL 60062-2096Principal Roland A Riegel

RT 4152004

FLC-TAN

Duane L Rehmeyer

AlternateBaker Engineering amp Risk Consultants Inc709 Highspire RoadGlenmore PA 19343Principal David C Kirby

SE 822010FLC-TAN

Joseph L Scheffey

AlternateHughes Associates Inc3610 Commerce Drive Suite 817Baltimore MD 21227-1652Principal Jack Woycheese

SE 03072013

FLC-TAN

Jeffrey M Shapiro

AlternateInternational Code Consultants8207 Asmara DriveAustin TX 78750Steel Tank InstituteSteel Plate Fabricators AssociationPrincipal Wayne B Geyer

M 10101997FLC-TAN

R Jeff Tanner

AlternateMichigan Department of Environmental QualityPO Box 30426Lansing MI 48909-7926Principal Marcia Jo Poxson

10292012

3

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Jeffrey J Wanko

Nonvoting MemberUS Department of LaborOccupational Safety amp Health Administration200 Constitution Ave NW Room N3119Washington DC 20210

E 03052012FLC-TAN

David L Blomquist

Member EmeritusBlomquist Fire Protection Engineering114 Golden Ridge RoadAlamo CA 94507-2869

1011993

FLC-TAN

Donald M Johnson

Member Emeritus3333 Rossmoor Parkway 1Walnut Creek CA 94595

111964FLC-TAN

Orville M Slye Jr

Member EmeritusLoss Control Associates Inc79 Sweetgum RoadLevittown PA 19056

111988

FLC-TAN

Brooke B Smith Jr

Member Emeritus114 Parkview DriveWoodland Park CO 80863

SE 111982FLC-TAN

Robert P Benedetti

Staff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy MA 02169-7471

4

FLCTAN2012-08 Minutesdoc

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 amp 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 amp Risk Consulting Corp CHAIR D H Havens Bechtel Marine Propulsion Corporation Knowles Atomic Power Laboratory D C Kirby Baker Engineering amp Risk Consultants Inc G D Kirby CYTEC Industries Inc D W Owen ExxonMobil Corporation

D L Rehmeyer Baker Engineering amp 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 amp 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

bbenedetti
Text Box
ATTACHMENT No A2

FLCTAN2012-08 Minutesdoc

P A McLaughlin McLaughlin amp Associates (Rep Fiberglass Tank amp Pipe Institute) D P Nugent Valspar Corporation A M Ordile Haines Fire amp 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 ndash 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 115 PM on Thursday August 30 2012 by Technical Committee

Chair Steve Haines 2 Attendees introduced themselves The Technical Committee roster was corrected as needed 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

Technical Committee Scope Statement The Technical Committee agreed to the need for a revised scope that accurately reflects the Technical Committeersquos 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 ldquoRecent Correspondencerdquo the Technical Committee discussed the following items

Recommendation from U S Chemical Safety and Hazard Investigation Board to mandate fully-automated 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

9 Under ldquoOld Businessrdquo 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

FLCTAN2012-08 Minutesdoc

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 2242 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 ndash Extra Hazard Group 2 The Technical Committee determined that this should be studied during the next document revision cycle

10 Under ldquoNew Businessrdquo 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 21715 Revise to require only one of the three options Section 224 Add statement that a multi-compartment tank is treated the same as a single

compartment tank for purposes of siting In 22734 should ldquoMrdquo 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 25131 conflicts with 278267 for Class II and Class III liquids Section 274 does it apply to all valves regardless of whether they connect to the top of the

tank or below the liquid level Paragraph 27441(1) What is the criteria for ldquoresistant to firerdquo Equivalent to steel Should not the provisions of 27823 through 2782121 apply to aboveground tanks as well as

underground tanks Subsection 2841 Clarify to indicate these are fixed unloading stations What is appropriate

distance for ldquodirect transfer from tank vehicle to storage tankrdquo 11 The NFPA 30 Second Draft meeting was tentatively scheduled for Thursday May 23 2013 in San

Antonio TX 12 The meeting adjourned at 545 PM

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

wwwnfpaorgdocument (ie wwwnfpaorg101) and click on the Next Edition tab

Process Stage

Process Step

Dates for TC

Dates forTC with

CC Public Input Closing Date 6222012 6222012

Final Date for TC First Draft Meeting 11302012 8312012

Public Input Posting of First Draft and TC Ballot 1182013 10122012

Stage Final date for Receipt of TC First Draft ballot 282013 1122012

(First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 2152013 1192012

Posting of First Draft for CC Meeting 11162012

Final date for CC First Draft Meeting 12282012

Posting of First Draft and CC Ballot 1182013

Final date for Receipt of CC First Draft ballot 282013

Final date for Receipt of CC First Draft ballot ‐ recirc 2152013

Post Final First Draft for Public Comment 2222013 2222013

Public Comment closing date 532013 532013

Final Date to Publish Notice of Consent Documents (Documents that received no Comments)

5102013 5102013

Appeal Closing Date for Consent Documents (Documents that received no Comments)

5242013 5242013

Final date for TC Second Draft Meeting 10182013 7122013

Comment Posting of Second Draft and TC Ballot 11292013 8232013

Stage Final date for Receipt of TC Second Draft ballot 12202013 9132013

(Second Final date for receipt of TC Second Draft ballot ‐ recirc 12272013 9202013

Draft) Posting of Second Draft for CC Meeting 9272013

Final date for CC Second Draft Meeting 1182013

Posting of Second Draft for CC Ballot 11292013

Final date for Receipt of CC Second Draft ballot 12202013

Final date for Receipt of CC Second Draft ballot ‐ recirc 12272013

Post Final Second Draft for NITMAM Review 132014 132014

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 272014 272014

Preparation Posting of Certified Amending Motions (CAMs) and Consent Documents

442014 442014

(amp Issuance) Appeal Closing Date for Consent Documents 4182014 4182014

SC Issuance Date for Consent Documents 592014 592014

Tech Session Association Meeting for Documents with CAMs 69‐122014 69‐122014

Appeals and Appeal Closing Date for Documents with CAMs 6242014 6242014

Issuance Council Issuance Date for Documents with CAMs 8142014 8142014

bbenedetti
Text Box
ATTACHMENT No A3

Committee Input No 16-NFPA 30-2012 [ Section No 21722 ]

21722 Security for Unsupervised Storage Tanks

Unsupervised isolated aboveground storage tanks shall be secured and shall be marked toidentify the fire hazards of the tank and the tankrsquos contents to the general public Where necessaryto protect the tank from tampering or trespassing the area where the tank is located shall besecured

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114315 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2011-H-1-6 made by the U S Chemical Safety andHazard Investigation Board the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for unsecured isolated storage tanks and issoliciting input for possible Technical Committee action at the second draft meeting

ResponseMessage

Ballot Results

This item has not been balloted

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Text Box
ATTACHMENT No A4

From D Havens 5‐17‐2013

Action by sub ndash retain current 21722 and add new appendix

Current Language 21722 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 tankrsquos 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 21722 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 tankrsquos 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 21722 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 tanks 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 A21722

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 Hiscott Jr David JTo Krumpolc Judith A Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Kraus Dick Paplawski

Robert Renkes Bob Wechsler DaveSubject RE NFPA 30 Group 1 sub team appendixDate Tuesday June 11 2013 91211 AM

My concern is that we are listing specific measures in the annex I realize that the annex is non ndashmandatory but sometimes these things creep into the code in later revisions We are also proposingto use several key ldquoundefinedrdquo words such as ldquo unsupervisedrdquo and ldquoremoterdquo and these terms willhave different meanings to different AHJrsquos and operators If we do not define these terms then thestandard dictionary definition applies and that will not provide guidance Each tank may pose adifferent hazard and to provide flexibility we should consider defaulting to allowing operators toconduct an assessment My proposal The committee is in general agreement with findings in the September 2011 CSB final reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents Additional securitymeasures should be developed based on fire and security risk assessments conducted by theoperator and petroleum industry practices Additional security measures could includeproviding a latched gate at the stairs leading to the tank platform and recommendations fromthe CSB report David Hiscott CSP CPPPhillips 66 TransportationEmergency Preparedness Response and Security3010 Briarpark Dr PWC - 7330-29Houston TX 77042Office - 832-765-1689Cell - 817-715-8951 NOTE New Contact information From Krumpolc Judith A [mailtoJudithKrumpolcbpcom] Sent Monday June 10 2013 405 PMTo Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Hiscott Jr David J Kraus DickPaplawski Robert Renkes Bob Wechsler DaveSubject [EXTERNAL]RE NFPA 30 Group 1 sub team appendix Bob and Task Group Members My concern with the Wechsler proposal A21722 is for the tanks that are remotelylocated isolated but not threatened by the public as much as in southern states such as inremote places in Alaska It is important to note that the biggest companies in the oil and gasindustry are working together with API to develop an annex for API RP 12R1 to include arequirement for a latched gate at the stairs leading to the platform for such remote tanks torespond to the same CSB report cited in the annex referenced by NFPA Should NFPAshould do similarly to avoid confusion I suggest we include a statement allowing the tankowner to make the decision when to add protective measures and give examples of additionalprotective measures The signage should be mandatory but the additional protection should

be added ldquowhen necessaryrdquo as determined by the operator when public access is a relevantthreat 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 reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents When public access isa relevant threat obvious protective measures should be implemented to help prevent thepublic from tampering with the unsupervised remotely located tanks by providing a latchedgate at the stairs leading to the platform In highly susceptible areas unsupervised remotelylocated tanks require additional protective measures which includes any or all the followingsecuring the hatches on the tanks restricting access to the entire facility or utilizinginherently safer tank design at these facilities I welcome any feedback

Judy KrumpolcTechnical Authority- Fire and Explosion AnalysisSafety + Operational Risk Deployed RampM150 W Warrenville Rd Naperville IL 60563Office 630 536-2804 Mobile 630 815-2098 Fax 630 420-4501Confidentiality Notice This electronic transmission and any documents sent with it constitute confidential inside or non-public information Ifyou are not the intended recipient or have received this communication in error please resend this communication to the sender and delete it fromyour computer system Any use or disclosure of the contents of this communication by anyone other than an intended recipient is strictlyprohibited and may be unlawful Thank you

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1008 AMTo Geyer Wayne Haines Steve Havens Dwight Hiscott Dave Kraus Dick Krumpolc Judith APaplawski Robert Renkes Bob Wechsler DaveSubject 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 [mailtodbwechslerattnet] Sent Monday June 10 2013 1027 AMTo Benedetti BobSubject Re NFPA 30 Group 1 sub team appendix BobI pulled up a copy of the final CSB Jan 2011 report on the tank incidents While there is a lotin this report I attempted rather than to repeat the information simply summarize it withinthe context of our existing statement Hopefully this accomplishes the sub team objective andstill 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 thesub team for additional comment and review Thanks

Committee Input No 11-NFPA 30-2012 [ Section No 224 ]

224 Location of Aboveground Storage Tanks

2241 Location with Respect to Property Lines Public Ways and Important Buildings

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ATTACHMENT No A5

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is not permitted to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22411(a) and Table22411(b) Where tank spacing is based on a weak roof-to-shell seam design the user shall presentevidence certifying such construction to the authority having jurisdiction upon request

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Not toExceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Waya

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Propertya

Floating roofProtection for

exposuresb12 times diameter of tank 16 times diameter of tank

NoneDiameter of tank but neednot exceed 175 ft

16 times diameter of tank

Vertical with weak roof-to-shellseam

Approved foam or

inerting systemc ontanks not exceeding

150 ft in diameterd

12 times diameter of tank 16 times diameter of tank

Protection for

exposuresb Diameter of tank 13 times diameter of tank

None2 times diameter of tank butneed not exceed 350 ft

13 times diameter of tank

Horizontal and vertical tankswith emergency relief ventingto limit pressures to 25 psi(gauge pressure of 17 kPa)

Approved inerting

systemb on the tank orapproved foam systemon vertical tanks

12 times value in Table22411(b)

12 times value in Table22411(b)

Protection for

exposuresb Value in Table 22411(b) Value in Table 22411(b)

None2 times value in Table22411(b)

Value in Table 22411(b)

Protected aboveground tank None12 times value in Table22411(b)

12 times value in Table22411(b)

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft (15 m)

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

dFor tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

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Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

For SI units 1 ft = 03 m 1 gal = 38 L

22412

Vertical tanks with weak roof-to-shell seams (see 2272) that store Class IIIA liquids shall be permitted to belocated at one-half the distances specified in Table 22411(a) provided the tanks are not within the samediked area as or within the drainage path of a tank storing a Class I or Class II liquid

22413

Tanks storing Class I Class II or Class IIIA stable liquids and operating at pressures that exceed a gaugepressure of 25 psi (17 kPa) or are equipped with emergency venting that will permit pressures to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22413 and Table 22411(b)

Table 22413 Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Permittedto Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or Can BeBuilt Upon Including the Opposite

Side of a Public Way

From Nearest Side of Any Public Wayor from Nearest Important Building on

the Same Property

Any typeProtection for

exposures1 12 times value in Table 22411(b) but notless than 25 ft

1 12 times value in Table 22411(b) but notless than 25 ft

None3 times value in Table 22411(b) but not beless than 50 ft

1 12 times value in Table 22411(b) but notless than 25 ft

For SI units 1 ft = 03 m

See definition 3346 Protection for Exposures

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22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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5 of 8 632013 1037 PM

22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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6 of 8 632013 1037 PM

22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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7 of 8 632013 1037 PM

224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

ResponseMessage

Ballot Results

This item has not been balloted

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8 of 8 632013 1037 PM

Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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1 of 5 632013 1039 PM

Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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3 of 5 632013 1039 PM

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

ResponseMessage

Ballot Results

This item has not been balloted

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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3 of 5 632013 1049 PM

Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

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bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Stephen W Haines

ChairHaines Fire amp Risk Consulting Corp1 Linda Lane Suite BSouthampton NJ 08088Alternate Anthony M Ordile

SE 08092012FLC-TAN

Steven P Allwein

PrincipalMorrison Brothers Company570 East Seventh StreetDubuque IA 52001

M 7162003

FLC-TAN

John H Bagnall

PrincipalBurns amp McDonnell Engineering CompanyPO Box 419173Kansas City MO 64141

SE 1152004FLC-TAN

Gregory P Bareta

PrincipalWisconsin Department of Commerce141 NW Barstow StreetWaukesha WI 53188-3789

E 342008

FLC-TAN

Tim D Blackford

PrincipalChevron Energy Technology Company3901 Briarpark DriveHouston TX 77042American Petroleum InstituteAlternate Richard S Kraus

U 312011FLC-TAN

John V Cignatta

PrincipalDatanet Engineering Inc11416 Reisterstown RoadOwings Mills MD 21117

SE 822010

FLC-TAN

Sullivan D Curran

PrincipalFiberglass Tank amp Pipe Institute11150 South Wilcrest Drive Suite 101Houston TX 77099-4343Alternate Patrick A McLaughlin

M 111994FLC-TAN

Charles A Davis

PrincipalURS Corporation7650 West Courtney Campbell CausewayTampa FL 33607-1462

SE 1011996

FLC-TAN

Claire V De Taeye

PrincipalTravelers Insurance Company75 Town Centre DriveRochester NY 14623

I 312011FLC-TAN

Michael Doxey

PrincipalHMT Inc24 Waterway Avenue Suite 400The Woodlands TX 77380

M 08092012

FLC-TAN

Wayne B Geyer

PrincipalSteel Tank Institute (STISPFA)944 Donata CourtLake Zurich IL 60047Alternate Jeffrey M Shapiro

M 111986FLC-TAN

Edward S Goldhammer

PrincipalAon Fire Protection11770 Bernardo PlazaSan Diego CA 92128Alternate Thomas S Lentz

I 852009

FLC-TAN

Dwight H Havens

PrincipalBechtel Marine Propulsion CorporationKnolls Atomic Power Laboratory20 Bellflower RoadMalta NY 12020-4431

U 7241997FLC-TAN

David C Kirby

PrincipalBaker Engineering amp Risk Consultants Inc1560 Clearview HeightsCharleston WV 25312Alternate Duane L Rehmeyer

SE 111991

1

bbenedetti
Text Box
ATTACHMENT No A1

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Gregory D Kirby

PrincipalCYTEC Industries Inc1 Heilman AvenueWillow Island WV 26134

U 1171997FLC-TAN

David P Nugent

PrincipalValspar Corporation8725 West Higgins Road Suite 1000Chicago IL 60631

U 3212006

FLC-TAN

Marcia Jo Poxson

PrincipalMichigan Department of Environmental QualityPO Box 30426Lansing MI 48909-7926Alternate R Jeff Tanner

E 10292012FLC-TAN

Niall Ramsden

PrincipalResource Protection InternationalWalker HouseGeorge StreetAylesbury Bucks HP20 2HU United Kingdom

SE 10292012

FLC-TAN

Robert N Renkes

PrincipalPetroleum Equipment Institute6514 East 69th StreetTulsa OK 74133

M 111984FLC-TAN

John W Richmond Sr

PrincipalEastman Chemical CompanyPO Box 511 (B-18)Kingsport TN 37663

U 4142005

FLC-TAN

Roland A Riegel

PrincipalUL LLC1285 Walt Whitman RoadMelville NY 11747-3085Alternate Alfredo M Ramirez

RT 4152004FLC-TAN

James R Rocco

PrincipalSage Risk Solutions LLC360 Heritage RoadAurora OH 44202Petroleum Marketers Association of AmericaAlternate Charles R Plummer

U 3212006

FLC-TAN

Tim G Schroeder

PrincipalHusky Corporation2325 Husky WayPacific MO 63069

M 10182011FLC-TAN

Clark D Shepard

PrincipalExxonMobil CorporationResearch amp Engineering3225 Gallows Road Room 3A2111Fairfax VA 22037Alternate David W Owen

U 1122000

FLC-TAN

Beth Tate

PrincipalOffice of the Fire MarshalCommunity Safety amp Correctional Services5775 Yonge Street 7th FloorToronto ON M2M 4J1 Canada

E 7292005FLC-TAN

David B Wechsler

Principal27706 Dalton Bluff CourtKaty TX 77494American Chemistry Council

U 10272009

FLC-TAN

Peter J Willse

PrincipalXL Global Asset Protection Services100 Constitution Plaza 12th FloorHartford CT 06103Alternate Luis F Arango

I 3212006FLC-TAN

Jack Woycheese

PrincipalHughes Associates Inc2195 Overlook DriveWalnut Creek CA 94597Alternate Joseph L Scheffey

SE 111996

2

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Luis F Arango

AlternateXL Global Asset Protection Services21707 Shallow Glen LaneKaty TX 77450Principal Peter J Willse

I 7162003FLC-TAN

Richard S Kraus

AlternateAPIPetroleum Safety Consultants210 East Fairfax Street Apt 600Falls Church VA 22046-2909American Petroleum InstitutePrincipal Tim D Blackford

U 452001

FLC-TAN

Thomas S Lentz

AlternateAon Risk Services Inc200 East Randolph StreetChicago IL 60014Principal Edward S Goldhammer

I 322010FLC-TAN

Patrick A McLaughlin

AlternateMcLaughlin amp Associates2070 South Fox Glen WayEagle ID 83616Fiberglass Tank amp Pipe InstitutePrincipal Sullivan D Curran

M 411994

FLC-TAN

Anthony M Ordile

AlternateHaines Fire amp Risk Consulting Corporation1 Linda Lane Suite BSouthampton NJ 08088Principal Stephen W Haines

SE 1011993FLC-TAN

David W Owen

AlternateExxonMobil CorporationResearch and Engineering2800 Decker Drive MOB 541Baytown TX 77520Principal Clark D Shepard

U 7122001

FLC-TAN

Charles R Plummer

AlternatePPM Consultants Inc1600 Lamy LaneMonroe LA 71201-3736Petroleum Marketers Association of AmericaPrincipal James R Rocco

U 4142005FLC-TAN

Alfredo M Ramirez

AlternateUL LLC333 Pfingsten RoadNorthbrook IL 60062-2096Principal Roland A Riegel

RT 4152004

FLC-TAN

Duane L Rehmeyer

AlternateBaker Engineering amp Risk Consultants Inc709 Highspire RoadGlenmore PA 19343Principal David C Kirby

SE 822010FLC-TAN

Joseph L Scheffey

AlternateHughes Associates Inc3610 Commerce Drive Suite 817Baltimore MD 21227-1652Principal Jack Woycheese

SE 03072013

FLC-TAN

Jeffrey M Shapiro

AlternateInternational Code Consultants8207 Asmara DriveAustin TX 78750Steel Tank InstituteSteel Plate Fabricators AssociationPrincipal Wayne B Geyer

M 10101997FLC-TAN

R Jeff Tanner

AlternateMichigan Department of Environmental QualityPO Box 30426Lansing MI 48909-7926Principal Marcia Jo Poxson

10292012

3

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Jeffrey J Wanko

Nonvoting MemberUS Department of LaborOccupational Safety amp Health Administration200 Constitution Ave NW Room N3119Washington DC 20210

E 03052012FLC-TAN

David L Blomquist

Member EmeritusBlomquist Fire Protection Engineering114 Golden Ridge RoadAlamo CA 94507-2869

1011993

FLC-TAN

Donald M Johnson

Member Emeritus3333 Rossmoor Parkway 1Walnut Creek CA 94595

111964FLC-TAN

Orville M Slye Jr

Member EmeritusLoss Control Associates Inc79 Sweetgum RoadLevittown PA 19056

111988

FLC-TAN

Brooke B Smith Jr

Member Emeritus114 Parkview DriveWoodland Park CO 80863

SE 111982FLC-TAN

Robert P Benedetti

Staff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy MA 02169-7471

4

FLCTAN2012-08 Minutesdoc

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 amp 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 amp Risk Consulting Corp CHAIR D H Havens Bechtel Marine Propulsion Corporation Knowles Atomic Power Laboratory D C Kirby Baker Engineering amp Risk Consultants Inc G D Kirby CYTEC Industries Inc D W Owen ExxonMobil Corporation

D L Rehmeyer Baker Engineering amp 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 amp 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

bbenedetti
Text Box
ATTACHMENT No A2

FLCTAN2012-08 Minutesdoc

P A McLaughlin McLaughlin amp Associates (Rep Fiberglass Tank amp Pipe Institute) D P Nugent Valspar Corporation A M Ordile Haines Fire amp 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 ndash 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 115 PM on Thursday August 30 2012 by Technical Committee

Chair Steve Haines 2 Attendees introduced themselves The Technical Committee roster was corrected as needed 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

Technical Committee Scope Statement The Technical Committee agreed to the need for a revised scope that accurately reflects the Technical Committeersquos 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 ldquoRecent Correspondencerdquo the Technical Committee discussed the following items

Recommendation from U S Chemical Safety and Hazard Investigation Board to mandate fully-automated 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

9 Under ldquoOld Businessrdquo 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

FLCTAN2012-08 Minutesdoc

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 2242 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 ndash Extra Hazard Group 2 The Technical Committee determined that this should be studied during the next document revision cycle

10 Under ldquoNew Businessrdquo 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 21715 Revise to require only one of the three options Section 224 Add statement that a multi-compartment tank is treated the same as a single

compartment tank for purposes of siting In 22734 should ldquoMrdquo 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 25131 conflicts with 278267 for Class II and Class III liquids Section 274 does it apply to all valves regardless of whether they connect to the top of the

tank or below the liquid level Paragraph 27441(1) What is the criteria for ldquoresistant to firerdquo Equivalent to steel Should not the provisions of 27823 through 2782121 apply to aboveground tanks as well as

underground tanks Subsection 2841 Clarify to indicate these are fixed unloading stations What is appropriate

distance for ldquodirect transfer from tank vehicle to storage tankrdquo 11 The NFPA 30 Second Draft meeting was tentatively scheduled for Thursday May 23 2013 in San

Antonio TX 12 The meeting adjourned at 545 PM

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

wwwnfpaorgdocument (ie wwwnfpaorg101) and click on the Next Edition tab

Process Stage

Process Step

Dates for TC

Dates forTC with

CC Public Input Closing Date 6222012 6222012

Final Date for TC First Draft Meeting 11302012 8312012

Public Input Posting of First Draft and TC Ballot 1182013 10122012

Stage Final date for Receipt of TC First Draft ballot 282013 1122012

(First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 2152013 1192012

Posting of First Draft for CC Meeting 11162012

Final date for CC First Draft Meeting 12282012

Posting of First Draft and CC Ballot 1182013

Final date for Receipt of CC First Draft ballot 282013

Final date for Receipt of CC First Draft ballot ‐ recirc 2152013

Post Final First Draft for Public Comment 2222013 2222013

Public Comment closing date 532013 532013

Final Date to Publish Notice of Consent Documents (Documents that received no Comments)

5102013 5102013

Appeal Closing Date for Consent Documents (Documents that received no Comments)

5242013 5242013

Final date for TC Second Draft Meeting 10182013 7122013

Comment Posting of Second Draft and TC Ballot 11292013 8232013

Stage Final date for Receipt of TC Second Draft ballot 12202013 9132013

(Second Final date for receipt of TC Second Draft ballot ‐ recirc 12272013 9202013

Draft) Posting of Second Draft for CC Meeting 9272013

Final date for CC Second Draft Meeting 1182013

Posting of Second Draft for CC Ballot 11292013

Final date for Receipt of CC Second Draft ballot 12202013

Final date for Receipt of CC Second Draft ballot ‐ recirc 12272013

Post Final Second Draft for NITMAM Review 132014 132014

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 272014 272014

Preparation Posting of Certified Amending Motions (CAMs) and Consent Documents

442014 442014

(amp Issuance) Appeal Closing Date for Consent Documents 4182014 4182014

SC Issuance Date for Consent Documents 592014 592014

Tech Session Association Meeting for Documents with CAMs 69‐122014 69‐122014

Appeals and Appeal Closing Date for Documents with CAMs 6242014 6242014

Issuance Council Issuance Date for Documents with CAMs 8142014 8142014

bbenedetti
Text Box
ATTACHMENT No A3

Committee Input No 16-NFPA 30-2012 [ Section No 21722 ]

21722 Security for Unsupervised Storage Tanks

Unsupervised isolated aboveground storage tanks shall be secured and shall be marked toidentify the fire hazards of the tank and the tankrsquos contents to the general public Where necessaryto protect the tank from tampering or trespassing the area where the tank is located shall besecured

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114315 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2011-H-1-6 made by the U S Chemical Safety andHazard Investigation Board the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for unsecured isolated storage tanks and issoliciting input for possible Technical Committee action at the second draft meeting

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 6112013 1011 AM

bbenedetti
Text Box
ATTACHMENT No A4

From D Havens 5‐17‐2013

Action by sub ndash retain current 21722 and add new appendix

Current Language 21722 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 tankrsquos 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 21722 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 tankrsquos 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 21722 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 tanks 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 A21722

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 Hiscott Jr David JTo Krumpolc Judith A Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Kraus Dick Paplawski

Robert Renkes Bob Wechsler DaveSubject RE NFPA 30 Group 1 sub team appendixDate Tuesday June 11 2013 91211 AM

My concern is that we are listing specific measures in the annex I realize that the annex is non ndashmandatory but sometimes these things creep into the code in later revisions We are also proposingto use several key ldquoundefinedrdquo words such as ldquo unsupervisedrdquo and ldquoremoterdquo and these terms willhave different meanings to different AHJrsquos and operators If we do not define these terms then thestandard dictionary definition applies and that will not provide guidance Each tank may pose adifferent hazard and to provide flexibility we should consider defaulting to allowing operators toconduct an assessment My proposal The committee is in general agreement with findings in the September 2011 CSB final reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents Additional securitymeasures should be developed based on fire and security risk assessments conducted by theoperator and petroleum industry practices Additional security measures could includeproviding a latched gate at the stairs leading to the tank platform and recommendations fromthe CSB report David Hiscott CSP CPPPhillips 66 TransportationEmergency Preparedness Response and Security3010 Briarpark Dr PWC - 7330-29Houston TX 77042Office - 832-765-1689Cell - 817-715-8951 NOTE New Contact information From Krumpolc Judith A [mailtoJudithKrumpolcbpcom] Sent Monday June 10 2013 405 PMTo Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Hiscott Jr David J Kraus DickPaplawski Robert Renkes Bob Wechsler DaveSubject [EXTERNAL]RE NFPA 30 Group 1 sub team appendix Bob and Task Group Members My concern with the Wechsler proposal A21722 is for the tanks that are remotelylocated isolated but not threatened by the public as much as in southern states such as inremote places in Alaska It is important to note that the biggest companies in the oil and gasindustry are working together with API to develop an annex for API RP 12R1 to include arequirement for a latched gate at the stairs leading to the platform for such remote tanks torespond to the same CSB report cited in the annex referenced by NFPA Should NFPAshould do similarly to avoid confusion I suggest we include a statement allowing the tankowner to make the decision when to add protective measures and give examples of additionalprotective measures The signage should be mandatory but the additional protection should

be added ldquowhen necessaryrdquo as determined by the operator when public access is a relevantthreat 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 reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents When public access isa relevant threat obvious protective measures should be implemented to help prevent thepublic from tampering with the unsupervised remotely located tanks by providing a latchedgate at the stairs leading to the platform In highly susceptible areas unsupervised remotelylocated tanks require additional protective measures which includes any or all the followingsecuring the hatches on the tanks restricting access to the entire facility or utilizinginherently safer tank design at these facilities I welcome any feedback

Judy KrumpolcTechnical Authority- Fire and Explosion AnalysisSafety + Operational Risk Deployed RampM150 W Warrenville Rd Naperville IL 60563Office 630 536-2804 Mobile 630 815-2098 Fax 630 420-4501Confidentiality Notice This electronic transmission and any documents sent with it constitute confidential inside or non-public information Ifyou are not the intended recipient or have received this communication in error please resend this communication to the sender and delete it fromyour computer system Any use or disclosure of the contents of this communication by anyone other than an intended recipient is strictlyprohibited and may be unlawful Thank you

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1008 AMTo Geyer Wayne Haines Steve Havens Dwight Hiscott Dave Kraus Dick Krumpolc Judith APaplawski Robert Renkes Bob Wechsler DaveSubject 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 [mailtodbwechslerattnet] Sent Monday June 10 2013 1027 AMTo Benedetti BobSubject Re NFPA 30 Group 1 sub team appendix BobI pulled up a copy of the final CSB Jan 2011 report on the tank incidents While there is a lotin this report I attempted rather than to repeat the information simply summarize it withinthe context of our existing statement Hopefully this accomplishes the sub team objective andstill 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 thesub team for additional comment and review Thanks

Committee Input No 11-NFPA 30-2012 [ Section No 224 ]

224 Location of Aboveground Storage Tanks

2241 Location with Respect to Property Lines Public Ways and Important Buildings

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bbenedetti
Text Box
ATTACHMENT No A5

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is not permitted to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22411(a) and Table22411(b) Where tank spacing is based on a weak roof-to-shell seam design the user shall presentevidence certifying such construction to the authority having jurisdiction upon request

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Not toExceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Waya

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Propertya

Floating roofProtection for

exposuresb12 times diameter of tank 16 times diameter of tank

NoneDiameter of tank but neednot exceed 175 ft

16 times diameter of tank

Vertical with weak roof-to-shellseam

Approved foam or

inerting systemc ontanks not exceeding

150 ft in diameterd

12 times diameter of tank 16 times diameter of tank

Protection for

exposuresb Diameter of tank 13 times diameter of tank

None2 times diameter of tank butneed not exceed 350 ft

13 times diameter of tank

Horizontal and vertical tankswith emergency relief ventingto limit pressures to 25 psi(gauge pressure of 17 kPa)

Approved inerting

systemb on the tank orapproved foam systemon vertical tanks

12 times value in Table22411(b)

12 times value in Table22411(b)

Protection for

exposuresb Value in Table 22411(b) Value in Table 22411(b)

None2 times value in Table22411(b)

Value in Table 22411(b)

Protected aboveground tank None12 times value in Table22411(b)

12 times value in Table22411(b)

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft (15 m)

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

dFor tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

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Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

For SI units 1 ft = 03 m 1 gal = 38 L

22412

Vertical tanks with weak roof-to-shell seams (see 2272) that store Class IIIA liquids shall be permitted to belocated at one-half the distances specified in Table 22411(a) provided the tanks are not within the samediked area as or within the drainage path of a tank storing a Class I or Class II liquid

22413

Tanks storing Class I Class II or Class IIIA stable liquids and operating at pressures that exceed a gaugepressure of 25 psi (17 kPa) or are equipped with emergency venting that will permit pressures to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22413 and Table 22411(b)

Table 22413 Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Permittedto Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or Can BeBuilt Upon Including the Opposite

Side of a Public Way

From Nearest Side of Any Public Wayor from Nearest Important Building on

the Same Property

Any typeProtection for

exposures1 12 times value in Table 22411(b) but notless than 25 ft

1 12 times value in Table 22411(b) but notless than 25 ft

None3 times value in Table 22411(b) but not beless than 50 ft

1 12 times value in Table 22411(b) but notless than 25 ft

For SI units 1 ft = 03 m

See definition 3346 Protection for Exposures

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22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

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Ballot Results

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Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

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Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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1 of 2 632013 1048 PM

Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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1 of 5 632013 1049 PM

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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2 of 2 632013 1051 PM

Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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1 of 2 632013 1054 PM

Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1044 PM

Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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1 of 2 632013 1046 PM

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Gregory D Kirby

PrincipalCYTEC Industries Inc1 Heilman AvenueWillow Island WV 26134

U 1171997FLC-TAN

David P Nugent

PrincipalValspar Corporation8725 West Higgins Road Suite 1000Chicago IL 60631

U 3212006

FLC-TAN

Marcia Jo Poxson

PrincipalMichigan Department of Environmental QualityPO Box 30426Lansing MI 48909-7926Alternate R Jeff Tanner

E 10292012FLC-TAN

Niall Ramsden

PrincipalResource Protection InternationalWalker HouseGeorge StreetAylesbury Bucks HP20 2HU United Kingdom

SE 10292012

FLC-TAN

Robert N Renkes

PrincipalPetroleum Equipment Institute6514 East 69th StreetTulsa OK 74133

M 111984FLC-TAN

John W Richmond Sr

PrincipalEastman Chemical CompanyPO Box 511 (B-18)Kingsport TN 37663

U 4142005

FLC-TAN

Roland A Riegel

PrincipalUL LLC1285 Walt Whitman RoadMelville NY 11747-3085Alternate Alfredo M Ramirez

RT 4152004FLC-TAN

James R Rocco

PrincipalSage Risk Solutions LLC360 Heritage RoadAurora OH 44202Petroleum Marketers Association of AmericaAlternate Charles R Plummer

U 3212006

FLC-TAN

Tim G Schroeder

PrincipalHusky Corporation2325 Husky WayPacific MO 63069

M 10182011FLC-TAN

Clark D Shepard

PrincipalExxonMobil CorporationResearch amp Engineering3225 Gallows Road Room 3A2111Fairfax VA 22037Alternate David W Owen

U 1122000

FLC-TAN

Beth Tate

PrincipalOffice of the Fire MarshalCommunity Safety amp Correctional Services5775 Yonge Street 7th FloorToronto ON M2M 4J1 Canada

E 7292005FLC-TAN

David B Wechsler

Principal27706 Dalton Bluff CourtKaty TX 77494American Chemistry Council

U 10272009

FLC-TAN

Peter J Willse

PrincipalXL Global Asset Protection Services100 Constitution Plaza 12th FloorHartford CT 06103Alternate Luis F Arango

I 3212006FLC-TAN

Jack Woycheese

PrincipalHughes Associates Inc2195 Overlook DriveWalnut Creek CA 94597Alternate Joseph L Scheffey

SE 111996

2

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Luis F Arango

AlternateXL Global Asset Protection Services21707 Shallow Glen LaneKaty TX 77450Principal Peter J Willse

I 7162003FLC-TAN

Richard S Kraus

AlternateAPIPetroleum Safety Consultants210 East Fairfax Street Apt 600Falls Church VA 22046-2909American Petroleum InstitutePrincipal Tim D Blackford

U 452001

FLC-TAN

Thomas S Lentz

AlternateAon Risk Services Inc200 East Randolph StreetChicago IL 60014Principal Edward S Goldhammer

I 322010FLC-TAN

Patrick A McLaughlin

AlternateMcLaughlin amp Associates2070 South Fox Glen WayEagle ID 83616Fiberglass Tank amp Pipe InstitutePrincipal Sullivan D Curran

M 411994

FLC-TAN

Anthony M Ordile

AlternateHaines Fire amp Risk Consulting Corporation1 Linda Lane Suite BSouthampton NJ 08088Principal Stephen W Haines

SE 1011993FLC-TAN

David W Owen

AlternateExxonMobil CorporationResearch and Engineering2800 Decker Drive MOB 541Baytown TX 77520Principal Clark D Shepard

U 7122001

FLC-TAN

Charles R Plummer

AlternatePPM Consultants Inc1600 Lamy LaneMonroe LA 71201-3736Petroleum Marketers Association of AmericaPrincipal James R Rocco

U 4142005FLC-TAN

Alfredo M Ramirez

AlternateUL LLC333 Pfingsten RoadNorthbrook IL 60062-2096Principal Roland A Riegel

RT 4152004

FLC-TAN

Duane L Rehmeyer

AlternateBaker Engineering amp Risk Consultants Inc709 Highspire RoadGlenmore PA 19343Principal David C Kirby

SE 822010FLC-TAN

Joseph L Scheffey

AlternateHughes Associates Inc3610 Commerce Drive Suite 817Baltimore MD 21227-1652Principal Jack Woycheese

SE 03072013

FLC-TAN

Jeffrey M Shapiro

AlternateInternational Code Consultants8207 Asmara DriveAustin TX 78750Steel Tank InstituteSteel Plate Fabricators AssociationPrincipal Wayne B Geyer

M 10101997FLC-TAN

R Jeff Tanner

AlternateMichigan Department of Environmental QualityPO Box 30426Lansing MI 48909-7926Principal Marcia Jo Poxson

10292012

3

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Jeffrey J Wanko

Nonvoting MemberUS Department of LaborOccupational Safety amp Health Administration200 Constitution Ave NW Room N3119Washington DC 20210

E 03052012FLC-TAN

David L Blomquist

Member EmeritusBlomquist Fire Protection Engineering114 Golden Ridge RoadAlamo CA 94507-2869

1011993

FLC-TAN

Donald M Johnson

Member Emeritus3333 Rossmoor Parkway 1Walnut Creek CA 94595

111964FLC-TAN

Orville M Slye Jr

Member EmeritusLoss Control Associates Inc79 Sweetgum RoadLevittown PA 19056

111988

FLC-TAN

Brooke B Smith Jr

Member Emeritus114 Parkview DriveWoodland Park CO 80863

SE 111982FLC-TAN

Robert P Benedetti

Staff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy MA 02169-7471

4

FLCTAN2012-08 Minutesdoc

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 amp 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 amp Risk Consulting Corp CHAIR D H Havens Bechtel Marine Propulsion Corporation Knowles Atomic Power Laboratory D C Kirby Baker Engineering amp Risk Consultants Inc G D Kirby CYTEC Industries Inc D W Owen ExxonMobil Corporation

D L Rehmeyer Baker Engineering amp 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 amp 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

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Text Box
ATTACHMENT No A2

FLCTAN2012-08 Minutesdoc

P A McLaughlin McLaughlin amp Associates (Rep Fiberglass Tank amp Pipe Institute) D P Nugent Valspar Corporation A M Ordile Haines Fire amp 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 ndash 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 115 PM on Thursday August 30 2012 by Technical Committee

Chair Steve Haines 2 Attendees introduced themselves The Technical Committee roster was corrected as needed 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

Technical Committee Scope Statement The Technical Committee agreed to the need for a revised scope that accurately reflects the Technical Committeersquos 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 ldquoRecent Correspondencerdquo the Technical Committee discussed the following items

Recommendation from U S Chemical Safety and Hazard Investigation Board to mandate fully-automated 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

9 Under ldquoOld Businessrdquo 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

FLCTAN2012-08 Minutesdoc

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 2242 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 ndash Extra Hazard Group 2 The Technical Committee determined that this should be studied during the next document revision cycle

10 Under ldquoNew Businessrdquo 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 21715 Revise to require only one of the three options Section 224 Add statement that a multi-compartment tank is treated the same as a single

compartment tank for purposes of siting In 22734 should ldquoMrdquo 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 25131 conflicts with 278267 for Class II and Class III liquids Section 274 does it apply to all valves regardless of whether they connect to the top of the

tank or below the liquid level Paragraph 27441(1) What is the criteria for ldquoresistant to firerdquo Equivalent to steel Should not the provisions of 27823 through 2782121 apply to aboveground tanks as well as

underground tanks Subsection 2841 Clarify to indicate these are fixed unloading stations What is appropriate

distance for ldquodirect transfer from tank vehicle to storage tankrdquo 11 The NFPA 30 Second Draft meeting was tentatively scheduled for Thursday May 23 2013 in San

Antonio TX 12 The meeting adjourned at 545 PM

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

wwwnfpaorgdocument (ie wwwnfpaorg101) and click on the Next Edition tab

Process Stage

Process Step

Dates for TC

Dates forTC with

CC Public Input Closing Date 6222012 6222012

Final Date for TC First Draft Meeting 11302012 8312012

Public Input Posting of First Draft and TC Ballot 1182013 10122012

Stage Final date for Receipt of TC First Draft ballot 282013 1122012

(First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 2152013 1192012

Posting of First Draft for CC Meeting 11162012

Final date for CC First Draft Meeting 12282012

Posting of First Draft and CC Ballot 1182013

Final date for Receipt of CC First Draft ballot 282013

Final date for Receipt of CC First Draft ballot ‐ recirc 2152013

Post Final First Draft for Public Comment 2222013 2222013

Public Comment closing date 532013 532013

Final Date to Publish Notice of Consent Documents (Documents that received no Comments)

5102013 5102013

Appeal Closing Date for Consent Documents (Documents that received no Comments)

5242013 5242013

Final date for TC Second Draft Meeting 10182013 7122013

Comment Posting of Second Draft and TC Ballot 11292013 8232013

Stage Final date for Receipt of TC Second Draft ballot 12202013 9132013

(Second Final date for receipt of TC Second Draft ballot ‐ recirc 12272013 9202013

Draft) Posting of Second Draft for CC Meeting 9272013

Final date for CC Second Draft Meeting 1182013

Posting of Second Draft for CC Ballot 11292013

Final date for Receipt of CC Second Draft ballot 12202013

Final date for Receipt of CC Second Draft ballot ‐ recirc 12272013

Post Final Second Draft for NITMAM Review 132014 132014

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 272014 272014

Preparation Posting of Certified Amending Motions (CAMs) and Consent Documents

442014 442014

(amp Issuance) Appeal Closing Date for Consent Documents 4182014 4182014

SC Issuance Date for Consent Documents 592014 592014

Tech Session Association Meeting for Documents with CAMs 69‐122014 69‐122014

Appeals and Appeal Closing Date for Documents with CAMs 6242014 6242014

Issuance Council Issuance Date for Documents with CAMs 8142014 8142014

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ATTACHMENT No A3

Committee Input No 16-NFPA 30-2012 [ Section No 21722 ]

21722 Security for Unsupervised Storage Tanks

Unsupervised isolated aboveground storage tanks shall be secured and shall be marked toidentify the fire hazards of the tank and the tankrsquos contents to the general public Where necessaryto protect the tank from tampering or trespassing the area where the tank is located shall besecured

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114315 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2011-H-1-6 made by the U S Chemical Safety andHazard Investigation Board the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for unsecured isolated storage tanks and issoliciting input for possible Technical Committee action at the second draft meeting

ResponseMessage

Ballot Results

This item has not been balloted

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ATTACHMENT No A4

From D Havens 5‐17‐2013

Action by sub ndash retain current 21722 and add new appendix

Current Language 21722 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 tankrsquos 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 21722 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 tankrsquos 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 21722 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 tanks 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 A21722

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 Hiscott Jr David JTo Krumpolc Judith A Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Kraus Dick Paplawski

Robert Renkes Bob Wechsler DaveSubject RE NFPA 30 Group 1 sub team appendixDate Tuesday June 11 2013 91211 AM

My concern is that we are listing specific measures in the annex I realize that the annex is non ndashmandatory but sometimes these things creep into the code in later revisions We are also proposingto use several key ldquoundefinedrdquo words such as ldquo unsupervisedrdquo and ldquoremoterdquo and these terms willhave different meanings to different AHJrsquos and operators If we do not define these terms then thestandard dictionary definition applies and that will not provide guidance Each tank may pose adifferent hazard and to provide flexibility we should consider defaulting to allowing operators toconduct an assessment My proposal The committee is in general agreement with findings in the September 2011 CSB final reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents Additional securitymeasures should be developed based on fire and security risk assessments conducted by theoperator and petroleum industry practices Additional security measures could includeproviding a latched gate at the stairs leading to the tank platform and recommendations fromthe CSB report David Hiscott CSP CPPPhillips 66 TransportationEmergency Preparedness Response and Security3010 Briarpark Dr PWC - 7330-29Houston TX 77042Office - 832-765-1689Cell - 817-715-8951 NOTE New Contact information From Krumpolc Judith A [mailtoJudithKrumpolcbpcom] Sent Monday June 10 2013 405 PMTo Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Hiscott Jr David J Kraus DickPaplawski Robert Renkes Bob Wechsler DaveSubject [EXTERNAL]RE NFPA 30 Group 1 sub team appendix Bob and Task Group Members My concern with the Wechsler proposal A21722 is for the tanks that are remotelylocated isolated but not threatened by the public as much as in southern states such as inremote places in Alaska It is important to note that the biggest companies in the oil and gasindustry are working together with API to develop an annex for API RP 12R1 to include arequirement for a latched gate at the stairs leading to the platform for such remote tanks torespond to the same CSB report cited in the annex referenced by NFPA Should NFPAshould do similarly to avoid confusion I suggest we include a statement allowing the tankowner to make the decision when to add protective measures and give examples of additionalprotective measures The signage should be mandatory but the additional protection should

be added ldquowhen necessaryrdquo as determined by the operator when public access is a relevantthreat 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 reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents When public access isa relevant threat obvious protective measures should be implemented to help prevent thepublic from tampering with the unsupervised remotely located tanks by providing a latchedgate at the stairs leading to the platform In highly susceptible areas unsupervised remotelylocated tanks require additional protective measures which includes any or all the followingsecuring the hatches on the tanks restricting access to the entire facility or utilizinginherently safer tank design at these facilities I welcome any feedback

Judy KrumpolcTechnical Authority- Fire and Explosion AnalysisSafety + Operational Risk Deployed RampM150 W Warrenville Rd Naperville IL 60563Office 630 536-2804 Mobile 630 815-2098 Fax 630 420-4501Confidentiality Notice This electronic transmission and any documents sent with it constitute confidential inside or non-public information Ifyou are not the intended recipient or have received this communication in error please resend this communication to the sender and delete it fromyour computer system Any use or disclosure of the contents of this communication by anyone other than an intended recipient is strictlyprohibited and may be unlawful Thank you

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1008 AMTo Geyer Wayne Haines Steve Havens Dwight Hiscott Dave Kraus Dick Krumpolc Judith APaplawski Robert Renkes Bob Wechsler DaveSubject 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 [mailtodbwechslerattnet] Sent Monday June 10 2013 1027 AMTo Benedetti BobSubject Re NFPA 30 Group 1 sub team appendix BobI pulled up a copy of the final CSB Jan 2011 report on the tank incidents While there is a lotin this report I attempted rather than to repeat the information simply summarize it withinthe context of our existing statement Hopefully this accomplishes the sub team objective andstill 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 thesub team for additional comment and review Thanks

Committee Input No 11-NFPA 30-2012 [ Section No 224 ]

224 Location of Aboveground Storage Tanks

2241 Location with Respect to Property Lines Public Ways and Important Buildings

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ATTACHMENT No A5

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is not permitted to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22411(a) and Table22411(b) Where tank spacing is based on a weak roof-to-shell seam design the user shall presentevidence certifying such construction to the authority having jurisdiction upon request

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Not toExceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Waya

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Propertya

Floating roofProtection for

exposuresb12 times diameter of tank 16 times diameter of tank

NoneDiameter of tank but neednot exceed 175 ft

16 times diameter of tank

Vertical with weak roof-to-shellseam

Approved foam or

inerting systemc ontanks not exceeding

150 ft in diameterd

12 times diameter of tank 16 times diameter of tank

Protection for

exposuresb Diameter of tank 13 times diameter of tank

None2 times diameter of tank butneed not exceed 350 ft

13 times diameter of tank

Horizontal and vertical tankswith emergency relief ventingto limit pressures to 25 psi(gauge pressure of 17 kPa)

Approved inerting

systemb on the tank orapproved foam systemon vertical tanks

12 times value in Table22411(b)

12 times value in Table22411(b)

Protection for

exposuresb Value in Table 22411(b) Value in Table 22411(b)

None2 times value in Table22411(b)

Value in Table 22411(b)

Protected aboveground tank None12 times value in Table22411(b)

12 times value in Table22411(b)

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft (15 m)

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

dFor tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

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Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

For SI units 1 ft = 03 m 1 gal = 38 L

22412

Vertical tanks with weak roof-to-shell seams (see 2272) that store Class IIIA liquids shall be permitted to belocated at one-half the distances specified in Table 22411(a) provided the tanks are not within the samediked area as or within the drainage path of a tank storing a Class I or Class II liquid

22413

Tanks storing Class I Class II or Class IIIA stable liquids and operating at pressures that exceed a gaugepressure of 25 psi (17 kPa) or are equipped with emergency venting that will permit pressures to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22413 and Table 22411(b)

Table 22413 Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Permittedto Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or Can BeBuilt Upon Including the Opposite

Side of a Public Way

From Nearest Side of Any Public Wayor from Nearest Important Building on

the Same Property

Any typeProtection for

exposures1 12 times value in Table 22411(b) but notless than 25 ft

1 12 times value in Table 22411(b) but notless than 25 ft

None3 times value in Table 22411(b) but not beless than 50 ft

1 12 times value in Table 22411(b) but notless than 25 ft

For SI units 1 ft = 03 m

See definition 3346 Protection for Exposures

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22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

ResponseMessage

Ballot Results

This item has not been balloted

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Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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3 of 5 632013 1039 PM

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

ResponseMessage

Ballot Results

This item has not been balloted

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

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bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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1 of 2 632013 1046 PM

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Text Box
ATTACHMENT No A9

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Luis F Arango

AlternateXL Global Asset Protection Services21707 Shallow Glen LaneKaty TX 77450Principal Peter J Willse

I 7162003FLC-TAN

Richard S Kraus

AlternateAPIPetroleum Safety Consultants210 East Fairfax Street Apt 600Falls Church VA 22046-2909American Petroleum InstitutePrincipal Tim D Blackford

U 452001

FLC-TAN

Thomas S Lentz

AlternateAon Risk Services Inc200 East Randolph StreetChicago IL 60014Principal Edward S Goldhammer

I 322010FLC-TAN

Patrick A McLaughlin

AlternateMcLaughlin amp Associates2070 South Fox Glen WayEagle ID 83616Fiberglass Tank amp Pipe InstitutePrincipal Sullivan D Curran

M 411994

FLC-TAN

Anthony M Ordile

AlternateHaines Fire amp Risk Consulting Corporation1 Linda Lane Suite BSouthampton NJ 08088Principal Stephen W Haines

SE 1011993FLC-TAN

David W Owen

AlternateExxonMobil CorporationResearch and Engineering2800 Decker Drive MOB 541Baytown TX 77520Principal Clark D Shepard

U 7122001

FLC-TAN

Charles R Plummer

AlternatePPM Consultants Inc1600 Lamy LaneMonroe LA 71201-3736Petroleum Marketers Association of AmericaPrincipal James R Rocco

U 4142005FLC-TAN

Alfredo M Ramirez

AlternateUL LLC333 Pfingsten RoadNorthbrook IL 60062-2096Principal Roland A Riegel

RT 4152004

FLC-TAN

Duane L Rehmeyer

AlternateBaker Engineering amp Risk Consultants Inc709 Highspire RoadGlenmore PA 19343Principal David C Kirby

SE 822010FLC-TAN

Joseph L Scheffey

AlternateHughes Associates Inc3610 Commerce Drive Suite 817Baltimore MD 21227-1652Principal Jack Woycheese

SE 03072013

FLC-TAN

Jeffrey M Shapiro

AlternateInternational Code Consultants8207 Asmara DriveAustin TX 78750Steel Tank InstituteSteel Plate Fabricators AssociationPrincipal Wayne B Geyer

M 10101997FLC-TAN

R Jeff Tanner

AlternateMichigan Department of Environmental QualityPO Box 30426Lansing MI 48909-7926Principal Marcia Jo Poxson

10292012

3

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Jeffrey J Wanko

Nonvoting MemberUS Department of LaborOccupational Safety amp Health Administration200 Constitution Ave NW Room N3119Washington DC 20210

E 03052012FLC-TAN

David L Blomquist

Member EmeritusBlomquist Fire Protection Engineering114 Golden Ridge RoadAlamo CA 94507-2869

1011993

FLC-TAN

Donald M Johnson

Member Emeritus3333 Rossmoor Parkway 1Walnut Creek CA 94595

111964FLC-TAN

Orville M Slye Jr

Member EmeritusLoss Control Associates Inc79 Sweetgum RoadLevittown PA 19056

111988

FLC-TAN

Brooke B Smith Jr

Member Emeritus114 Parkview DriveWoodland Park CO 80863

SE 111982FLC-TAN

Robert P Benedetti

Staff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy MA 02169-7471

4

FLCTAN2012-08 Minutesdoc

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 amp 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 amp Risk Consulting Corp CHAIR D H Havens Bechtel Marine Propulsion Corporation Knowles Atomic Power Laboratory D C Kirby Baker Engineering amp Risk Consultants Inc G D Kirby CYTEC Industries Inc D W Owen ExxonMobil Corporation

D L Rehmeyer Baker Engineering amp 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 amp 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

bbenedetti
Text Box
ATTACHMENT No A2

FLCTAN2012-08 Minutesdoc

P A McLaughlin McLaughlin amp Associates (Rep Fiberglass Tank amp Pipe Institute) D P Nugent Valspar Corporation A M Ordile Haines Fire amp 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 ndash 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 115 PM on Thursday August 30 2012 by Technical Committee

Chair Steve Haines 2 Attendees introduced themselves The Technical Committee roster was corrected as needed 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

Technical Committee Scope Statement The Technical Committee agreed to the need for a revised scope that accurately reflects the Technical Committeersquos 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 ldquoRecent Correspondencerdquo the Technical Committee discussed the following items

Recommendation from U S Chemical Safety and Hazard Investigation Board to mandate fully-automated 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

9 Under ldquoOld Businessrdquo 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

FLCTAN2012-08 Minutesdoc

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 2242 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 ndash Extra Hazard Group 2 The Technical Committee determined that this should be studied during the next document revision cycle

10 Under ldquoNew Businessrdquo 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 21715 Revise to require only one of the three options Section 224 Add statement that a multi-compartment tank is treated the same as a single

compartment tank for purposes of siting In 22734 should ldquoMrdquo 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 25131 conflicts with 278267 for Class II and Class III liquids Section 274 does it apply to all valves regardless of whether they connect to the top of the

tank or below the liquid level Paragraph 27441(1) What is the criteria for ldquoresistant to firerdquo Equivalent to steel Should not the provisions of 27823 through 2782121 apply to aboveground tanks as well as

underground tanks Subsection 2841 Clarify to indicate these are fixed unloading stations What is appropriate

distance for ldquodirect transfer from tank vehicle to storage tankrdquo 11 The NFPA 30 Second Draft meeting was tentatively scheduled for Thursday May 23 2013 in San

Antonio TX 12 The meeting adjourned at 545 PM

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

wwwnfpaorgdocument (ie wwwnfpaorg101) and click on the Next Edition tab

Process Stage

Process Step

Dates for TC

Dates forTC with

CC Public Input Closing Date 6222012 6222012

Final Date for TC First Draft Meeting 11302012 8312012

Public Input Posting of First Draft and TC Ballot 1182013 10122012

Stage Final date for Receipt of TC First Draft ballot 282013 1122012

(First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 2152013 1192012

Posting of First Draft for CC Meeting 11162012

Final date for CC First Draft Meeting 12282012

Posting of First Draft and CC Ballot 1182013

Final date for Receipt of CC First Draft ballot 282013

Final date for Receipt of CC First Draft ballot ‐ recirc 2152013

Post Final First Draft for Public Comment 2222013 2222013

Public Comment closing date 532013 532013

Final Date to Publish Notice of Consent Documents (Documents that received no Comments)

5102013 5102013

Appeal Closing Date for Consent Documents (Documents that received no Comments)

5242013 5242013

Final date for TC Second Draft Meeting 10182013 7122013

Comment Posting of Second Draft and TC Ballot 11292013 8232013

Stage Final date for Receipt of TC Second Draft ballot 12202013 9132013

(Second Final date for receipt of TC Second Draft ballot ‐ recirc 12272013 9202013

Draft) Posting of Second Draft for CC Meeting 9272013

Final date for CC Second Draft Meeting 1182013

Posting of Second Draft for CC Ballot 11292013

Final date for Receipt of CC Second Draft ballot 12202013

Final date for Receipt of CC Second Draft ballot ‐ recirc 12272013

Post Final Second Draft for NITMAM Review 132014 132014

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 272014 272014

Preparation Posting of Certified Amending Motions (CAMs) and Consent Documents

442014 442014

(amp Issuance) Appeal Closing Date for Consent Documents 4182014 4182014

SC Issuance Date for Consent Documents 592014 592014

Tech Session Association Meeting for Documents with CAMs 69‐122014 69‐122014

Appeals and Appeal Closing Date for Documents with CAMs 6242014 6242014

Issuance Council Issuance Date for Documents with CAMs 8142014 8142014

bbenedetti
Text Box
ATTACHMENT No A3

Committee Input No 16-NFPA 30-2012 [ Section No 21722 ]

21722 Security for Unsupervised Storage Tanks

Unsupervised isolated aboveground storage tanks shall be secured and shall be marked toidentify the fire hazards of the tank and the tankrsquos contents to the general public Where necessaryto protect the tank from tampering or trespassing the area where the tank is located shall besecured

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114315 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2011-H-1-6 made by the U S Chemical Safety andHazard Investigation Board the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for unsecured isolated storage tanks and issoliciting input for possible Technical Committee action at the second draft meeting

ResponseMessage

Ballot Results

This item has not been balloted

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ATTACHMENT No A4

From D Havens 5‐17‐2013

Action by sub ndash retain current 21722 and add new appendix

Current Language 21722 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 tankrsquos 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 21722 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 tankrsquos 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 21722 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 tanks 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 A21722

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 Hiscott Jr David JTo Krumpolc Judith A Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Kraus Dick Paplawski

Robert Renkes Bob Wechsler DaveSubject RE NFPA 30 Group 1 sub team appendixDate Tuesday June 11 2013 91211 AM

My concern is that we are listing specific measures in the annex I realize that the annex is non ndashmandatory but sometimes these things creep into the code in later revisions We are also proposingto use several key ldquoundefinedrdquo words such as ldquo unsupervisedrdquo and ldquoremoterdquo and these terms willhave different meanings to different AHJrsquos and operators If we do not define these terms then thestandard dictionary definition applies and that will not provide guidance Each tank may pose adifferent hazard and to provide flexibility we should consider defaulting to allowing operators toconduct an assessment My proposal The committee is in general agreement with findings in the September 2011 CSB final reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents Additional securitymeasures should be developed based on fire and security risk assessments conducted by theoperator and petroleum industry practices Additional security measures could includeproviding a latched gate at the stairs leading to the tank platform and recommendations fromthe CSB report David Hiscott CSP CPPPhillips 66 TransportationEmergency Preparedness Response and Security3010 Briarpark Dr PWC - 7330-29Houston TX 77042Office - 832-765-1689Cell - 817-715-8951 NOTE New Contact information From Krumpolc Judith A [mailtoJudithKrumpolcbpcom] Sent Monday June 10 2013 405 PMTo Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Hiscott Jr David J Kraus DickPaplawski Robert Renkes Bob Wechsler DaveSubject [EXTERNAL]RE NFPA 30 Group 1 sub team appendix Bob and Task Group Members My concern with the Wechsler proposal A21722 is for the tanks that are remotelylocated isolated but not threatened by the public as much as in southern states such as inremote places in Alaska It is important to note that the biggest companies in the oil and gasindustry are working together with API to develop an annex for API RP 12R1 to include arequirement for a latched gate at the stairs leading to the platform for such remote tanks torespond to the same CSB report cited in the annex referenced by NFPA Should NFPAshould do similarly to avoid confusion I suggest we include a statement allowing the tankowner to make the decision when to add protective measures and give examples of additionalprotective measures The signage should be mandatory but the additional protection should

be added ldquowhen necessaryrdquo as determined by the operator when public access is a relevantthreat 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 reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents When public access isa relevant threat obvious protective measures should be implemented to help prevent thepublic from tampering with the unsupervised remotely located tanks by providing a latchedgate at the stairs leading to the platform In highly susceptible areas unsupervised remotelylocated tanks require additional protective measures which includes any or all the followingsecuring the hatches on the tanks restricting access to the entire facility or utilizinginherently safer tank design at these facilities I welcome any feedback

Judy KrumpolcTechnical Authority- Fire and Explosion AnalysisSafety + Operational Risk Deployed RampM150 W Warrenville Rd Naperville IL 60563Office 630 536-2804 Mobile 630 815-2098 Fax 630 420-4501Confidentiality Notice This electronic transmission and any documents sent with it constitute confidential inside or non-public information Ifyou are not the intended recipient or have received this communication in error please resend this communication to the sender and delete it fromyour computer system Any use or disclosure of the contents of this communication by anyone other than an intended recipient is strictlyprohibited and may be unlawful Thank you

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1008 AMTo Geyer Wayne Haines Steve Havens Dwight Hiscott Dave Kraus Dick Krumpolc Judith APaplawski Robert Renkes Bob Wechsler DaveSubject 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 [mailtodbwechslerattnet] Sent Monday June 10 2013 1027 AMTo Benedetti BobSubject Re NFPA 30 Group 1 sub team appendix BobI pulled up a copy of the final CSB Jan 2011 report on the tank incidents While there is a lotin this report I attempted rather than to repeat the information simply summarize it withinthe context of our existing statement Hopefully this accomplishes the sub team objective andstill 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 thesub team for additional comment and review Thanks

Committee Input No 11-NFPA 30-2012 [ Section No 224 ]

224 Location of Aboveground Storage Tanks

2241 Location with Respect to Property Lines Public Ways and Important Buildings

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ATTACHMENT No A5

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is not permitted to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22411(a) and Table22411(b) Where tank spacing is based on a weak roof-to-shell seam design the user shall presentevidence certifying such construction to the authority having jurisdiction upon request

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Not toExceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Waya

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Propertya

Floating roofProtection for

exposuresb12 times diameter of tank 16 times diameter of tank

NoneDiameter of tank but neednot exceed 175 ft

16 times diameter of tank

Vertical with weak roof-to-shellseam

Approved foam or

inerting systemc ontanks not exceeding

150 ft in diameterd

12 times diameter of tank 16 times diameter of tank

Protection for

exposuresb Diameter of tank 13 times diameter of tank

None2 times diameter of tank butneed not exceed 350 ft

13 times diameter of tank

Horizontal and vertical tankswith emergency relief ventingto limit pressures to 25 psi(gauge pressure of 17 kPa)

Approved inerting

systemb on the tank orapproved foam systemon vertical tanks

12 times value in Table22411(b)

12 times value in Table22411(b)

Protection for

exposuresb Value in Table 22411(b) Value in Table 22411(b)

None2 times value in Table22411(b)

Value in Table 22411(b)

Protected aboveground tank None12 times value in Table22411(b)

12 times value in Table22411(b)

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft (15 m)

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

dFor tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

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Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

For SI units 1 ft = 03 m 1 gal = 38 L

22412

Vertical tanks with weak roof-to-shell seams (see 2272) that store Class IIIA liquids shall be permitted to belocated at one-half the distances specified in Table 22411(a) provided the tanks are not within the samediked area as or within the drainage path of a tank storing a Class I or Class II liquid

22413

Tanks storing Class I Class II or Class IIIA stable liquids and operating at pressures that exceed a gaugepressure of 25 psi (17 kPa) or are equipped with emergency venting that will permit pressures to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22413 and Table 22411(b)

Table 22413 Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Permittedto Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or Can BeBuilt Upon Including the Opposite

Side of a Public Way

From Nearest Side of Any Public Wayor from Nearest Important Building on

the Same Property

Any typeProtection for

exposures1 12 times value in Table 22411(b) but notless than 25 ft

1 12 times value in Table 22411(b) but notless than 25 ft

None3 times value in Table 22411(b) but not beless than 50 ft

1 12 times value in Table 22411(b) but notless than 25 ft

For SI units 1 ft = 03 m

See definition 3346 Protection for Exposures

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22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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7 of 8 632013 1037 PM

224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

ResponseMessage

Ballot Results

This item has not been balloted

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8 of 8 632013 1037 PM

Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

ResponseMessage

Ballot Results

This item has not been balloted

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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1 of 2 632013 1048 PM

Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

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bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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ATTACHMENT No A9

Address List No PhoneTank Storage and Piping Systems FLC-TAN

Flammable and Combustible Liquids

Robert P Benedetti05202013

FLC-TAN

Jeffrey J Wanko

Nonvoting MemberUS Department of LaborOccupational Safety amp Health Administration200 Constitution Ave NW Room N3119Washington DC 20210

E 03052012FLC-TAN

David L Blomquist

Member EmeritusBlomquist Fire Protection Engineering114 Golden Ridge RoadAlamo CA 94507-2869

1011993

FLC-TAN

Donald M Johnson

Member Emeritus3333 Rossmoor Parkway 1Walnut Creek CA 94595

111964FLC-TAN

Orville M Slye Jr

Member EmeritusLoss Control Associates Inc79 Sweetgum RoadLevittown PA 19056

111988

FLC-TAN

Brooke B Smith Jr

Member Emeritus114 Parkview DriveWoodland Park CO 80863

SE 111982FLC-TAN

Robert P Benedetti

Staff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy MA 02169-7471

4

FLCTAN2012-08 Minutesdoc

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 amp 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 amp Risk Consulting Corp CHAIR D H Havens Bechtel Marine Propulsion Corporation Knowles Atomic Power Laboratory D C Kirby Baker Engineering amp Risk Consultants Inc G D Kirby CYTEC Industries Inc D W Owen ExxonMobil Corporation

D L Rehmeyer Baker Engineering amp 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 amp 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

bbenedetti
Text Box
ATTACHMENT No A2

FLCTAN2012-08 Minutesdoc

P A McLaughlin McLaughlin amp Associates (Rep Fiberglass Tank amp Pipe Institute) D P Nugent Valspar Corporation A M Ordile Haines Fire amp 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 ndash 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 115 PM on Thursday August 30 2012 by Technical Committee

Chair Steve Haines 2 Attendees introduced themselves The Technical Committee roster was corrected as needed 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

Technical Committee Scope Statement The Technical Committee agreed to the need for a revised scope that accurately reflects the Technical Committeersquos 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 ldquoRecent Correspondencerdquo the Technical Committee discussed the following items

Recommendation from U S Chemical Safety and Hazard Investigation Board to mandate fully-automated 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

9 Under ldquoOld Businessrdquo 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

FLCTAN2012-08 Minutesdoc

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 2242 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 ndash Extra Hazard Group 2 The Technical Committee determined that this should be studied during the next document revision cycle

10 Under ldquoNew Businessrdquo 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 21715 Revise to require only one of the three options Section 224 Add statement that a multi-compartment tank is treated the same as a single

compartment tank for purposes of siting In 22734 should ldquoMrdquo 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 25131 conflicts with 278267 for Class II and Class III liquids Section 274 does it apply to all valves regardless of whether they connect to the top of the

tank or below the liquid level Paragraph 27441(1) What is the criteria for ldquoresistant to firerdquo Equivalent to steel Should not the provisions of 27823 through 2782121 apply to aboveground tanks as well as

underground tanks Subsection 2841 Clarify to indicate these are fixed unloading stations What is appropriate

distance for ldquodirect transfer from tank vehicle to storage tankrdquo 11 The NFPA 30 Second Draft meeting was tentatively scheduled for Thursday May 23 2013 in San

Antonio TX 12 The meeting adjourned at 545 PM

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

wwwnfpaorgdocument (ie wwwnfpaorg101) and click on the Next Edition tab

Process Stage

Process Step

Dates for TC

Dates forTC with

CC Public Input Closing Date 6222012 6222012

Final Date for TC First Draft Meeting 11302012 8312012

Public Input Posting of First Draft and TC Ballot 1182013 10122012

Stage Final date for Receipt of TC First Draft ballot 282013 1122012

(First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 2152013 1192012

Posting of First Draft for CC Meeting 11162012

Final date for CC First Draft Meeting 12282012

Posting of First Draft and CC Ballot 1182013

Final date for Receipt of CC First Draft ballot 282013

Final date for Receipt of CC First Draft ballot ‐ recirc 2152013

Post Final First Draft for Public Comment 2222013 2222013

Public Comment closing date 532013 532013

Final Date to Publish Notice of Consent Documents (Documents that received no Comments)

5102013 5102013

Appeal Closing Date for Consent Documents (Documents that received no Comments)

5242013 5242013

Final date for TC Second Draft Meeting 10182013 7122013

Comment Posting of Second Draft and TC Ballot 11292013 8232013

Stage Final date for Receipt of TC Second Draft ballot 12202013 9132013

(Second Final date for receipt of TC Second Draft ballot ‐ recirc 12272013 9202013

Draft) Posting of Second Draft for CC Meeting 9272013

Final date for CC Second Draft Meeting 1182013

Posting of Second Draft for CC Ballot 11292013

Final date for Receipt of CC Second Draft ballot 12202013

Final date for Receipt of CC Second Draft ballot ‐ recirc 12272013

Post Final Second Draft for NITMAM Review 132014 132014

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 272014 272014

Preparation Posting of Certified Amending Motions (CAMs) and Consent Documents

442014 442014

(amp Issuance) Appeal Closing Date for Consent Documents 4182014 4182014

SC Issuance Date for Consent Documents 592014 592014

Tech Session Association Meeting for Documents with CAMs 69‐122014 69‐122014

Appeals and Appeal Closing Date for Documents with CAMs 6242014 6242014

Issuance Council Issuance Date for Documents with CAMs 8142014 8142014

bbenedetti
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ATTACHMENT No A3

Committee Input No 16-NFPA 30-2012 [ Section No 21722 ]

21722 Security for Unsupervised Storage Tanks

Unsupervised isolated aboveground storage tanks shall be secured and shall be marked toidentify the fire hazards of the tank and the tankrsquos contents to the general public Where necessaryto protect the tank from tampering or trespassing the area where the tank is located shall besecured

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114315 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2011-H-1-6 made by the U S Chemical Safety andHazard Investigation Board the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for unsecured isolated storage tanks and issoliciting input for possible Technical Committee action at the second draft meeting

ResponseMessage

Ballot Results

This item has not been balloted

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ATTACHMENT No A4

From D Havens 5‐17‐2013

Action by sub ndash retain current 21722 and add new appendix

Current Language 21722 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 tankrsquos 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 21722 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 tankrsquos 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 21722 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 tanks 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 A21722

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 Hiscott Jr David JTo Krumpolc Judith A Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Kraus Dick Paplawski

Robert Renkes Bob Wechsler DaveSubject RE NFPA 30 Group 1 sub team appendixDate Tuesday June 11 2013 91211 AM

My concern is that we are listing specific measures in the annex I realize that the annex is non ndashmandatory but sometimes these things creep into the code in later revisions We are also proposingto use several key ldquoundefinedrdquo words such as ldquo unsupervisedrdquo and ldquoremoterdquo and these terms willhave different meanings to different AHJrsquos and operators If we do not define these terms then thestandard dictionary definition applies and that will not provide guidance Each tank may pose adifferent hazard and to provide flexibility we should consider defaulting to allowing operators toconduct an assessment My proposal The committee is in general agreement with findings in the September 2011 CSB final reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents Additional securitymeasures should be developed based on fire and security risk assessments conducted by theoperator and petroleum industry practices Additional security measures could includeproviding a latched gate at the stairs leading to the tank platform and recommendations fromthe CSB report David Hiscott CSP CPPPhillips 66 TransportationEmergency Preparedness Response and Security3010 Briarpark Dr PWC - 7330-29Houston TX 77042Office - 832-765-1689Cell - 817-715-8951 NOTE New Contact information From Krumpolc Judith A [mailtoJudithKrumpolcbpcom] Sent Monday June 10 2013 405 PMTo Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Hiscott Jr David J Kraus DickPaplawski Robert Renkes Bob Wechsler DaveSubject [EXTERNAL]RE NFPA 30 Group 1 sub team appendix Bob and Task Group Members My concern with the Wechsler proposal A21722 is for the tanks that are remotelylocated isolated but not threatened by the public as much as in southern states such as inremote places in Alaska It is important to note that the biggest companies in the oil and gasindustry are working together with API to develop an annex for API RP 12R1 to include arequirement for a latched gate at the stairs leading to the platform for such remote tanks torespond to the same CSB report cited in the annex referenced by NFPA Should NFPAshould do similarly to avoid confusion I suggest we include a statement allowing the tankowner to make the decision when to add protective measures and give examples of additionalprotective measures The signage should be mandatory but the additional protection should

be added ldquowhen necessaryrdquo as determined by the operator when public access is a relevantthreat 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 reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents When public access isa relevant threat obvious protective measures should be implemented to help prevent thepublic from tampering with the unsupervised remotely located tanks by providing a latchedgate at the stairs leading to the platform In highly susceptible areas unsupervised remotelylocated tanks require additional protective measures which includes any or all the followingsecuring the hatches on the tanks restricting access to the entire facility or utilizinginherently safer tank design at these facilities I welcome any feedback

Judy KrumpolcTechnical Authority- Fire and Explosion AnalysisSafety + Operational Risk Deployed RampM150 W Warrenville Rd Naperville IL 60563Office 630 536-2804 Mobile 630 815-2098 Fax 630 420-4501Confidentiality Notice This electronic transmission and any documents sent with it constitute confidential inside or non-public information Ifyou are not the intended recipient or have received this communication in error please resend this communication to the sender and delete it fromyour computer system Any use or disclosure of the contents of this communication by anyone other than an intended recipient is strictlyprohibited and may be unlawful Thank you

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1008 AMTo Geyer Wayne Haines Steve Havens Dwight Hiscott Dave Kraus Dick Krumpolc Judith APaplawski Robert Renkes Bob Wechsler DaveSubject 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 [mailtodbwechslerattnet] Sent Monday June 10 2013 1027 AMTo Benedetti BobSubject Re NFPA 30 Group 1 sub team appendix BobI pulled up a copy of the final CSB Jan 2011 report on the tank incidents While there is a lotin this report I attempted rather than to repeat the information simply summarize it withinthe context of our existing statement Hopefully this accomplishes the sub team objective andstill 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 thesub team for additional comment and review Thanks

Committee Input No 11-NFPA 30-2012 [ Section No 224 ]

224 Location of Aboveground Storage Tanks

2241 Location with Respect to Property Lines Public Ways and Important Buildings

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ATTACHMENT No A5

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is not permitted to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22411(a) and Table22411(b) Where tank spacing is based on a weak roof-to-shell seam design the user shall presentevidence certifying such construction to the authority having jurisdiction upon request

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Not toExceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Waya

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Propertya

Floating roofProtection for

exposuresb12 times diameter of tank 16 times diameter of tank

NoneDiameter of tank but neednot exceed 175 ft

16 times diameter of tank

Vertical with weak roof-to-shellseam

Approved foam or

inerting systemc ontanks not exceeding

150 ft in diameterd

12 times diameter of tank 16 times diameter of tank

Protection for

exposuresb Diameter of tank 13 times diameter of tank

None2 times diameter of tank butneed not exceed 350 ft

13 times diameter of tank

Horizontal and vertical tankswith emergency relief ventingto limit pressures to 25 psi(gauge pressure of 17 kPa)

Approved inerting

systemb on the tank orapproved foam systemon vertical tanks

12 times value in Table22411(b)

12 times value in Table22411(b)

Protection for

exposuresb Value in Table 22411(b) Value in Table 22411(b)

None2 times value in Table22411(b)

Value in Table 22411(b)

Protected aboveground tank None12 times value in Table22411(b)

12 times value in Table22411(b)

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft (15 m)

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

dFor tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

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Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

For SI units 1 ft = 03 m 1 gal = 38 L

22412

Vertical tanks with weak roof-to-shell seams (see 2272) that store Class IIIA liquids shall be permitted to belocated at one-half the distances specified in Table 22411(a) provided the tanks are not within the samediked area as or within the drainage path of a tank storing a Class I or Class II liquid

22413

Tanks storing Class I Class II or Class IIIA stable liquids and operating at pressures that exceed a gaugepressure of 25 psi (17 kPa) or are equipped with emergency venting that will permit pressures to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22413 and Table 22411(b)

Table 22413 Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Permittedto Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or Can BeBuilt Upon Including the Opposite

Side of a Public Way

From Nearest Side of Any Public Wayor from Nearest Important Building on

the Same Property

Any typeProtection for

exposures1 12 times value in Table 22411(b) but notless than 25 ft

1 12 times value in Table 22411(b) but notless than 25 ft

None3 times value in Table 22411(b) but not beless than 50 ft

1 12 times value in Table 22411(b) but notless than 25 ft

For SI units 1 ft = 03 m

See definition 3346 Protection for Exposures

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22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

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Ballot Results

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8 of 8 632013 1037 PM

Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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1 of 5 632013 1039 PM

Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

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Ballot Results

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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2 of 5 632013 1049 PM

Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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3 of 5 632013 1049 PM

Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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1 of 1 632013 1042 PM

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ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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ATTACHMENT No A9

FLCTAN2012-08 Minutesdoc

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 amp 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 amp Risk Consulting Corp CHAIR D H Havens Bechtel Marine Propulsion Corporation Knowles Atomic Power Laboratory D C Kirby Baker Engineering amp Risk Consultants Inc G D Kirby CYTEC Industries Inc D W Owen ExxonMobil Corporation

D L Rehmeyer Baker Engineering amp 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 amp 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

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ATTACHMENT No A2

FLCTAN2012-08 Minutesdoc

P A McLaughlin McLaughlin amp Associates (Rep Fiberglass Tank amp Pipe Institute) D P Nugent Valspar Corporation A M Ordile Haines Fire amp 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 ndash 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 115 PM on Thursday August 30 2012 by Technical Committee

Chair Steve Haines 2 Attendees introduced themselves The Technical Committee roster was corrected as needed 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

Technical Committee Scope Statement The Technical Committee agreed to the need for a revised scope that accurately reflects the Technical Committeersquos 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 ldquoRecent Correspondencerdquo the Technical Committee discussed the following items

Recommendation from U S Chemical Safety and Hazard Investigation Board to mandate fully-automated 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

9 Under ldquoOld Businessrdquo 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

FLCTAN2012-08 Minutesdoc

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 2242 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 ndash Extra Hazard Group 2 The Technical Committee determined that this should be studied during the next document revision cycle

10 Under ldquoNew Businessrdquo 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 21715 Revise to require only one of the three options Section 224 Add statement that a multi-compartment tank is treated the same as a single

compartment tank for purposes of siting In 22734 should ldquoMrdquo 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 25131 conflicts with 278267 for Class II and Class III liquids Section 274 does it apply to all valves regardless of whether they connect to the top of the

tank or below the liquid level Paragraph 27441(1) What is the criteria for ldquoresistant to firerdquo Equivalent to steel Should not the provisions of 27823 through 2782121 apply to aboveground tanks as well as

underground tanks Subsection 2841 Clarify to indicate these are fixed unloading stations What is appropriate

distance for ldquodirect transfer from tank vehicle to storage tankrdquo 11 The NFPA 30 Second Draft meeting was tentatively scheduled for Thursday May 23 2013 in San

Antonio TX 12 The meeting adjourned at 545 PM

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

wwwnfpaorgdocument (ie wwwnfpaorg101) and click on the Next Edition tab

Process Stage

Process Step

Dates for TC

Dates forTC with

CC Public Input Closing Date 6222012 6222012

Final Date for TC First Draft Meeting 11302012 8312012

Public Input Posting of First Draft and TC Ballot 1182013 10122012

Stage Final date for Receipt of TC First Draft ballot 282013 1122012

(First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 2152013 1192012

Posting of First Draft for CC Meeting 11162012

Final date for CC First Draft Meeting 12282012

Posting of First Draft and CC Ballot 1182013

Final date for Receipt of CC First Draft ballot 282013

Final date for Receipt of CC First Draft ballot ‐ recirc 2152013

Post Final First Draft for Public Comment 2222013 2222013

Public Comment closing date 532013 532013

Final Date to Publish Notice of Consent Documents (Documents that received no Comments)

5102013 5102013

Appeal Closing Date for Consent Documents (Documents that received no Comments)

5242013 5242013

Final date for TC Second Draft Meeting 10182013 7122013

Comment Posting of Second Draft and TC Ballot 11292013 8232013

Stage Final date for Receipt of TC Second Draft ballot 12202013 9132013

(Second Final date for receipt of TC Second Draft ballot ‐ recirc 12272013 9202013

Draft) Posting of Second Draft for CC Meeting 9272013

Final date for CC Second Draft Meeting 1182013

Posting of Second Draft for CC Ballot 11292013

Final date for Receipt of CC Second Draft ballot 12202013

Final date for Receipt of CC Second Draft ballot ‐ recirc 12272013

Post Final Second Draft for NITMAM Review 132014 132014

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 272014 272014

Preparation Posting of Certified Amending Motions (CAMs) and Consent Documents

442014 442014

(amp Issuance) Appeal Closing Date for Consent Documents 4182014 4182014

SC Issuance Date for Consent Documents 592014 592014

Tech Session Association Meeting for Documents with CAMs 69‐122014 69‐122014

Appeals and Appeal Closing Date for Documents with CAMs 6242014 6242014

Issuance Council Issuance Date for Documents with CAMs 8142014 8142014

bbenedetti
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ATTACHMENT No A3

Committee Input No 16-NFPA 30-2012 [ Section No 21722 ]

21722 Security for Unsupervised Storage Tanks

Unsupervised isolated aboveground storage tanks shall be secured and shall be marked toidentify the fire hazards of the tank and the tankrsquos contents to the general public Where necessaryto protect the tank from tampering or trespassing the area where the tank is located shall besecured

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114315 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2011-H-1-6 made by the U S Chemical Safety andHazard Investigation Board the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for unsecured isolated storage tanks and issoliciting input for possible Technical Committee action at the second draft meeting

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 6112013 1011 AM

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ATTACHMENT No A4

From D Havens 5‐17‐2013

Action by sub ndash retain current 21722 and add new appendix

Current Language 21722 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 tankrsquos 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 21722 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 tankrsquos 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 21722 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 tanks 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 A21722

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 Hiscott Jr David JTo Krumpolc Judith A Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Kraus Dick Paplawski

Robert Renkes Bob Wechsler DaveSubject RE NFPA 30 Group 1 sub team appendixDate Tuesday June 11 2013 91211 AM

My concern is that we are listing specific measures in the annex I realize that the annex is non ndashmandatory but sometimes these things creep into the code in later revisions We are also proposingto use several key ldquoundefinedrdquo words such as ldquo unsupervisedrdquo and ldquoremoterdquo and these terms willhave different meanings to different AHJrsquos and operators If we do not define these terms then thestandard dictionary definition applies and that will not provide guidance Each tank may pose adifferent hazard and to provide flexibility we should consider defaulting to allowing operators toconduct an assessment My proposal The committee is in general agreement with findings in the September 2011 CSB final reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents Additional securitymeasures should be developed based on fire and security risk assessments conducted by theoperator and petroleum industry practices Additional security measures could includeproviding a latched gate at the stairs leading to the tank platform and recommendations fromthe CSB report David Hiscott CSP CPPPhillips 66 TransportationEmergency Preparedness Response and Security3010 Briarpark Dr PWC - 7330-29Houston TX 77042Office - 832-765-1689Cell - 817-715-8951 NOTE New Contact information From Krumpolc Judith A [mailtoJudithKrumpolcbpcom] Sent Monday June 10 2013 405 PMTo Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Hiscott Jr David J Kraus DickPaplawski Robert Renkes Bob Wechsler DaveSubject [EXTERNAL]RE NFPA 30 Group 1 sub team appendix Bob and Task Group Members My concern with the Wechsler proposal A21722 is for the tanks that are remotelylocated isolated but not threatened by the public as much as in southern states such as inremote places in Alaska It is important to note that the biggest companies in the oil and gasindustry are working together with API to develop an annex for API RP 12R1 to include arequirement for a latched gate at the stairs leading to the platform for such remote tanks torespond to the same CSB report cited in the annex referenced by NFPA Should NFPAshould do similarly to avoid confusion I suggest we include a statement allowing the tankowner to make the decision when to add protective measures and give examples of additionalprotective measures The signage should be mandatory but the additional protection should

be added ldquowhen necessaryrdquo as determined by the operator when public access is a relevantthreat 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 reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents When public access isa relevant threat obvious protective measures should be implemented to help prevent thepublic from tampering with the unsupervised remotely located tanks by providing a latchedgate at the stairs leading to the platform In highly susceptible areas unsupervised remotelylocated tanks require additional protective measures which includes any or all the followingsecuring the hatches on the tanks restricting access to the entire facility or utilizinginherently safer tank design at these facilities I welcome any feedback

Judy KrumpolcTechnical Authority- Fire and Explosion AnalysisSafety + Operational Risk Deployed RampM150 W Warrenville Rd Naperville IL 60563Office 630 536-2804 Mobile 630 815-2098 Fax 630 420-4501Confidentiality Notice This electronic transmission and any documents sent with it constitute confidential inside or non-public information Ifyou are not the intended recipient or have received this communication in error please resend this communication to the sender and delete it fromyour computer system Any use or disclosure of the contents of this communication by anyone other than an intended recipient is strictlyprohibited and may be unlawful Thank you

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1008 AMTo Geyer Wayne Haines Steve Havens Dwight Hiscott Dave Kraus Dick Krumpolc Judith APaplawski Robert Renkes Bob Wechsler DaveSubject 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 [mailtodbwechslerattnet] Sent Monday June 10 2013 1027 AMTo Benedetti BobSubject Re NFPA 30 Group 1 sub team appendix BobI pulled up a copy of the final CSB Jan 2011 report on the tank incidents While there is a lotin this report I attempted rather than to repeat the information simply summarize it withinthe context of our existing statement Hopefully this accomplishes the sub team objective andstill 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 thesub team for additional comment and review Thanks

Committee Input No 11-NFPA 30-2012 [ Section No 224 ]

224 Location of Aboveground Storage Tanks

2241 Location with Respect to Property Lines Public Ways and Important Buildings

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bbenedetti
Text Box
ATTACHMENT No A5

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is not permitted to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22411(a) and Table22411(b) Where tank spacing is based on a weak roof-to-shell seam design the user shall presentevidence certifying such construction to the authority having jurisdiction upon request

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Not toExceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Waya

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Propertya

Floating roofProtection for

exposuresb12 times diameter of tank 16 times diameter of tank

NoneDiameter of tank but neednot exceed 175 ft

16 times diameter of tank

Vertical with weak roof-to-shellseam

Approved foam or

inerting systemc ontanks not exceeding

150 ft in diameterd

12 times diameter of tank 16 times diameter of tank

Protection for

exposuresb Diameter of tank 13 times diameter of tank

None2 times diameter of tank butneed not exceed 350 ft

13 times diameter of tank

Horizontal and vertical tankswith emergency relief ventingto limit pressures to 25 psi(gauge pressure of 17 kPa)

Approved inerting

systemb on the tank orapproved foam systemon vertical tanks

12 times value in Table22411(b)

12 times value in Table22411(b)

Protection for

exposuresb Value in Table 22411(b) Value in Table 22411(b)

None2 times value in Table22411(b)

Value in Table 22411(b)

Protected aboveground tank None12 times value in Table22411(b)

12 times value in Table22411(b)

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft (15 m)

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

dFor tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

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Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

For SI units 1 ft = 03 m 1 gal = 38 L

22412

Vertical tanks with weak roof-to-shell seams (see 2272) that store Class IIIA liquids shall be permitted to belocated at one-half the distances specified in Table 22411(a) provided the tanks are not within the samediked area as or within the drainage path of a tank storing a Class I or Class II liquid

22413

Tanks storing Class I Class II or Class IIIA stable liquids and operating at pressures that exceed a gaugepressure of 25 psi (17 kPa) or are equipped with emergency venting that will permit pressures to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22413 and Table 22411(b)

Table 22413 Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Permittedto Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or Can BeBuilt Upon Including the Opposite

Side of a Public Way

From Nearest Side of Any Public Wayor from Nearest Important Building on

the Same Property

Any typeProtection for

exposures1 12 times value in Table 22411(b) but notless than 25 ft

1 12 times value in Table 22411(b) but notless than 25 ft

None3 times value in Table 22411(b) but not beless than 50 ft

1 12 times value in Table 22411(b) but notless than 25 ft

For SI units 1 ft = 03 m

See definition 3346 Protection for Exposures

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22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

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Ballot Results

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Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

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Ballot Results

This item has not been balloted

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Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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1 of 2 632013 1048 PM

Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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1 of 5 632013 1049 PM

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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2 of 2 632013 1051 PM

Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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1 of 2 632013 1054 PM

Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1044 PM

Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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1 of 2 632013 1046 PM

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

FLCTAN2012-08 Minutesdoc

P A McLaughlin McLaughlin amp Associates (Rep Fiberglass Tank amp Pipe Institute) D P Nugent Valspar Corporation A M Ordile Haines Fire amp 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 ndash 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 115 PM on Thursday August 30 2012 by Technical Committee

Chair Steve Haines 2 Attendees introduced themselves The Technical Committee roster was corrected as needed 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

Technical Committee Scope Statement The Technical Committee agreed to the need for a revised scope that accurately reflects the Technical Committeersquos 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 ldquoRecent Correspondencerdquo the Technical Committee discussed the following items

Recommendation from U S Chemical Safety and Hazard Investigation Board to mandate fully-automated 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

9 Under ldquoOld Businessrdquo 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

FLCTAN2012-08 Minutesdoc

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 2242 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 ndash Extra Hazard Group 2 The Technical Committee determined that this should be studied during the next document revision cycle

10 Under ldquoNew Businessrdquo 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 21715 Revise to require only one of the three options Section 224 Add statement that a multi-compartment tank is treated the same as a single

compartment tank for purposes of siting In 22734 should ldquoMrdquo 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 25131 conflicts with 278267 for Class II and Class III liquids Section 274 does it apply to all valves regardless of whether they connect to the top of the

tank or below the liquid level Paragraph 27441(1) What is the criteria for ldquoresistant to firerdquo Equivalent to steel Should not the provisions of 27823 through 2782121 apply to aboveground tanks as well as

underground tanks Subsection 2841 Clarify to indicate these are fixed unloading stations What is appropriate

distance for ldquodirect transfer from tank vehicle to storage tankrdquo 11 The NFPA 30 Second Draft meeting was tentatively scheduled for Thursday May 23 2013 in San

Antonio TX 12 The meeting adjourned at 545 PM

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

wwwnfpaorgdocument (ie wwwnfpaorg101) and click on the Next Edition tab

Process Stage

Process Step

Dates for TC

Dates forTC with

CC Public Input Closing Date 6222012 6222012

Final Date for TC First Draft Meeting 11302012 8312012

Public Input Posting of First Draft and TC Ballot 1182013 10122012

Stage Final date for Receipt of TC First Draft ballot 282013 1122012

(First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 2152013 1192012

Posting of First Draft for CC Meeting 11162012

Final date for CC First Draft Meeting 12282012

Posting of First Draft and CC Ballot 1182013

Final date for Receipt of CC First Draft ballot 282013

Final date for Receipt of CC First Draft ballot ‐ recirc 2152013

Post Final First Draft for Public Comment 2222013 2222013

Public Comment closing date 532013 532013

Final Date to Publish Notice of Consent Documents (Documents that received no Comments)

5102013 5102013

Appeal Closing Date for Consent Documents (Documents that received no Comments)

5242013 5242013

Final date for TC Second Draft Meeting 10182013 7122013

Comment Posting of Second Draft and TC Ballot 11292013 8232013

Stage Final date for Receipt of TC Second Draft ballot 12202013 9132013

(Second Final date for receipt of TC Second Draft ballot ‐ recirc 12272013 9202013

Draft) Posting of Second Draft for CC Meeting 9272013

Final date for CC Second Draft Meeting 1182013

Posting of Second Draft for CC Ballot 11292013

Final date for Receipt of CC Second Draft ballot 12202013

Final date for Receipt of CC Second Draft ballot ‐ recirc 12272013

Post Final Second Draft for NITMAM Review 132014 132014

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 272014 272014

Preparation Posting of Certified Amending Motions (CAMs) and Consent Documents

442014 442014

(amp Issuance) Appeal Closing Date for Consent Documents 4182014 4182014

SC Issuance Date for Consent Documents 592014 592014

Tech Session Association Meeting for Documents with CAMs 69‐122014 69‐122014

Appeals and Appeal Closing Date for Documents with CAMs 6242014 6242014

Issuance Council Issuance Date for Documents with CAMs 8142014 8142014

bbenedetti
Text Box
ATTACHMENT No A3

Committee Input No 16-NFPA 30-2012 [ Section No 21722 ]

21722 Security for Unsupervised Storage Tanks

Unsupervised isolated aboveground storage tanks shall be secured and shall be marked toidentify the fire hazards of the tank and the tankrsquos contents to the general public Where necessaryto protect the tank from tampering or trespassing the area where the tank is located shall besecured

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114315 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2011-H-1-6 made by the U S Chemical Safety andHazard Investigation Board the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for unsecured isolated storage tanks and issoliciting input for possible Technical Committee action at the second draft meeting

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bbenedetti
Text Box
ATTACHMENT No A4

From D Havens 5‐17‐2013

Action by sub ndash retain current 21722 and add new appendix

Current Language 21722 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 tankrsquos 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 21722 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 tankrsquos 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 21722 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 tanks 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 A21722

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 Hiscott Jr David JTo Krumpolc Judith A Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Kraus Dick Paplawski

Robert Renkes Bob Wechsler DaveSubject RE NFPA 30 Group 1 sub team appendixDate Tuesday June 11 2013 91211 AM

My concern is that we are listing specific measures in the annex I realize that the annex is non ndashmandatory but sometimes these things creep into the code in later revisions We are also proposingto use several key ldquoundefinedrdquo words such as ldquo unsupervisedrdquo and ldquoremoterdquo and these terms willhave different meanings to different AHJrsquos and operators If we do not define these terms then thestandard dictionary definition applies and that will not provide guidance Each tank may pose adifferent hazard and to provide flexibility we should consider defaulting to allowing operators toconduct an assessment My proposal The committee is in general agreement with findings in the September 2011 CSB final reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents Additional securitymeasures should be developed based on fire and security risk assessments conducted by theoperator and petroleum industry practices Additional security measures could includeproviding a latched gate at the stairs leading to the tank platform and recommendations fromthe CSB report David Hiscott CSP CPPPhillips 66 TransportationEmergency Preparedness Response and Security3010 Briarpark Dr PWC - 7330-29Houston TX 77042Office - 832-765-1689Cell - 817-715-8951 NOTE New Contact information From Krumpolc Judith A [mailtoJudithKrumpolcbpcom] Sent Monday June 10 2013 405 PMTo Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Hiscott Jr David J Kraus DickPaplawski Robert Renkes Bob Wechsler DaveSubject [EXTERNAL]RE NFPA 30 Group 1 sub team appendix Bob and Task Group Members My concern with the Wechsler proposal A21722 is for the tanks that are remotelylocated isolated but not threatened by the public as much as in southern states such as inremote places in Alaska It is important to note that the biggest companies in the oil and gasindustry are working together with API to develop an annex for API RP 12R1 to include arequirement for a latched gate at the stairs leading to the platform for such remote tanks torespond to the same CSB report cited in the annex referenced by NFPA Should NFPAshould do similarly to avoid confusion I suggest we include a statement allowing the tankowner to make the decision when to add protective measures and give examples of additionalprotective measures The signage should be mandatory but the additional protection should

be added ldquowhen necessaryrdquo as determined by the operator when public access is a relevantthreat 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 reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents When public access isa relevant threat obvious protective measures should be implemented to help prevent thepublic from tampering with the unsupervised remotely located tanks by providing a latchedgate at the stairs leading to the platform In highly susceptible areas unsupervised remotelylocated tanks require additional protective measures which includes any or all the followingsecuring the hatches on the tanks restricting access to the entire facility or utilizinginherently safer tank design at these facilities I welcome any feedback

Judy KrumpolcTechnical Authority- Fire and Explosion AnalysisSafety + Operational Risk Deployed RampM150 W Warrenville Rd Naperville IL 60563Office 630 536-2804 Mobile 630 815-2098 Fax 630 420-4501Confidentiality Notice This electronic transmission and any documents sent with it constitute confidential inside or non-public information Ifyou are not the intended recipient or have received this communication in error please resend this communication to the sender and delete it fromyour computer system Any use or disclosure of the contents of this communication by anyone other than an intended recipient is strictlyprohibited and may be unlawful Thank you

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1008 AMTo Geyer Wayne Haines Steve Havens Dwight Hiscott Dave Kraus Dick Krumpolc Judith APaplawski Robert Renkes Bob Wechsler DaveSubject 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 [mailtodbwechslerattnet] Sent Monday June 10 2013 1027 AMTo Benedetti BobSubject Re NFPA 30 Group 1 sub team appendix BobI pulled up a copy of the final CSB Jan 2011 report on the tank incidents While there is a lotin this report I attempted rather than to repeat the information simply summarize it withinthe context of our existing statement Hopefully this accomplishes the sub team objective andstill 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 thesub team for additional comment and review Thanks

Committee Input No 11-NFPA 30-2012 [ Section No 224 ]

224 Location of Aboveground Storage Tanks

2241 Location with Respect to Property Lines Public Ways and Important Buildings

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Text Box
ATTACHMENT No A5

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is not permitted to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22411(a) and Table22411(b) Where tank spacing is based on a weak roof-to-shell seam design the user shall presentevidence certifying such construction to the authority having jurisdiction upon request

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Not toExceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Waya

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Propertya

Floating roofProtection for

exposuresb12 times diameter of tank 16 times diameter of tank

NoneDiameter of tank but neednot exceed 175 ft

16 times diameter of tank

Vertical with weak roof-to-shellseam

Approved foam or

inerting systemc ontanks not exceeding

150 ft in diameterd

12 times diameter of tank 16 times diameter of tank

Protection for

exposuresb Diameter of tank 13 times diameter of tank

None2 times diameter of tank butneed not exceed 350 ft

13 times diameter of tank

Horizontal and vertical tankswith emergency relief ventingto limit pressures to 25 psi(gauge pressure of 17 kPa)

Approved inerting

systemb on the tank orapproved foam systemon vertical tanks

12 times value in Table22411(b)

12 times value in Table22411(b)

Protection for

exposuresb Value in Table 22411(b) Value in Table 22411(b)

None2 times value in Table22411(b)

Value in Table 22411(b)

Protected aboveground tank None12 times value in Table22411(b)

12 times value in Table22411(b)

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft (15 m)

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

dFor tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

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Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

For SI units 1 ft = 03 m 1 gal = 38 L

22412

Vertical tanks with weak roof-to-shell seams (see 2272) that store Class IIIA liquids shall be permitted to belocated at one-half the distances specified in Table 22411(a) provided the tanks are not within the samediked area as or within the drainage path of a tank storing a Class I or Class II liquid

22413

Tanks storing Class I Class II or Class IIIA stable liquids and operating at pressures that exceed a gaugepressure of 25 psi (17 kPa) or are equipped with emergency venting that will permit pressures to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22413 and Table 22411(b)

Table 22413 Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Permittedto Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or Can BeBuilt Upon Including the Opposite

Side of a Public Way

From Nearest Side of Any Public Wayor from Nearest Important Building on

the Same Property

Any typeProtection for

exposures1 12 times value in Table 22411(b) but notless than 25 ft

1 12 times value in Table 22411(b) but notless than 25 ft

None3 times value in Table 22411(b) but not beless than 50 ft

1 12 times value in Table 22411(b) but notless than 25 ft

For SI units 1 ft = 03 m

See definition 3346 Protection for Exposures

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22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

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Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

ResponseMessage

Ballot Results

This item has not been balloted

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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2 of 2 632013 1051 PM

Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1044 PM

Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

Ballot Results

This item has not been balloted

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bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

FLCTAN2012-08 Minutesdoc

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 2242 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 ndash Extra Hazard Group 2 The Technical Committee determined that this should be studied during the next document revision cycle

10 Under ldquoNew Businessrdquo 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 21715 Revise to require only one of the three options Section 224 Add statement that a multi-compartment tank is treated the same as a single

compartment tank for purposes of siting In 22734 should ldquoMrdquo 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 25131 conflicts with 278267 for Class II and Class III liquids Section 274 does it apply to all valves regardless of whether they connect to the top of the

tank or below the liquid level Paragraph 27441(1) What is the criteria for ldquoresistant to firerdquo Equivalent to steel Should not the provisions of 27823 through 2782121 apply to aboveground tanks as well as

underground tanks Subsection 2841 Clarify to indicate these are fixed unloading stations What is appropriate

distance for ldquodirect transfer from tank vehicle to storage tankrdquo 11 The NFPA 30 Second Draft meeting was tentatively scheduled for Thursday May 23 2013 in San

Antonio TX 12 The meeting adjourned at 545 PM

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

wwwnfpaorgdocument (ie wwwnfpaorg101) and click on the Next Edition tab

Process Stage

Process Step

Dates for TC

Dates forTC with

CC Public Input Closing Date 6222012 6222012

Final Date for TC First Draft Meeting 11302012 8312012

Public Input Posting of First Draft and TC Ballot 1182013 10122012

Stage Final date for Receipt of TC First Draft ballot 282013 1122012

(First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 2152013 1192012

Posting of First Draft for CC Meeting 11162012

Final date for CC First Draft Meeting 12282012

Posting of First Draft and CC Ballot 1182013

Final date for Receipt of CC First Draft ballot 282013

Final date for Receipt of CC First Draft ballot ‐ recirc 2152013

Post Final First Draft for Public Comment 2222013 2222013

Public Comment closing date 532013 532013

Final Date to Publish Notice of Consent Documents (Documents that received no Comments)

5102013 5102013

Appeal Closing Date for Consent Documents (Documents that received no Comments)

5242013 5242013

Final date for TC Second Draft Meeting 10182013 7122013

Comment Posting of Second Draft and TC Ballot 11292013 8232013

Stage Final date for Receipt of TC Second Draft ballot 12202013 9132013

(Second Final date for receipt of TC Second Draft ballot ‐ recirc 12272013 9202013

Draft) Posting of Second Draft for CC Meeting 9272013

Final date for CC Second Draft Meeting 1182013

Posting of Second Draft for CC Ballot 11292013

Final date for Receipt of CC Second Draft ballot 12202013

Final date for Receipt of CC Second Draft ballot ‐ recirc 12272013

Post Final Second Draft for NITMAM Review 132014 132014

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 272014 272014

Preparation Posting of Certified Amending Motions (CAMs) and Consent Documents

442014 442014

(amp Issuance) Appeal Closing Date for Consent Documents 4182014 4182014

SC Issuance Date for Consent Documents 592014 592014

Tech Session Association Meeting for Documents with CAMs 69‐122014 69‐122014

Appeals and Appeal Closing Date for Documents with CAMs 6242014 6242014

Issuance Council Issuance Date for Documents with CAMs 8142014 8142014

bbenedetti
Text Box
ATTACHMENT No A3

Committee Input No 16-NFPA 30-2012 [ Section No 21722 ]

21722 Security for Unsupervised Storage Tanks

Unsupervised isolated aboveground storage tanks shall be secured and shall be marked toidentify the fire hazards of the tank and the tankrsquos contents to the general public Where necessaryto protect the tank from tampering or trespassing the area where the tank is located shall besecured

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114315 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2011-H-1-6 made by the U S Chemical Safety andHazard Investigation Board the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for unsecured isolated storage tanks and issoliciting input for possible Technical Committee action at the second draft meeting

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 6112013 1011 AM

bbenedetti
Text Box
ATTACHMENT No A4

From D Havens 5‐17‐2013

Action by sub ndash retain current 21722 and add new appendix

Current Language 21722 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 tankrsquos 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 21722 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 tankrsquos 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 21722 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 tanks 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 A21722

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 Hiscott Jr David JTo Krumpolc Judith A Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Kraus Dick Paplawski

Robert Renkes Bob Wechsler DaveSubject RE NFPA 30 Group 1 sub team appendixDate Tuesday June 11 2013 91211 AM

My concern is that we are listing specific measures in the annex I realize that the annex is non ndashmandatory but sometimes these things creep into the code in later revisions We are also proposingto use several key ldquoundefinedrdquo words such as ldquo unsupervisedrdquo and ldquoremoterdquo and these terms willhave different meanings to different AHJrsquos and operators If we do not define these terms then thestandard dictionary definition applies and that will not provide guidance Each tank may pose adifferent hazard and to provide flexibility we should consider defaulting to allowing operators toconduct an assessment My proposal The committee is in general agreement with findings in the September 2011 CSB final reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents Additional securitymeasures should be developed based on fire and security risk assessments conducted by theoperator and petroleum industry practices Additional security measures could includeproviding a latched gate at the stairs leading to the tank platform and recommendations fromthe CSB report David Hiscott CSP CPPPhillips 66 TransportationEmergency Preparedness Response and Security3010 Briarpark Dr PWC - 7330-29Houston TX 77042Office - 832-765-1689Cell - 817-715-8951 NOTE New Contact information From Krumpolc Judith A [mailtoJudithKrumpolcbpcom] Sent Monday June 10 2013 405 PMTo Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Hiscott Jr David J Kraus DickPaplawski Robert Renkes Bob Wechsler DaveSubject [EXTERNAL]RE NFPA 30 Group 1 sub team appendix Bob and Task Group Members My concern with the Wechsler proposal A21722 is for the tanks that are remotelylocated isolated but not threatened by the public as much as in southern states such as inremote places in Alaska It is important to note that the biggest companies in the oil and gasindustry are working together with API to develop an annex for API RP 12R1 to include arequirement for a latched gate at the stairs leading to the platform for such remote tanks torespond to the same CSB report cited in the annex referenced by NFPA Should NFPAshould do similarly to avoid confusion I suggest we include a statement allowing the tankowner to make the decision when to add protective measures and give examples of additionalprotective measures The signage should be mandatory but the additional protection should

be added ldquowhen necessaryrdquo as determined by the operator when public access is a relevantthreat 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 reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents When public access isa relevant threat obvious protective measures should be implemented to help prevent thepublic from tampering with the unsupervised remotely located tanks by providing a latchedgate at the stairs leading to the platform In highly susceptible areas unsupervised remotelylocated tanks require additional protective measures which includes any or all the followingsecuring the hatches on the tanks restricting access to the entire facility or utilizinginherently safer tank design at these facilities I welcome any feedback

Judy KrumpolcTechnical Authority- Fire and Explosion AnalysisSafety + Operational Risk Deployed RampM150 W Warrenville Rd Naperville IL 60563Office 630 536-2804 Mobile 630 815-2098 Fax 630 420-4501Confidentiality Notice This electronic transmission and any documents sent with it constitute confidential inside or non-public information Ifyou are not the intended recipient or have received this communication in error please resend this communication to the sender and delete it fromyour computer system Any use or disclosure of the contents of this communication by anyone other than an intended recipient is strictlyprohibited and may be unlawful Thank you

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1008 AMTo Geyer Wayne Haines Steve Havens Dwight Hiscott Dave Kraus Dick Krumpolc Judith APaplawski Robert Renkes Bob Wechsler DaveSubject 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 [mailtodbwechslerattnet] Sent Monday June 10 2013 1027 AMTo Benedetti BobSubject Re NFPA 30 Group 1 sub team appendix BobI pulled up a copy of the final CSB Jan 2011 report on the tank incidents While there is a lotin this report I attempted rather than to repeat the information simply summarize it withinthe context of our existing statement Hopefully this accomplishes the sub team objective andstill 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 thesub team for additional comment and review Thanks

Committee Input No 11-NFPA 30-2012 [ Section No 224 ]

224 Location of Aboveground Storage Tanks

2241 Location with Respect to Property Lines Public Ways and Important Buildings

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bbenedetti
Text Box
ATTACHMENT No A5

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is not permitted to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22411(a) and Table22411(b) Where tank spacing is based on a weak roof-to-shell seam design the user shall presentevidence certifying such construction to the authority having jurisdiction upon request

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Not toExceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Waya

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Propertya

Floating roofProtection for

exposuresb12 times diameter of tank 16 times diameter of tank

NoneDiameter of tank but neednot exceed 175 ft

16 times diameter of tank

Vertical with weak roof-to-shellseam

Approved foam or

inerting systemc ontanks not exceeding

150 ft in diameterd

12 times diameter of tank 16 times diameter of tank

Protection for

exposuresb Diameter of tank 13 times diameter of tank

None2 times diameter of tank butneed not exceed 350 ft

13 times diameter of tank

Horizontal and vertical tankswith emergency relief ventingto limit pressures to 25 psi(gauge pressure of 17 kPa)

Approved inerting

systemb on the tank orapproved foam systemon vertical tanks

12 times value in Table22411(b)

12 times value in Table22411(b)

Protection for

exposuresb Value in Table 22411(b) Value in Table 22411(b)

None2 times value in Table22411(b)

Value in Table 22411(b)

Protected aboveground tank None12 times value in Table22411(b)

12 times value in Table22411(b)

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft (15 m)

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

dFor tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

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Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

For SI units 1 ft = 03 m 1 gal = 38 L

22412

Vertical tanks with weak roof-to-shell seams (see 2272) that store Class IIIA liquids shall be permitted to belocated at one-half the distances specified in Table 22411(a) provided the tanks are not within the samediked area as or within the drainage path of a tank storing a Class I or Class II liquid

22413

Tanks storing Class I Class II or Class IIIA stable liquids and operating at pressures that exceed a gaugepressure of 25 psi (17 kPa) or are equipped with emergency venting that will permit pressures to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22413 and Table 22411(b)

Table 22413 Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Permittedto Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or Can BeBuilt Upon Including the Opposite

Side of a Public Way

From Nearest Side of Any Public Wayor from Nearest Important Building on

the Same Property

Any typeProtection for

exposures1 12 times value in Table 22411(b) but notless than 25 ft

1 12 times value in Table 22411(b) but notless than 25 ft

None3 times value in Table 22411(b) but not beless than 50 ft

1 12 times value in Table 22411(b) but notless than 25 ft

For SI units 1 ft = 03 m

See definition 3346 Protection for Exposures

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22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

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Ballot Results

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Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

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Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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1 of 2 632013 1048 PM

Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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1 of 5 632013 1049 PM

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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2 of 2 632013 1051 PM

Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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1 of 2 632013 1054 PM

Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1044 PM

Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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1 of 2 632013 1046 PM

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

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bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

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

wwwnfpaorgdocument (ie wwwnfpaorg101) and click on the Next Edition tab

Process Stage

Process Step

Dates for TC

Dates forTC with

CC Public Input Closing Date 6222012 6222012

Final Date for TC First Draft Meeting 11302012 8312012

Public Input Posting of First Draft and TC Ballot 1182013 10122012

Stage Final date for Receipt of TC First Draft ballot 282013 1122012

(First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 2152013 1192012

Posting of First Draft for CC Meeting 11162012

Final date for CC First Draft Meeting 12282012

Posting of First Draft and CC Ballot 1182013

Final date for Receipt of CC First Draft ballot 282013

Final date for Receipt of CC First Draft ballot ‐ recirc 2152013

Post Final First Draft for Public Comment 2222013 2222013

Public Comment closing date 532013 532013

Final Date to Publish Notice of Consent Documents (Documents that received no Comments)

5102013 5102013

Appeal Closing Date for Consent Documents (Documents that received no Comments)

5242013 5242013

Final date for TC Second Draft Meeting 10182013 7122013

Comment Posting of Second Draft and TC Ballot 11292013 8232013

Stage Final date for Receipt of TC Second Draft ballot 12202013 9132013

(Second Final date for receipt of TC Second Draft ballot ‐ recirc 12272013 9202013

Draft) Posting of Second Draft for CC Meeting 9272013

Final date for CC Second Draft Meeting 1182013

Posting of Second Draft for CC Ballot 11292013

Final date for Receipt of CC Second Draft ballot 12202013

Final date for Receipt of CC Second Draft ballot ‐ recirc 12272013

Post Final Second Draft for NITMAM Review 132014 132014

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 272014 272014

Preparation Posting of Certified Amending Motions (CAMs) and Consent Documents

442014 442014

(amp Issuance) Appeal Closing Date for Consent Documents 4182014 4182014

SC Issuance Date for Consent Documents 592014 592014

Tech Session Association Meeting for Documents with CAMs 69‐122014 69‐122014

Appeals and Appeal Closing Date for Documents with CAMs 6242014 6242014

Issuance Council Issuance Date for Documents with CAMs 8142014 8142014

bbenedetti
Text Box
ATTACHMENT No A3

Committee Input No 16-NFPA 30-2012 [ Section No 21722 ]

21722 Security for Unsupervised Storage Tanks

Unsupervised isolated aboveground storage tanks shall be secured and shall be marked toidentify the fire hazards of the tank and the tankrsquos contents to the general public Where necessaryto protect the tank from tampering or trespassing the area where the tank is located shall besecured

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114315 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2011-H-1-6 made by the U S Chemical Safety andHazard Investigation Board the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for unsecured isolated storage tanks and issoliciting input for possible Technical Committee action at the second draft meeting

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Ballot Results

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1 of 1 6112013 1011 AM

bbenedetti
Text Box
ATTACHMENT No A4

From D Havens 5‐17‐2013

Action by sub ndash retain current 21722 and add new appendix

Current Language 21722 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 tankrsquos 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 21722 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 tankrsquos 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 21722 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 tanks 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 A21722

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 Hiscott Jr David JTo Krumpolc Judith A Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Kraus Dick Paplawski

Robert Renkes Bob Wechsler DaveSubject RE NFPA 30 Group 1 sub team appendixDate Tuesday June 11 2013 91211 AM

My concern is that we are listing specific measures in the annex I realize that the annex is non ndashmandatory but sometimes these things creep into the code in later revisions We are also proposingto use several key ldquoundefinedrdquo words such as ldquo unsupervisedrdquo and ldquoremoterdquo and these terms willhave different meanings to different AHJrsquos and operators If we do not define these terms then thestandard dictionary definition applies and that will not provide guidance Each tank may pose adifferent hazard and to provide flexibility we should consider defaulting to allowing operators toconduct an assessment My proposal The committee is in general agreement with findings in the September 2011 CSB final reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents Additional securitymeasures should be developed based on fire and security risk assessments conducted by theoperator and petroleum industry practices Additional security measures could includeproviding a latched gate at the stairs leading to the tank platform and recommendations fromthe CSB report David Hiscott CSP CPPPhillips 66 TransportationEmergency Preparedness Response and Security3010 Briarpark Dr PWC - 7330-29Houston TX 77042Office - 832-765-1689Cell - 817-715-8951 NOTE New Contact information From Krumpolc Judith A [mailtoJudithKrumpolcbpcom] Sent Monday June 10 2013 405 PMTo Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Hiscott Jr David J Kraus DickPaplawski Robert Renkes Bob Wechsler DaveSubject [EXTERNAL]RE NFPA 30 Group 1 sub team appendix Bob and Task Group Members My concern with the Wechsler proposal A21722 is for the tanks that are remotelylocated isolated but not threatened by the public as much as in southern states such as inremote places in Alaska It is important to note that the biggest companies in the oil and gasindustry are working together with API to develop an annex for API RP 12R1 to include arequirement for a latched gate at the stairs leading to the platform for such remote tanks torespond to the same CSB report cited in the annex referenced by NFPA Should NFPAshould do similarly to avoid confusion I suggest we include a statement allowing the tankowner to make the decision when to add protective measures and give examples of additionalprotective measures The signage should be mandatory but the additional protection should

be added ldquowhen necessaryrdquo as determined by the operator when public access is a relevantthreat 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 reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents When public access isa relevant threat obvious protective measures should be implemented to help prevent thepublic from tampering with the unsupervised remotely located tanks by providing a latchedgate at the stairs leading to the platform In highly susceptible areas unsupervised remotelylocated tanks require additional protective measures which includes any or all the followingsecuring the hatches on the tanks restricting access to the entire facility or utilizinginherently safer tank design at these facilities I welcome any feedback

Judy KrumpolcTechnical Authority- Fire and Explosion AnalysisSafety + Operational Risk Deployed RampM150 W Warrenville Rd Naperville IL 60563Office 630 536-2804 Mobile 630 815-2098 Fax 630 420-4501Confidentiality Notice This electronic transmission and any documents sent with it constitute confidential inside or non-public information Ifyou are not the intended recipient or have received this communication in error please resend this communication to the sender and delete it fromyour computer system Any use or disclosure of the contents of this communication by anyone other than an intended recipient is strictlyprohibited and may be unlawful Thank you

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1008 AMTo Geyer Wayne Haines Steve Havens Dwight Hiscott Dave Kraus Dick Krumpolc Judith APaplawski Robert Renkes Bob Wechsler DaveSubject 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 [mailtodbwechslerattnet] Sent Monday June 10 2013 1027 AMTo Benedetti BobSubject Re NFPA 30 Group 1 sub team appendix BobI pulled up a copy of the final CSB Jan 2011 report on the tank incidents While there is a lotin this report I attempted rather than to repeat the information simply summarize it withinthe context of our existing statement Hopefully this accomplishes the sub team objective andstill 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 thesub team for additional comment and review Thanks

Committee Input No 11-NFPA 30-2012 [ Section No 224 ]

224 Location of Aboveground Storage Tanks

2241 Location with Respect to Property Lines Public Ways and Important Buildings

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bbenedetti
Text Box
ATTACHMENT No A5

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is not permitted to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22411(a) and Table22411(b) Where tank spacing is based on a weak roof-to-shell seam design the user shall presentevidence certifying such construction to the authority having jurisdiction upon request

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Not toExceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Waya

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Propertya

Floating roofProtection for

exposuresb12 times diameter of tank 16 times diameter of tank

NoneDiameter of tank but neednot exceed 175 ft

16 times diameter of tank

Vertical with weak roof-to-shellseam

Approved foam or

inerting systemc ontanks not exceeding

150 ft in diameterd

12 times diameter of tank 16 times diameter of tank

Protection for

exposuresb Diameter of tank 13 times diameter of tank

None2 times diameter of tank butneed not exceed 350 ft

13 times diameter of tank

Horizontal and vertical tankswith emergency relief ventingto limit pressures to 25 psi(gauge pressure of 17 kPa)

Approved inerting

systemb on the tank orapproved foam systemon vertical tanks

12 times value in Table22411(b)

12 times value in Table22411(b)

Protection for

exposuresb Value in Table 22411(b) Value in Table 22411(b)

None2 times value in Table22411(b)

Value in Table 22411(b)

Protected aboveground tank None12 times value in Table22411(b)

12 times value in Table22411(b)

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft (15 m)

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

dFor tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

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Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

For SI units 1 ft = 03 m 1 gal = 38 L

22412

Vertical tanks with weak roof-to-shell seams (see 2272) that store Class IIIA liquids shall be permitted to belocated at one-half the distances specified in Table 22411(a) provided the tanks are not within the samediked area as or within the drainage path of a tank storing a Class I or Class II liquid

22413

Tanks storing Class I Class II or Class IIIA stable liquids and operating at pressures that exceed a gaugepressure of 25 psi (17 kPa) or are equipped with emergency venting that will permit pressures to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22413 and Table 22411(b)

Table 22413 Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Permittedto Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or Can BeBuilt Upon Including the Opposite

Side of a Public Way

From Nearest Side of Any Public Wayor from Nearest Important Building on

the Same Property

Any typeProtection for

exposures1 12 times value in Table 22411(b) but notless than 25 ft

1 12 times value in Table 22411(b) but notless than 25 ft

None3 times value in Table 22411(b) but not beless than 50 ft

1 12 times value in Table 22411(b) but notless than 25 ft

For SI units 1 ft = 03 m

See definition 3346 Protection for Exposures

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22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

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Ballot Results

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Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

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Ballot Results

This item has not been balloted

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Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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1 of 2 632013 1048 PM

Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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1 of 5 632013 1049 PM

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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2 of 2 632013 1051 PM

Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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1 of 2 632013 1054 PM

Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1044 PM

Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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1 of 2 632013 1046 PM

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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ATTACHMENT No A9

Committee Input No 16-NFPA 30-2012 [ Section No 21722 ]

21722 Security for Unsupervised Storage Tanks

Unsupervised isolated aboveground storage tanks shall be secured and shall be marked toidentify the fire hazards of the tank and the tankrsquos contents to the general public Where necessaryto protect the tank from tampering or trespassing the area where the tank is located shall besecured

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114315 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2011-H-1-6 made by the U S Chemical Safety andHazard Investigation Board the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for unsecured isolated storage tanks and issoliciting input for possible Technical Committee action at the second draft meeting

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1 of 1 6112013 1011 AM

bbenedetti
Text Box
ATTACHMENT No A4

From D Havens 5‐17‐2013

Action by sub ndash retain current 21722 and add new appendix

Current Language 21722 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 tankrsquos 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 21722 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 tankrsquos 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 21722 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 tanks 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 A21722

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 Hiscott Jr David JTo Krumpolc Judith A Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Kraus Dick Paplawski

Robert Renkes Bob Wechsler DaveSubject RE NFPA 30 Group 1 sub team appendixDate Tuesday June 11 2013 91211 AM

My concern is that we are listing specific measures in the annex I realize that the annex is non ndashmandatory but sometimes these things creep into the code in later revisions We are also proposingto use several key ldquoundefinedrdquo words such as ldquo unsupervisedrdquo and ldquoremoterdquo and these terms willhave different meanings to different AHJrsquos and operators If we do not define these terms then thestandard dictionary definition applies and that will not provide guidance Each tank may pose adifferent hazard and to provide flexibility we should consider defaulting to allowing operators toconduct an assessment My proposal The committee is in general agreement with findings in the September 2011 CSB final reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents Additional securitymeasures should be developed based on fire and security risk assessments conducted by theoperator and petroleum industry practices Additional security measures could includeproviding a latched gate at the stairs leading to the tank platform and recommendations fromthe CSB report David Hiscott CSP CPPPhillips 66 TransportationEmergency Preparedness Response and Security3010 Briarpark Dr PWC - 7330-29Houston TX 77042Office - 832-765-1689Cell - 817-715-8951 NOTE New Contact information From Krumpolc Judith A [mailtoJudithKrumpolcbpcom] Sent Monday June 10 2013 405 PMTo Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Hiscott Jr David J Kraus DickPaplawski Robert Renkes Bob Wechsler DaveSubject [EXTERNAL]RE NFPA 30 Group 1 sub team appendix Bob and Task Group Members My concern with the Wechsler proposal A21722 is for the tanks that are remotelylocated isolated but not threatened by the public as much as in southern states such as inremote places in Alaska It is important to note that the biggest companies in the oil and gasindustry are working together with API to develop an annex for API RP 12R1 to include arequirement for a latched gate at the stairs leading to the platform for such remote tanks torespond to the same CSB report cited in the annex referenced by NFPA Should NFPAshould do similarly to avoid confusion I suggest we include a statement allowing the tankowner to make the decision when to add protective measures and give examples of additionalprotective measures The signage should be mandatory but the additional protection should

be added ldquowhen necessaryrdquo as determined by the operator when public access is a relevantthreat 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 reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents When public access isa relevant threat obvious protective measures should be implemented to help prevent thepublic from tampering with the unsupervised remotely located tanks by providing a latchedgate at the stairs leading to the platform In highly susceptible areas unsupervised remotelylocated tanks require additional protective measures which includes any or all the followingsecuring the hatches on the tanks restricting access to the entire facility or utilizinginherently safer tank design at these facilities I welcome any feedback

Judy KrumpolcTechnical Authority- Fire and Explosion AnalysisSafety + Operational Risk Deployed RampM150 W Warrenville Rd Naperville IL 60563Office 630 536-2804 Mobile 630 815-2098 Fax 630 420-4501Confidentiality Notice This electronic transmission and any documents sent with it constitute confidential inside or non-public information Ifyou are not the intended recipient or have received this communication in error please resend this communication to the sender and delete it fromyour computer system Any use or disclosure of the contents of this communication by anyone other than an intended recipient is strictlyprohibited and may be unlawful Thank you

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1008 AMTo Geyer Wayne Haines Steve Havens Dwight Hiscott Dave Kraus Dick Krumpolc Judith APaplawski Robert Renkes Bob Wechsler DaveSubject 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 [mailtodbwechslerattnet] Sent Monday June 10 2013 1027 AMTo Benedetti BobSubject Re NFPA 30 Group 1 sub team appendix BobI pulled up a copy of the final CSB Jan 2011 report on the tank incidents While there is a lotin this report I attempted rather than to repeat the information simply summarize it withinthe context of our existing statement Hopefully this accomplishes the sub team objective andstill 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 thesub team for additional comment and review Thanks

Committee Input No 11-NFPA 30-2012 [ Section No 224 ]

224 Location of Aboveground Storage Tanks

2241 Location with Respect to Property Lines Public Ways and Important Buildings

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bbenedetti
Text Box
ATTACHMENT No A5

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is not permitted to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22411(a) and Table22411(b) Where tank spacing is based on a weak roof-to-shell seam design the user shall presentevidence certifying such construction to the authority having jurisdiction upon request

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Not toExceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Waya

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Propertya

Floating roofProtection for

exposuresb12 times diameter of tank 16 times diameter of tank

NoneDiameter of tank but neednot exceed 175 ft

16 times diameter of tank

Vertical with weak roof-to-shellseam

Approved foam or

inerting systemc ontanks not exceeding

150 ft in diameterd

12 times diameter of tank 16 times diameter of tank

Protection for

exposuresb Diameter of tank 13 times diameter of tank

None2 times diameter of tank butneed not exceed 350 ft

13 times diameter of tank

Horizontal and vertical tankswith emergency relief ventingto limit pressures to 25 psi(gauge pressure of 17 kPa)

Approved inerting

systemb on the tank orapproved foam systemon vertical tanks

12 times value in Table22411(b)

12 times value in Table22411(b)

Protection for

exposuresb Value in Table 22411(b) Value in Table 22411(b)

None2 times value in Table22411(b)

Value in Table 22411(b)

Protected aboveground tank None12 times value in Table22411(b)

12 times value in Table22411(b)

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft (15 m)

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

dFor tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

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Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

For SI units 1 ft = 03 m 1 gal = 38 L

22412

Vertical tanks with weak roof-to-shell seams (see 2272) that store Class IIIA liquids shall be permitted to belocated at one-half the distances specified in Table 22411(a) provided the tanks are not within the samediked area as or within the drainage path of a tank storing a Class I or Class II liquid

22413

Tanks storing Class I Class II or Class IIIA stable liquids and operating at pressures that exceed a gaugepressure of 25 psi (17 kPa) or are equipped with emergency venting that will permit pressures to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22413 and Table 22411(b)

Table 22413 Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Permittedto Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or Can BeBuilt Upon Including the Opposite

Side of a Public Way

From Nearest Side of Any Public Wayor from Nearest Important Building on

the Same Property

Any typeProtection for

exposures1 12 times value in Table 22411(b) but notless than 25 ft

1 12 times value in Table 22411(b) but notless than 25 ft

None3 times value in Table 22411(b) but not beless than 50 ft

1 12 times value in Table 22411(b) but notless than 25 ft

For SI units 1 ft = 03 m

See definition 3346 Protection for Exposures

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4 of 8 632013 1037 PM

22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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5 of 8 632013 1037 PM

22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

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Ballot Results

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8 of 8 632013 1037 PM

Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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1 of 5 632013 1039 PM

Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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2 of 5 632013 1039 PM

22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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3 of 5 632013 1039 PM

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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1 of 2 632013 1048 PM

Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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1 of 5 632013 1049 PM

22411

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2 of 5 632013 1049 PM

Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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3 of 5 632013 1049 PM

Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

Ballot Results

This item has not been balloted

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bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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ATTACHMENT No A9

From D Havens 5‐17‐2013

Action by sub ndash retain current 21722 and add new appendix

Current Language 21722 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 tankrsquos 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 21722 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 tankrsquos 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 21722 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 tanks 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 A21722

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 Hiscott Jr David JTo Krumpolc Judith A Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Kraus Dick Paplawski

Robert Renkes Bob Wechsler DaveSubject RE NFPA 30 Group 1 sub team appendixDate Tuesday June 11 2013 91211 AM

My concern is that we are listing specific measures in the annex I realize that the annex is non ndashmandatory but sometimes these things creep into the code in later revisions We are also proposingto use several key ldquoundefinedrdquo words such as ldquo unsupervisedrdquo and ldquoremoterdquo and these terms willhave different meanings to different AHJrsquos and operators If we do not define these terms then thestandard dictionary definition applies and that will not provide guidance Each tank may pose adifferent hazard and to provide flexibility we should consider defaulting to allowing operators toconduct an assessment My proposal The committee is in general agreement with findings in the September 2011 CSB final reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents Additional securitymeasures should be developed based on fire and security risk assessments conducted by theoperator and petroleum industry practices Additional security measures could includeproviding a latched gate at the stairs leading to the tank platform and recommendations fromthe CSB report David Hiscott CSP CPPPhillips 66 TransportationEmergency Preparedness Response and Security3010 Briarpark Dr PWC - 7330-29Houston TX 77042Office - 832-765-1689Cell - 817-715-8951 NOTE New Contact information From Krumpolc Judith A [mailtoJudithKrumpolcbpcom] Sent Monday June 10 2013 405 PMTo Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Hiscott Jr David J Kraus DickPaplawski Robert Renkes Bob Wechsler DaveSubject [EXTERNAL]RE NFPA 30 Group 1 sub team appendix Bob and Task Group Members My concern with the Wechsler proposal A21722 is for the tanks that are remotelylocated isolated but not threatened by the public as much as in southern states such as inremote places in Alaska It is important to note that the biggest companies in the oil and gasindustry are working together with API to develop an annex for API RP 12R1 to include arequirement for a latched gate at the stairs leading to the platform for such remote tanks torespond to the same CSB report cited in the annex referenced by NFPA Should NFPAshould do similarly to avoid confusion I suggest we include a statement allowing the tankowner to make the decision when to add protective measures and give examples of additionalprotective measures The signage should be mandatory but the additional protection should

be added ldquowhen necessaryrdquo as determined by the operator when public access is a relevantthreat 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 reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents When public access isa relevant threat obvious protective measures should be implemented to help prevent thepublic from tampering with the unsupervised remotely located tanks by providing a latchedgate at the stairs leading to the platform In highly susceptible areas unsupervised remotelylocated tanks require additional protective measures which includes any or all the followingsecuring the hatches on the tanks restricting access to the entire facility or utilizinginherently safer tank design at these facilities I welcome any feedback

Judy KrumpolcTechnical Authority- Fire and Explosion AnalysisSafety + Operational Risk Deployed RampM150 W Warrenville Rd Naperville IL 60563Office 630 536-2804 Mobile 630 815-2098 Fax 630 420-4501Confidentiality Notice This electronic transmission and any documents sent with it constitute confidential inside or non-public information Ifyou are not the intended recipient or have received this communication in error please resend this communication to the sender and delete it fromyour computer system Any use or disclosure of the contents of this communication by anyone other than an intended recipient is strictlyprohibited and may be unlawful Thank you

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1008 AMTo Geyer Wayne Haines Steve Havens Dwight Hiscott Dave Kraus Dick Krumpolc Judith APaplawski Robert Renkes Bob Wechsler DaveSubject 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 [mailtodbwechslerattnet] Sent Monday June 10 2013 1027 AMTo Benedetti BobSubject Re NFPA 30 Group 1 sub team appendix BobI pulled up a copy of the final CSB Jan 2011 report on the tank incidents While there is a lotin this report I attempted rather than to repeat the information simply summarize it withinthe context of our existing statement Hopefully this accomplishes the sub team objective andstill 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 thesub team for additional comment and review Thanks

Committee Input No 11-NFPA 30-2012 [ Section No 224 ]

224 Location of Aboveground Storage Tanks

2241 Location with Respect to Property Lines Public Ways and Important Buildings

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ATTACHMENT No A5

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is not permitted to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22411(a) and Table22411(b) Where tank spacing is based on a weak roof-to-shell seam design the user shall presentevidence certifying such construction to the authority having jurisdiction upon request

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Not toExceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Waya

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Propertya

Floating roofProtection for

exposuresb12 times diameter of tank 16 times diameter of tank

NoneDiameter of tank but neednot exceed 175 ft

16 times diameter of tank

Vertical with weak roof-to-shellseam

Approved foam or

inerting systemc ontanks not exceeding

150 ft in diameterd

12 times diameter of tank 16 times diameter of tank

Protection for

exposuresb Diameter of tank 13 times diameter of tank

None2 times diameter of tank butneed not exceed 350 ft

13 times diameter of tank

Horizontal and vertical tankswith emergency relief ventingto limit pressures to 25 psi(gauge pressure of 17 kPa)

Approved inerting

systemb on the tank orapproved foam systemon vertical tanks

12 times value in Table22411(b)

12 times value in Table22411(b)

Protection for

exposuresb Value in Table 22411(b) Value in Table 22411(b)

None2 times value in Table22411(b)

Value in Table 22411(b)

Protected aboveground tank None12 times value in Table22411(b)

12 times value in Table22411(b)

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft (15 m)

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

dFor tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

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Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

For SI units 1 ft = 03 m 1 gal = 38 L

22412

Vertical tanks with weak roof-to-shell seams (see 2272) that store Class IIIA liquids shall be permitted to belocated at one-half the distances specified in Table 22411(a) provided the tanks are not within the samediked area as or within the drainage path of a tank storing a Class I or Class II liquid

22413

Tanks storing Class I Class II or Class IIIA stable liquids and operating at pressures that exceed a gaugepressure of 25 psi (17 kPa) or are equipped with emergency venting that will permit pressures to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22413 and Table 22411(b)

Table 22413 Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Permittedto Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or Can BeBuilt Upon Including the Opposite

Side of a Public Way

From Nearest Side of Any Public Wayor from Nearest Important Building on

the Same Property

Any typeProtection for

exposures1 12 times value in Table 22411(b) but notless than 25 ft

1 12 times value in Table 22411(b) but notless than 25 ft

None3 times value in Table 22411(b) but not beless than 50 ft

1 12 times value in Table 22411(b) but notless than 25 ft

For SI units 1 ft = 03 m

See definition 3346 Protection for Exposures

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22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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6 of 8 632013 1037 PM

22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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7 of 8 632013 1037 PM

224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

ResponseMessage

Ballot Results

This item has not been balloted

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8 of 8 632013 1037 PM

Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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1 of 5 632013 1039 PM

Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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3 of 5 632013 1039 PM

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

ResponseMessage

Ballot Results

This item has not been balloted

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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1 of 2 632013 1048 PM

Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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3 of 5 632013 1049 PM

Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

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bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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bbenedetti
Text Box
ATTACHMENT No A9

From Hiscott Jr David JTo Krumpolc Judith A Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Kraus Dick Paplawski

Robert Renkes Bob Wechsler DaveSubject RE NFPA 30 Group 1 sub team appendixDate Tuesday June 11 2013 91211 AM

My concern is that we are listing specific measures in the annex I realize that the annex is non ndashmandatory but sometimes these things creep into the code in later revisions We are also proposingto use several key ldquoundefinedrdquo words such as ldquo unsupervisedrdquo and ldquoremoterdquo and these terms willhave different meanings to different AHJrsquos and operators If we do not define these terms then thestandard dictionary definition applies and that will not provide guidance Each tank may pose adifferent hazard and to provide flexibility we should consider defaulting to allowing operators toconduct an assessment My proposal The committee is in general agreement with findings in the September 2011 CSB final reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents Additional securitymeasures should be developed based on fire and security risk assessments conducted by theoperator and petroleum industry practices Additional security measures could includeproviding a latched gate at the stairs leading to the tank platform and recommendations fromthe CSB report David Hiscott CSP CPPPhillips 66 TransportationEmergency Preparedness Response and Security3010 Briarpark Dr PWC - 7330-29Houston TX 77042Office - 832-765-1689Cell - 817-715-8951 NOTE New Contact information From Krumpolc Judith A [mailtoJudithKrumpolcbpcom] Sent Monday June 10 2013 405 PMTo Benedetti Bob Geyer Wayne Haines Steve Havens Dwight Hiscott Jr David J Kraus DickPaplawski Robert Renkes Bob Wechsler DaveSubject [EXTERNAL]RE NFPA 30 Group 1 sub team appendix Bob and Task Group Members My concern with the Wechsler proposal A21722 is for the tanks that are remotelylocated isolated but not threatened by the public as much as in southern states such as inremote places in Alaska It is important to note that the biggest companies in the oil and gasindustry are working together with API to develop an annex for API RP 12R1 to include arequirement for a latched gate at the stairs leading to the platform for such remote tanks torespond to the same CSB report cited in the annex referenced by NFPA Should NFPAshould do similarly to avoid confusion I suggest we include a statement allowing the tankowner to make the decision when to add protective measures and give examples of additionalprotective measures The signage should be mandatory but the additional protection should

be added ldquowhen necessaryrdquo as determined by the operator when public access is a relevantthreat 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 reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents When public access isa relevant threat obvious protective measures should be implemented to help prevent thepublic from tampering with the unsupervised remotely located tanks by providing a latchedgate at the stairs leading to the platform In highly susceptible areas unsupervised remotelylocated tanks require additional protective measures which includes any or all the followingsecuring the hatches on the tanks restricting access to the entire facility or utilizinginherently safer tank design at these facilities I welcome any feedback

Judy KrumpolcTechnical Authority- Fire and Explosion AnalysisSafety + Operational Risk Deployed RampM150 W Warrenville Rd Naperville IL 60563Office 630 536-2804 Mobile 630 815-2098 Fax 630 420-4501Confidentiality Notice This electronic transmission and any documents sent with it constitute confidential inside or non-public information Ifyou are not the intended recipient or have received this communication in error please resend this communication to the sender and delete it fromyour computer system Any use or disclosure of the contents of this communication by anyone other than an intended recipient is strictlyprohibited and may be unlawful Thank you

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1008 AMTo Geyer Wayne Haines Steve Havens Dwight Hiscott Dave Kraus Dick Krumpolc Judith APaplawski Robert Renkes Bob Wechsler DaveSubject 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 [mailtodbwechslerattnet] Sent Monday June 10 2013 1027 AMTo Benedetti BobSubject Re NFPA 30 Group 1 sub team appendix BobI pulled up a copy of the final CSB Jan 2011 report on the tank incidents While there is a lotin this report I attempted rather than to repeat the information simply summarize it withinthe context of our existing statement Hopefully this accomplishes the sub team objective andstill 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 thesub team for additional comment and review Thanks

Committee Input No 11-NFPA 30-2012 [ Section No 224 ]

224 Location of Aboveground Storage Tanks

2241 Location with Respect to Property Lines Public Ways and Important Buildings

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bbenedetti
Text Box
ATTACHMENT No A5

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is not permitted to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22411(a) and Table22411(b) Where tank spacing is based on a weak roof-to-shell seam design the user shall presentevidence certifying such construction to the authority having jurisdiction upon request

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Not toExceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Waya

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Propertya

Floating roofProtection for

exposuresb12 times diameter of tank 16 times diameter of tank

NoneDiameter of tank but neednot exceed 175 ft

16 times diameter of tank

Vertical with weak roof-to-shellseam

Approved foam or

inerting systemc ontanks not exceeding

150 ft in diameterd

12 times diameter of tank 16 times diameter of tank

Protection for

exposuresb Diameter of tank 13 times diameter of tank

None2 times diameter of tank butneed not exceed 350 ft

13 times diameter of tank

Horizontal and vertical tankswith emergency relief ventingto limit pressures to 25 psi(gauge pressure of 17 kPa)

Approved inerting

systemb on the tank orapproved foam systemon vertical tanks

12 times value in Table22411(b)

12 times value in Table22411(b)

Protection for

exposuresb Value in Table 22411(b) Value in Table 22411(b)

None2 times value in Table22411(b)

Value in Table 22411(b)

Protected aboveground tank None12 times value in Table22411(b)

12 times value in Table22411(b)

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft (15 m)

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

dFor tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

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Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

For SI units 1 ft = 03 m 1 gal = 38 L

22412

Vertical tanks with weak roof-to-shell seams (see 2272) that store Class IIIA liquids shall be permitted to belocated at one-half the distances specified in Table 22411(a) provided the tanks are not within the samediked area as or within the drainage path of a tank storing a Class I or Class II liquid

22413

Tanks storing Class I Class II or Class IIIA stable liquids and operating at pressures that exceed a gaugepressure of 25 psi (17 kPa) or are equipped with emergency venting that will permit pressures to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22413 and Table 22411(b)

Table 22413 Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Permittedto Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or Can BeBuilt Upon Including the Opposite

Side of a Public Way

From Nearest Side of Any Public Wayor from Nearest Important Building on

the Same Property

Any typeProtection for

exposures1 12 times value in Table 22411(b) but notless than 25 ft

1 12 times value in Table 22411(b) but notless than 25 ft

None3 times value in Table 22411(b) but not beless than 50 ft

1 12 times value in Table 22411(b) but notless than 25 ft

For SI units 1 ft = 03 m

See definition 3346 Protection for Exposures

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22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

ResponseMessage

Ballot Results

This item has not been balloted

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Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

ResponseMessage

Ballot Results

This item has not been balloted

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Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

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bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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bbenedetti
Text Box
ATTACHMENT No A9

be added ldquowhen necessaryrdquo as determined by the operator when public access is a relevantthreat 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 reportthat three explosions in Mississippi Oklahoma and Texas in unsupervised remotely isolatedabove ground storage tanks Storage tanks should be protected from tampering or trespassingby warning signage that identify the fire hazards of the tank contents When public access isa relevant threat obvious protective measures should be implemented to help prevent thepublic from tampering with the unsupervised remotely located tanks by providing a latchedgate at the stairs leading to the platform In highly susceptible areas unsupervised remotelylocated tanks require additional protective measures which includes any or all the followingsecuring the hatches on the tanks restricting access to the entire facility or utilizinginherently safer tank design at these facilities I welcome any feedback

Judy KrumpolcTechnical Authority- Fire and Explosion AnalysisSafety + Operational Risk Deployed RampM150 W Warrenville Rd Naperville IL 60563Office 630 536-2804 Mobile 630 815-2098 Fax 630 420-4501Confidentiality Notice This electronic transmission and any documents sent with it constitute confidential inside or non-public information Ifyou are not the intended recipient or have received this communication in error please resend this communication to the sender and delete it fromyour computer system Any use or disclosure of the contents of this communication by anyone other than an intended recipient is strictlyprohibited and may be unlawful Thank you

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1008 AMTo Geyer Wayne Haines Steve Havens Dwight Hiscott Dave Kraus Dick Krumpolc Judith APaplawski Robert Renkes Bob Wechsler DaveSubject 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 [mailtodbwechslerattnet] Sent Monday June 10 2013 1027 AMTo Benedetti BobSubject Re NFPA 30 Group 1 sub team appendix BobI pulled up a copy of the final CSB Jan 2011 report on the tank incidents While there is a lotin this report I attempted rather than to repeat the information simply summarize it withinthe context of our existing statement Hopefully this accomplishes the sub team objective andstill 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 thesub team for additional comment and review Thanks

Committee Input No 11-NFPA 30-2012 [ Section No 224 ]

224 Location of Aboveground Storage Tanks

2241 Location with Respect to Property Lines Public Ways and Important Buildings

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bbenedetti
Text Box
ATTACHMENT No A5

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is not permitted to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22411(a) and Table22411(b) Where tank spacing is based on a weak roof-to-shell seam design the user shall presentevidence certifying such construction to the authority having jurisdiction upon request

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Not toExceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Waya

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Propertya

Floating roofProtection for

exposuresb12 times diameter of tank 16 times diameter of tank

NoneDiameter of tank but neednot exceed 175 ft

16 times diameter of tank

Vertical with weak roof-to-shellseam

Approved foam or

inerting systemc ontanks not exceeding

150 ft in diameterd

12 times diameter of tank 16 times diameter of tank

Protection for

exposuresb Diameter of tank 13 times diameter of tank

None2 times diameter of tank butneed not exceed 350 ft

13 times diameter of tank

Horizontal and vertical tankswith emergency relief ventingto limit pressures to 25 psi(gauge pressure of 17 kPa)

Approved inerting

systemb on the tank orapproved foam systemon vertical tanks

12 times value in Table22411(b)

12 times value in Table22411(b)

Protection for

exposuresb Value in Table 22411(b) Value in Table 22411(b)

None2 times value in Table22411(b)

Value in Table 22411(b)

Protected aboveground tank None12 times value in Table22411(b)

12 times value in Table22411(b)

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft (15 m)

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

dFor tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

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Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

For SI units 1 ft = 03 m 1 gal = 38 L

22412

Vertical tanks with weak roof-to-shell seams (see 2272) that store Class IIIA liquids shall be permitted to belocated at one-half the distances specified in Table 22411(a) provided the tanks are not within the samediked area as or within the drainage path of a tank storing a Class I or Class II liquid

22413

Tanks storing Class I Class II or Class IIIA stable liquids and operating at pressures that exceed a gaugepressure of 25 psi (17 kPa) or are equipped with emergency venting that will permit pressures to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22413 and Table 22411(b)

Table 22413 Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Permittedto Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or Can BeBuilt Upon Including the Opposite

Side of a Public Way

From Nearest Side of Any Public Wayor from Nearest Important Building on

the Same Property

Any typeProtection for

exposures1 12 times value in Table 22411(b) but notless than 25 ft

1 12 times value in Table 22411(b) but notless than 25 ft

None3 times value in Table 22411(b) but not beless than 50 ft

1 12 times value in Table 22411(b) but notless than 25 ft

For SI units 1 ft = 03 m

See definition 3346 Protection for Exposures

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22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

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Ballot Results

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8 of 8 632013 1037 PM

Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

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Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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1 of 2 632013 1048 PM

Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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1 of 5 632013 1049 PM

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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2 of 2 632013 1051 PM

Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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1 of 2 632013 1054 PM

Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1044 PM

Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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1 of 2 632013 1046 PM

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

Ballot Results

This item has not been balloted

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bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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bbenedetti
Text Box
ATTACHMENT No A9

Committee Input No 11-NFPA 30-2012 [ Section No 224 ]

224 Location of Aboveground Storage Tanks

2241 Location with Respect to Property Lines Public Ways and Important Buildings

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bbenedetti
Text Box
ATTACHMENT No A5

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is not permitted to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22411(a) and Table22411(b) Where tank spacing is based on a weak roof-to-shell seam design the user shall presentevidence certifying such construction to the authority having jurisdiction upon request

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Not toExceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Waya

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Propertya

Floating roofProtection for

exposuresb12 times diameter of tank 16 times diameter of tank

NoneDiameter of tank but neednot exceed 175 ft

16 times diameter of tank

Vertical with weak roof-to-shellseam

Approved foam or

inerting systemc ontanks not exceeding

150 ft in diameterd

12 times diameter of tank 16 times diameter of tank

Protection for

exposuresb Diameter of tank 13 times diameter of tank

None2 times diameter of tank butneed not exceed 350 ft

13 times diameter of tank

Horizontal and vertical tankswith emergency relief ventingto limit pressures to 25 psi(gauge pressure of 17 kPa)

Approved inerting

systemb on the tank orapproved foam systemon vertical tanks

12 times value in Table22411(b)

12 times value in Table22411(b)

Protection for

exposuresb Value in Table 22411(b) Value in Table 22411(b)

None2 times value in Table22411(b)

Value in Table 22411(b)

Protected aboveground tank None12 times value in Table22411(b)

12 times value in Table22411(b)

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft (15 m)

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

dFor tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

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Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

For SI units 1 ft = 03 m 1 gal = 38 L

22412

Vertical tanks with weak roof-to-shell seams (see 2272) that store Class IIIA liquids shall be permitted to belocated at one-half the distances specified in Table 22411(a) provided the tanks are not within the samediked area as or within the drainage path of a tank storing a Class I or Class II liquid

22413

Tanks storing Class I Class II or Class IIIA stable liquids and operating at pressures that exceed a gaugepressure of 25 psi (17 kPa) or are equipped with emergency venting that will permit pressures to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22413 and Table 22411(b)

Table 22413 Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Permittedto Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or Can BeBuilt Upon Including the Opposite

Side of a Public Way

From Nearest Side of Any Public Wayor from Nearest Important Building on

the Same Property

Any typeProtection for

exposures1 12 times value in Table 22411(b) but notless than 25 ft

1 12 times value in Table 22411(b) but notless than 25 ft

None3 times value in Table 22411(b) but not beless than 50 ft

1 12 times value in Table 22411(b) but notless than 25 ft

For SI units 1 ft = 03 m

See definition 3346 Protection for Exposures

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22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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6 of 8 632013 1037 PM

22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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7 of 8 632013 1037 PM

224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

ResponseMessage

Ballot Results

This item has not been balloted

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8 of 8 632013 1037 PM

Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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1 of 5 632013 1039 PM

Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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3 of 5 632013 1039 PM

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

ResponseMessage

Ballot Results

This item has not been balloted

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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1 of 2 632013 1048 PM

Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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3 of 5 632013 1049 PM

Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

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bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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bbenedetti
Text Box
ATTACHMENT No A9

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is not permitted to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22411(a) and Table22411(b) Where tank spacing is based on a weak roof-to-shell seam design the user shall presentevidence certifying such construction to the authority having jurisdiction upon request

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Not toExceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Waya

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Propertya

Floating roofProtection for

exposuresb12 times diameter of tank 16 times diameter of tank

NoneDiameter of tank but neednot exceed 175 ft

16 times diameter of tank

Vertical with weak roof-to-shellseam

Approved foam or

inerting systemc ontanks not exceeding

150 ft in diameterd

12 times diameter of tank 16 times diameter of tank

Protection for

exposuresb Diameter of tank 13 times diameter of tank

None2 times diameter of tank butneed not exceed 350 ft

13 times diameter of tank

Horizontal and vertical tankswith emergency relief ventingto limit pressures to 25 psi(gauge pressure of 17 kPa)

Approved inerting

systemb on the tank orapproved foam systemon vertical tanks

12 times value in Table22411(b)

12 times value in Table22411(b)

Protection for

exposuresb Value in Table 22411(b) Value in Table 22411(b)

None2 times value in Table22411(b)

Value in Table 22411(b)

Protected aboveground tank None12 times value in Table22411(b)

12 times value in Table22411(b)

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft (15 m)

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

dFor tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

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Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

For SI units 1 ft = 03 m 1 gal = 38 L

22412

Vertical tanks with weak roof-to-shell seams (see 2272) that store Class IIIA liquids shall be permitted to belocated at one-half the distances specified in Table 22411(a) provided the tanks are not within the samediked area as or within the drainage path of a tank storing a Class I or Class II liquid

22413

Tanks storing Class I Class II or Class IIIA stable liquids and operating at pressures that exceed a gaugepressure of 25 psi (17 kPa) or are equipped with emergency venting that will permit pressures to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22413 and Table 22411(b)

Table 22413 Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Permittedto Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or Can BeBuilt Upon Including the Opposite

Side of a Public Way

From Nearest Side of Any Public Wayor from Nearest Important Building on

the Same Property

Any typeProtection for

exposures1 12 times value in Table 22411(b) but notless than 25 ft

1 12 times value in Table 22411(b) but notless than 25 ft

None3 times value in Table 22411(b) but not beless than 50 ft

1 12 times value in Table 22411(b) but notless than 25 ft

For SI units 1 ft = 03 m

See definition 3346 Protection for Exposures

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22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

ResponseMessage

Ballot Results

This item has not been balloted

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8 of 8 632013 1037 PM

Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

ResponseMessage

Ballot Results

This item has not been balloted

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

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Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

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Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is not permitted to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22411(a) and Table22411(b) Where tank spacing is based on a weak roof-to-shell seam design the user shall presentevidence certifying such construction to the authority having jurisdiction upon request

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Not toExceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Waya

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Propertya

Floating roofProtection for

exposuresb12 times diameter of tank 16 times diameter of tank

NoneDiameter of tank but neednot exceed 175 ft

16 times diameter of tank

Vertical with weak roof-to-shellseam

Approved foam or

inerting systemc ontanks not exceeding

150 ft in diameterd

12 times diameter of tank 16 times diameter of tank

Protection for

exposuresb Diameter of tank 13 times diameter of tank

None2 times diameter of tank butneed not exceed 350 ft

13 times diameter of tank

Horizontal and vertical tankswith emergency relief ventingto limit pressures to 25 psi(gauge pressure of 17 kPa)

Approved inerting

systemb on the tank orapproved foam systemon vertical tanks

12 times value in Table22411(b)

12 times value in Table22411(b)

Protection for

exposuresb Value in Table 22411(b) Value in Table 22411(b)

None2 times value in Table22411(b)

Value in Table 22411(b)

Protected aboveground tank None12 times value in Table22411(b)

12 times value in Table22411(b)

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft (15 m)

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

dFor tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

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Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

For SI units 1 ft = 03 m 1 gal = 38 L

22412

Vertical tanks with weak roof-to-shell seams (see 2272) that store Class IIIA liquids shall be permitted to belocated at one-half the distances specified in Table 22411(a) provided the tanks are not within the samediked area as or within the drainage path of a tank storing a Class I or Class II liquid

22413

Tanks storing Class I Class II or Class IIIA stable liquids and operating at pressures that exceed a gaugepressure of 25 psi (17 kPa) or are equipped with emergency venting that will permit pressures to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22413 and Table 22411(b)

Table 22413 Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Permittedto Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or Can BeBuilt Upon Including the Opposite

Side of a Public Way

From Nearest Side of Any Public Wayor from Nearest Important Building on

the Same Property

Any typeProtection for

exposures1 12 times value in Table 22411(b) but notless than 25 ft

1 12 times value in Table 22411(b) but notless than 25 ft

None3 times value in Table 22411(b) but not beless than 50 ft

1 12 times value in Table 22411(b) but notless than 25 ft

For SI units 1 ft = 03 m

See definition 3346 Protection for Exposures

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22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

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Ballot Results

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8 of 8 632013 1037 PM

Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

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Ballot Results

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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2 of 5 632013 1049 PM

Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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3 of 5 632013 1049 PM

Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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ATTACHMENT No A9

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

For SI units 1 ft = 03 m 1 gal = 38 L

22412

Vertical tanks with weak roof-to-shell seams (see 2272) that store Class IIIA liquids shall be permitted to belocated at one-half the distances specified in Table 22411(a) provided the tanks are not within the samediked area as or within the drainage path of a tank storing a Class I or Class II liquid

22413

Tanks storing Class I Class II or Class IIIA stable liquids and operating at pressures that exceed a gaugepressure of 25 psi (17 kPa) or are equipped with emergency venting that will permit pressures to exceed agauge pressure of 25 psi (17 kPa) shall be located in accordance with Table 22413 and Table 22411(b)

Table 22413 Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal Pressure Permittedto Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or Can BeBuilt Upon Including the Opposite

Side of a Public Way

From Nearest Side of Any Public Wayor from Nearest Important Building on

the Same Property

Any typeProtection for

exposures1 12 times value in Table 22411(b) but notless than 25 ft

1 12 times value in Table 22411(b) but notless than 25 ft

None3 times value in Table 22411(b) but not beless than 50 ft

1 12 times value in Table 22411(b) but notless than 25 ft

For SI units 1 ft = 03 m

See definition 3346 Protection for Exposures

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22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

ResponseMessage

Ballot Results

This item has not been balloted

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Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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3 of 5 632013 1039 PM

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

ResponseMessage

Ballot Results

This item has not been balloted

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

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bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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1 of 2 632013 1046 PM

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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bbenedetti
Text Box
ATTACHMENT No A9

22414

Tanks storing liquids with boil-over characteristics shall be located in accordance with Table 22414 Liquidswith boil-over characteristics shall not be stored in fixed roof tanks larger than 150 ft (45 m) in diameter unlessan approved inerting system is provided on the tank

Table 22414 Location of Aboveground Storage Tanks Storing Boil-Over Liquids

Minimum Distance (ft)

Type ofTank Protection

From Property Line that Is or CanBe Built Upon Including the

Opposite Side of a Public Waya

From Nearest Side of Any PublicWay or from Nearest Important

Building on the Same Propertya

Floatingroof

Protection for

exposuresb12 times diameter of tank 16 times diameter of tank

None Diameter of tank 16 times diameter of tank

Fixed roofApproved foam or

inerting systemc Diameter of tank 13 times diameter of tank

Protection for

exposuresb 2 times diameter of tank 23 times diameter of tank

None4 times diameter of tank but need notexceed 350 ft

23 times diameter of tank

For SI units 1 ft = 03 m

aThe minimum distance cannot be less than 5 ft

bSee definition 3346 Protection for Exposures

cSee NFPA 69 Standard on Explosion Prevention Systems

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22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

ResponseMessage

Ballot Results

This item has not been balloted

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Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

ResponseMessage

Ballot Results

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Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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2 of 5 632013 1049 PM

Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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ATTACHMENT No A9

22415

Tanks storing unstable liquids shall be located in accordance with Table 22415 and Table 22411(b)

Table 22415 Location of Aboveground Storage Tanks Storing Unstable Liquids

Minimum Distance (ft)

Type of Tank Protection

From Property Linethat Is or Can Be

Built Upon Includingthe Opposite Side of

a Public Way

From Nearest Side ofAny Public Way or

from NearestImportant Building on

the Same Propertya

Horizontal and vertical tankswith emergency reliefventing to permit pressurenot in excess of a gaugepressure of 25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

Value in Table22411(b) but not lessthan 25 ft

Not less than 25 ft

Protection for exposuresb2 12 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

None5 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

Horizontal and vertical tankswith emergency reliefventing to permit pressureover a gauge pressure of25 psi (17 kPa)

Tank protected with any one ofthe following approved water

spray approved inertinga

approved insulation andrefrigeration approvedbarricade

2 times value in Table22411(b) but not lessthan 50 ft

Not less than 50 ft

Protection for exposuresb4 times value in Table22411(b) but not lessthan 100 ft

Not less than 100 ft

None8 times value in Table22411(b) but not lessthan 150 ft

Not less than 150 ft

For SI units 1 ft = 03 m

aSee NFPA 69 Standard on Explosion Prevention Systems

bSee definition 3346 Protection for Exposures

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22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

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Ballot Results

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Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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3 of 5 632013 1039 PM

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

ResponseMessage

Ballot Results

This item has not been balloted

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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1 of 2 632013 1048 PM

Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

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bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

22416

Tanks storing Class IIIB stable liquids shall be located in accordance with Table 22416

Table 22416 Location of Aboveground Storage Tanks Storing Class IIIB Liquids

Minimum Distance (ft)

TankCapacity

(gal)

From Property Line that Is or Can Be BuiltUpon Including the Opposite Side of a

Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

12000 or less 5 5

12001 to30000

10 5

30001 to50000

10 10

50001 to100000

15 10

100001 ormore

15 15

For SI units 1 ft = 03 m 1 gal = 38 L

Exception If located within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid the tank storing Class IIIB liquid shall be located in accordance with 22411

22417

Where two tank properties of diverse ownership have a common boundary the authority having jurisdictionshall be permitted with the written consent of the owners of the two properties to substitute the distancesprovided in 2242 for the minimum distances set forth in 22411

22418

Where end failure of a horizontal pressure tank or vessel can expose property the tank or vessel shall beplaced with its longitudinal axis parallel to the nearest important exposure

2242 Shell-to-Shell Spacing of Adjacent Aboveground Storage Tanks

22421

Tanks storing Class I Class II or Class IIIA stable liquids shall be separated by the distances given in Table22421

Table 22421 Minimum Shell-to-Shell Spacing of Aboveground Storage Tanks

Fixed or Horizontal Tanks

Tank Diameter Floating Roof Tanks Class I or II Liquids Class IIIA Liquids

All tanks not over 150 ft(45 m) in diameter

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

16 times sum of adjacent tankdiameters but not less than3 ft (09 m)

Tanks larger than 150 ft(45 m) in diameter

If remote impounding isprovided in accordancewith 22111

16 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

16 times sum of adjacent tankdiameters

If open diking is providedin accordance with 22112

14 times sum of adjacent tankdiameters

13 times sum of adjacent tankdiameters

14 times sum of adjacent tankdiameters

Note The ldquosum of adjacent tank diametersrdquo means the sum of the diameters of each pair of tanks that areadjacent to each other See also A22421

224211

Tanks that store crude petroleum have individual capacities not exceeding 3000 bbl [126000 gal (480 m3)]and are located at production facilities in isolated locations shall not be required to be separated by more than3 ft (09 m)

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7 of 8 632013 1037 PM

224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

ResponseMessage

Ballot Results

This item has not been balloted

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8 of 8 632013 1037 PM

Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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1 of 5 632013 1039 PM

Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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3 of 5 632013 1039 PM

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

ResponseMessage

Ballot Results

This item has not been balloted

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

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bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

224212

Tanks used only for storing Class IIIB liquids shall not be required to be separated by more than 3 ft (09 m)provided they are not within the same diked area as or within the drainage path of a tank storing a Class I orClass II liquid If located within the same diked area as or within the drainage path of a tank storing a Class Ior Class II liquid the tank storing Class IIIB liquid shall be spaced in accordance with the requirements forClass IIIA liquids in Table 22421

22422

A tank storing unstable liquid shall be separated from any other tank containing either an unstable liquid or aClass I II or III liquid by a distance not less than one-half the sum of their diameters

22423

Where tanks are in a diked area containing Class I or Class II liquids or in the drainage path of Class I or ClassII liquids and are compacted in three or more rows or in an irregular pattern greater spacing or other meansshall be permitted to be required by the authority having jurisdiction to make tanks in the interior of the patternaccessible for fire-fighting purposes

22424

The minimum horizontal separation between an LP-Gas container and a Class I Class II or Class IIIA liquidstorage tank shall be 20 ft (6 m)

224241

Means shall be provided to prevent Class I Class II or Class IIIA liquids from accumulating under adjacentLP-Gas containers by means of dikes diversion curbs or grading

224242

Where flammable or combustible liquid storage tanks are within a diked area the LP-Gas containers shall beoutside the diked area and at least 3 ft (09 m) away from the centerline of the wall of the diked area

22425

If a tank storing a Class I Class II or Class IIIA liquid operates at pressures exceeding a gauge pressure of25 psi (17 kPa) or is equipped with emergency relief venting that will permit pressures to exceed a gaugepressure of 25 psi (17 kPa) it shall be separated from an LP-Gas container by the appropriate distance givenin Table 22421

22426

The requirements of 22424 shall not apply where LP-Gas containers of 125 gal (475 L) or less capacity areinstalled 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 101759 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input12 on Section 227

ResponseMessage

Ballot Results

This item has not been balloted

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8 of 8 632013 1037 PM

Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

ResponseMessage

Ballot Results

This item has not been balloted

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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2 of 5 632013 1049 PM

Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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3 of 5 632013 1049 PM

Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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Ballot Results

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bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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bbenedetti
Text Box
ATTACHMENT No A9

Committee Input No 12-NFPA 30-2012 [ Section No 227 ]

227 Emergency Relief Venting for Fire Exposure for Aboveground Storage Tanks

2271 General

22711

Every aboveground storage tank shall have emergency relief venting in the form of construction or a device ordevices that will relieve excessive internal pressure caused by an exposure fire

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space (annulus) ofa secondary containmentndashtype tank and the enclosed space of tanks of closed-top dike construction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended for insulationmembranes or weather shields that are capable of containing liquid because of a leak from the primaryvessel The insulation membrane or weather shield shall not interfere with emergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not within the dikedarea or the drainage path of tanks storing Class I or Class II liquids shall not be required to meet therequirements of 22711

22712

For vertical tanks the emergency relief venting construction referred to in 22711 shall be permitted to be afloating roof a lifter roof a weak roof-to-shell seam or another approved pressure-relieving construction

22713

If unstable liquids are stored the effects of heat or gas resulting from polymerization decompositioncondensation or self-reactivity shall be taken into account

22714

If two-phase flow is anticipated during emergency venting an engineering evaluation shall be conducted inorder to size the pressure-relieving devices

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage or ANSIUL 142Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids

2273 Pressure-Relieving Devices

22731

Where entire dependence for emergency relief venting is placed upon pressure-relieving devices the totalventing capacity of both normal and emergency vents shall be sufficient to prevent rupture of the shell orbottom of a vertical tank or of the shell or heads of a horizontal tank

22732

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Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

ResponseMessage

Ballot Results

This item has not been balloted

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Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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1 of 2 632013 1048 PM

Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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1 of 5 632013 1049 PM

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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2 of 2 632013 1051 PM

Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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1 of 2 632013 1054 PM

Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1044 PM

Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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1 of 2 632013 1046 PM

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

Except as provided for in 22735 22736 and 22737 the total emergency relief venting capacity of bothnormal and emergency venting devices shall be not less than that determined in Table 22732 (See AnnexB for the square footage of typical tank sizes)

Table 22732 Required Emergency Relief Venting mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH ft2 CFH

20 21100 160 168000 900 493000

30 31600 180 190000 1000 524000

40 42100 200 211000 1200 557000

50 52700 250 239000 1400 587000

60 63200 300 265000 1600 614000

70 73700 350 288000 1800 639000

80 84200 400 312000 2000 662000

90 94800 500 354000 2400 704000

100 105000 600 392000 2800 742000

120 126000 700 428000 and over

140 147000 800 462000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

227321

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

227322

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 topsurface of the tank

(4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank

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22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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3 of 5 632013 1039 PM

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

ResponseMessage

Ballot Results

This item has not been balloted

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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1 of 2 632013 1048 PM

Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1044 PM

Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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1 of 2 632013 1046 PM

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

22733

The total emergency relief venting capacity for tanks and storage vessels designed to operate at pressuresabove a gauge pressure of 10 psi (69 kPa) shall be as follows

(1) For tanks whose wetted area does not exceed 2800 ft2 (260 m2) not less than that determined in Table22732

(2) For tanks whose wetted area exceeds 2800 ft2 (260 m2) not less than that determined in Table 22733or not less than that calculated by the following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

A = wetted area (ft2)

Table 22733 Required Emergency Relief Venting for Tanks with Wetted Area over 2800 ft2 (260 m2) andOperating at Gauge Pressure over 1 psi (69 kPa) mdash Cubic Feet of Free Air per Hour (CFH) versus WettedArea of Tank Shell (ft2)

ft2 CFH ft2 CFH

2800 742000 9000 1930000

3000 786000 10000 2110000

3500 892000 15000 2940000

4000 995000 20000 3720000

4500 1100000 25000 4470000

5000 1250000 30000 5190000

6000 1390000 35000 5900000

7000 1570000 40000 6570000

8000 1760000

For SI units 10 ft2 = 093 m2 36 ft3 = 10 m3

Notes

(1) Interpolate for intermediate values not specified in the table

(2) CFH is flow capacity at absolute pressure of 147 psi (101 kPa) and 60degF (156degC) See 2273102

22734

The total emergency relief venting capacity for any specific stable liquid shall be permitted to be determined bythe following formula

where

CFH = venting capacity requirement (ft3 of free air per hour)

V = ft3 of free air per hour (CFH) value from Table 22732

L = latent heat of vaporization of specific liquid (Btulb)

M = molecular weight of specific liquids

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3 of 5 632013 1039 PM

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

ResponseMessage

Ballot Results

This item has not been balloted

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1044 PM

Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the required emergencyrelief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by oneof the following reduction factors when protection is provided as indicated Only one of the following factorsshall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19 m2) that areprovided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automatically actuated waterspray system that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for FireProtection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets the requirementsof 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spray system thatmeets the requirements of NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection andthat have insulation that meets the requirements of 22738

22736

Where water-miscible liquids whose heats of combustion and rates of burning are equal to or less than thoseof ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fire exposure fromliquids other than these liquids the emergency relief venting capacity shall be permitted to be reduced by anadditional 50 percent Drainage shall not be required to obtain this reduction In no case shall the factors in22735 (1) through 22735 (5) be reduced to less than 015

22737

Where liquids that are not water-miscible and whose heats of combustion and rates of burning are equal to orless than those of ethyl alcohol (ethanol) are stored processed or handled and where there is no potential fireexposure from liquids other than these liquids the emergency relief venting capacity determined by 22735(1) or 22735 (3) shall be permitted to be reduced by an additional 50 percent No further reduction shall beallowed for protection by means of water spray Drainage shall not be required to obtain this reduction In nocase shall the factors in 22735 (1) through 22735 (5) be reduced to less than 015

22738

Insulation for which credit is taken in 22735 (4) and 22735 (5) shall meet the following performancecriteria

(1) The insulation shall remain in place under fire exposure conditions

(2) The insulation shall withstand dislodgment when subjected to hose stream impingement during fireexposure

(3) The insulation shall maintain a maximum conductance value of 40 Btuhrft2degF (23 Wm2degC) when theouter insulation jacket or cover is at a temperature of 1660degF (904degC) and when the mean temperature ofthe insulation is 1000degF (538degC)

Exception The requirement of 22738 (2) need not apply where use of solid hose streams is notcontemplated or would not be practical

22739

The outlets of all vents and vent drains on tanks equipped with emergency relief venting that permits pressuresto exceed a gauge pressure of 25 psi (172 kPa) shall be arranged to discharge so that localized overheatingof or flame impingement on any part of the tank will not occur if vapors from the vents are ignited

227310

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4 of 5 632013 1039 PM

Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

ResponseMessage

Ballot Results

This item has not been balloted

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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1 of 2 632013 1048 PM

Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1044 PM

Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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1 of 2 632013 1046 PM

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

Each commercial tank venting device shall have the following information either stamped or cast into the metalbody 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 227310 (2)

2273101

If the start-to-open pressure is less than a gauge pressure of 25 psi (172 kPa) and the pressure at the fullopen position is greater than a gauge pressure of 25 psi (172 kPa) the flow capacity at a gauge pressure of25 psi (172 kPa) shall also be stamped on the venting device

2273102

The flow capacity shall be expressed in cubic feet per hour of air at 60degF (156degC) and an absolute pressure of147 psi (101 kPa)

2273103

The flow capacity of tank venting devices less than 8 in (200 mm) in nominal pipe size shall be determined byactual test These tests shall be permitted to be conducted by a qualified impartial outside agency or by themanufacturer if certified by a qualified impartial observer

2273104

The flow capacity of tank venting devices equal to or greater than 8 in (200 mm) nominal pipe size includingmanway covers with long bolts shall be determined by test or by calculation If determined by calculation theopening pressure shall be measured by test the calculation shall be based on a flow coefficient of 05 appliedto the rated orifice the rating pressure and corresponding free orifice area shall be stated and the wordcalculated shall appear on the nameplate

2274 Extension of Emergency Vent Piping

Piping to or from approved emergency vent devices for atmospheric and low-pressure tanks shall be sized toprovide emergency vent flows that limit the back pressure to less than the maximum pressure permitted by thedesign of the tank Piping to or from approved emergency vent devices for pressure vessels shall be sized inaccordance with the ASME Boiler and Pressure Vessel Code

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101837 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is investigating the need forfurther regulation of the pressure limitations on the outer shell of aboveground secondarycontainment-type tanks under emergency venting conditions Public comments are sought to provideinput for possible Technical Committee action at the second draft meeting See also Committee Input11 on Section 224

ResponseMessage

Ballot Results

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5 of 5 632013 1039 PM

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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1 of 2 632013 1048 PM

Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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1 of 5 632013 1049 PM

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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2 of 2 632013 1051 PM

Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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1 of 2 632013 1054 PM

Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1044 PM

Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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1 of 2 632013 1046 PM

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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bbenedetti
Text Box
ATTACHMENT No A9

Public Comment No 20-NFPA 30-2013 [ Section No 214214 ]

214214

Horizontal cylindrical and rectangular tanks built according to any of the standards specified in214211 shall be permitted to operate at pressures from atmospheric to a gauge pressure of10 psi (69 kPa) and shall be limited to a shall not exceed a gauge pressure of 25 psi (17 kPa)under emergency venting conditions The same requirement applies to every compartment and anyinterstitial space of such tanks

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

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 that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Wed May 08 151135 EDT 2013

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Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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3 of 5 632013 1049 PM

Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

Ballot Results

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bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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bbenedetti
Text Box
ATTACHMENT No A9

Public Comment No 21-NFPA 30-2013 [ Section No 22411 ]

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22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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2 of 2 632013 1051 PM

Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

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bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1044 PM

Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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bbenedetti
Text Box
ATTACHMENT No A9

22411

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Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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2 of 2 632013 1051 PM

Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

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bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

Tanks storing Class I Class II or Class IIIA stable liquids whose internal pressure is notpermitted to exceed pressure of every compartment of the tank and any interstitial space of the tankshall not exceed a gauge pressure of 25 psi (17 kPa) shall The tanks shall be located inaccordance with Table 22411(a) and Table 22411(b) Where tank spacing is based on a weakroof-to-shell seam a venting by form of construction design the user shall present evidence certifyingsuch construction to the authority having jurisdiction upon request certifying the construction complieswith this requirement

Table 22411(a) Location of Aboveground Storage Tanks Storing Stable Liquids mdash Internal PressureNot to Exceed a Gauge Pressure of 25 psi (17 kPa)

Minimum Distance (ft)

Type of Tank Protection

From Property LineThat Is or Can Be Built

Upon Including theOpposite Side of a

Public Way a

From Nearest Side ofAny Public Way or from

Nearest ImportantBuilding on the Same

Property a

Floating roofProtection for

exposures b1 frasl 2 times diameter of

tank

1 frasl 6 times diameter oftank

NoneDiameter of tank butneed not exceed 175 ft

1 frasl 6 times diameter oftank

Vertical with weakroof-to-shell seam

Approved foam or

inerting system c ontanks not exceeding

150 ft in diameter d

1 frasl 2 times diameter oftank

1 frasl 6 times diameter oftank

Protection for

exposures b Diameter of tank1 frasl 3 times diameter of

tank

None2 times diameter of tankbut need not exceed350 ft

1 frasl 3 times diameter oftank

Horizontal and verticaltanks with emergency reliefventing to limit pressures to25 psi (gauge pressure of17 kPa)

Approved inerting

system b on the tankor approved foamsystem on verticaltanks

1 frasl 2 times value in Table22411(b)

1 frasl 2 times value in Table22411(b)

Protection for

exposures bValue in Table22411(b)

Value in Table22411(b)

None2 times value in Table22411(b)

Value in Table22411(b)

Protected abovegroundtank

None1 frasl 2 times value in Table

22411(b)

1 frasl 2 times value in Table22411(b)

For SI units 1 ft = 03 m

a The minimum distance cannot be less than 5 ft (15 m)

b See definition 3346 Protection for Exposures

c See NFPA 69 Standard on Explosion Prevention Systems

d For tanks over 150 ft (45 m) in diameter use ldquoProtection for Exposuresrdquo or ldquoNonerdquo as applicable

Table 22411(b) Reference Table for Use with Tables 22411(a) 22413 and 22415

Minimum Distance (ft)

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3 of 5 632013 1049 PM

Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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4 of 5 632013 1049 PM

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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1 of 2 632013 1051 PM

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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2 of 2 632013 1051 PM

Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

Ballot Results

This item has not been balloted

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bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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bbenedetti
Text Box
ATTACHMENT No A9

Tank Capacity(gal)

From Property Line that Is or Can BeBuilt Upon Including the Opposite Side

of a Public Way

From Nearest Side of Any Public Way orfrom Nearest Important Building on the

Same Property

275 or less 5 5

276 to 750 10 5

751 to 12000 15 5

12001 to30000

20 5

30001 to50000

30 10

50001 to100000

50 15

100001 to500000

80 25

500001 to1000000

100 35

1000001 to2000000

135 45

2000001 to3000000

165 55

3000001 ormore

175 60

For SI units 1 ft = 03 m 1 gal = 38 L

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial

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space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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5 of 5 632013 1049 PM

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

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bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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bbenedetti
Text Box
ATTACHMENT No A9

space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 114407 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

Ballot Results

This item has not been balloted

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bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

Public Comment No 27-NFPA 30-2013 [ New Section after 227 ]

TITLE OF NEW CONTENT

No recommendation provided

Additional Proposed Changes

File Name Description Approved

30_Holmespdf

Statement of Problem and Substantiation for Public Comment

Yes 25 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 25 psi any other rating will require testing of the e vent for airflow

When large ASTs 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 amp Bailey Mfg Co

Submittal Date Thu May 09 143041 EDT 2013

Copyright Assignment

I Bradford Holmes hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1050 PM

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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2 of 2 632013 1051 PM

Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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1 of 2 632013 1052 PM

Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

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bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

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bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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bbenedetti
Text Box
ATTACHMENT No A9

Public Comment No 22-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground storage tank shall have emergency relief venting designed for use whenthe tank is exposed to a fire The vent shall be in the form of construction in accordance with2272 or a device or devices that will relieve

excessive

internal pressure

caused by an exposure fire

above the limits defined in 22411(s) or 22413 as applicable

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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

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requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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1 of 2 632013 1046 PM

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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bbenedetti
Text Box
ATTACHMENT No A9

requirements as the primary tank Table 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 115411 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 thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation) I understand and intend that I acquireno rights including rights as a joint author in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform 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 copyrightassignment

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 andconditions contained therein I understand and intend that by checking this box I am creating an electronic signature that will upon mysubmission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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1 of 2 632013 1052 PM

Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1040 PM

bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

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bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

Public Comment No 25-NFPA 30-2013 [ Section No 22711 ]

22711

Every aboveground

storage tank shall

tank and every compartment or interstitial space of an aboveground tank shall have emergencyrelief venting in the form of construction or a device or devices that will relieve excessiveinternal pressure caused by an exposure fire This requirement shall be verifiable by the abilityto 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 bevented at 25 psig

227111

This requirement shall apply to each compartment of a compartmented tank the interstitial space(annulus) of a secondary containmentndashtype tank and the enclosed space of tanks of closed-top dikeconstruction

227112

This requirement shall also apply to spaces or enclosed volumes such as those intended forinsulation membranes or weather shields that are capable of containing liquid because of a leakfrom the primary vessel The insulation membrane or weather shield shall not interfere withemergency venting

227113

Tanks storing Class IIIB liquids that are larger than 12000 gal (45400 L) capacity and are not withinthe diked area or the drainage path of tanks storing Class I or Class II liquids shall not be required tomeet the requirements of 22711

Additional Proposed Changes

File Name Description Approved

30_Greer_2pdf

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 tanks 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

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 125914 EDT 2013

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Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

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bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1044 PM

Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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bbenedetti
Text Box
ATTACHMENT No A9

Public Comment No 10-NFPA 30-2013 [ Section No 227111 ]

227111

This requirement shall apply to each compartment of a compartmented tank the interstitialspace (annulus) of a secondary containmentndashtype tank and the enclosed space of tanks ofclosed-top dike construction and shall be limited to a gauge pressure of 2 5 psi underemergency venting conditions in the primary tank as well as in the interstice of thesecondary containment tanks

Additional Proposed Changes

File Name Description Approved

30_227111docx 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 25 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 080610 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

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Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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ATTACHMENT No A9

Public Comment No 23-NFPA 30-2013 [ Section No 2272 ]

2272 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 bedesigned in accordance with API Standard 650 Welded Steel Tanks for Oil Storage If used thesecondary containment of Protected Tanks labeled UL 2085 shall be constructed to fail preferentiallyabove the liquid level as evidenced by the UL required marking

Additional Proposed Changes

File Name Description Approved

30_Grainawipdf

Statement of Problem and Substantiation for Public Comment

Related to Items 11 and 12There is confusion on what is intended in NFPA 30 regarding emergency venting The purpose of this proposal is to clarify that1) Table 22411(a) is intended for atmospheric tanks and requires the tank pressure not to exceed 25 psi2) Section 214214 also states that atmospheric tanks shall have emergency venting that functions at pressures no greater than 25 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 227111 and 227112 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 25 psi Applying the same emergency relief venting requirements which is that the venting mechanism must operate at a maximum 25 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 25 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 81 in UL 142 Emergency venting capacity for primary tanks and interstitial space of secondary containment tanks uses Table 22732 which suggests that NFPA should adopt the same policy Further I have deleted the reference to the UL 142 standard in 2272 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 standardI am also suggesting editorial corrections to the language for the purpose of making sections 22411 and 22711 easier to read In section 22411 I am proposing to change ldquois not permitted tordquo to ldquoshall notrdquo because the first is generally considered to be permissive language Also an AHJ does not certify ldquosuchrdquo anything but rather certifies ldquothe constructionrdquo

Submitter Information Verification

Submitter Full Name Lorri Grainawi

Organization Steel Tank Institute

Submittal Date Thu May 09 120355 EDT 2013

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Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

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Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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bbenedetti
Text Box
ATTACHMENT No A9

Committee Input No 13-NFPA 30-2012 [ Section No 22735 ]

22735

Except as provided for in 22736 and 22737 for tanks containing stable liquids the requiredemergency relief venting capacity determined by 22732 22733 or 22734 shall be permittedto be multiplied by one of the following reduction factors when protection is provided as indicatedOnly one of the following factors shall be used for any one tank

(1) A reduction factor of 05 shall be allowed for tanks with wetted area greater than 200 ft2 (19

m2) that are provided with drainage that meets the requirements of 22111

(2) A reduction factor of 03 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that are provided with drainage that meets the requirements of 22111

(3) A reduction factor of 03 shall be allowed for tanks that are protected with an automaticallyactuated water spray system that meets the requirements of NFPA 15 Standard for WaterSpray Fixed Systems for Fire Protection

(4) A reduction factor of 03 shall be allowed for tanks protected with insulation that meets therequirements of 22738

(5) A reduction factor of 015 shall be allowed for tanks that are protected with a water spraysystem that meets the requirements of NFPA 15 Standard for Water Spray Fixed Systems forFire Protection and that have insulation that meets the requirements of 22738

Supplemental Information

FileName

Description

Replacement_for_Emergency_Venting_Reduction_FactorsdocReplacement for Subsection 22735

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 101958 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The Technical Committee on Tank Storage and Piping Systems is considering replacingthe text of 22735 with a table indicating the allowed reduction factors (See Attachment)The Technical Committee solicits input from the public during the Public Comment period

ResponseMessage

Ballot Results

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bbenedetti
Text Box
ATTACHMENT No A6

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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bbenedetti
Text Box
ATTACHMENT No A9

Replacement for 22735 Reduction Factors for Emergency Relief Venting

22735 For tanks containing stable liquids the required emergency relief venting capacity determined by 22732 22733 or 22734 shall be permitted to be multiplied by one of the reduction factors shown in Table 22735 when protection is provided as indicated Only one reduction factor shall be used for any one tank Protection measures shall meet 22735 (1) through (4) as appropriate (1) Drainage shall meet the requirements of 22111 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 22111 (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 22738 227351 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 22735 Drainage shall not be required to obtain this reduction In no case shall the combined reduction factor be less than 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision 227352 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 22735 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 015 There shall be no fire exposure from liquids other than from those liquids covered by this provision

Table 22735 Emergency Relief Venting Reduction Factors Stable Liquids

water-miscible or non-water-miscible

Water-miscible Liquids that meet

227351

Non-water-miscible Liquids that meet

227352 Protection Measure(s)

NONE 10 05 05 Drainage alone 05 025 025

Manual water spray combined with drainage

03 015 03

Automatically-actuated water spray

03 015 03

Insulation alone 03 015 03 Manual or automatically-

actuated water spray combined with insulation

015 015

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

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1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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1 of 2 632013 1046 PM

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

Committee Input No 15-NFPA 30-2012 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground StorageTanks

Liquid Classification

Capacity

gal L

I 12000 45400

II and IIIA 20000 75700

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 114027 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

The NFPA 30 Technical Committee on Tank Storage and Piping Systems is consideringeliminating the limitation on capacity of the primary tank for listed secondarycontainment-type tanks as set forth in Table 221141 where the secondary containment isused to meet the spill control provisions of Section 2211 The Technical Committee invitespublic comment on this issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1041 PM

bbenedetti
Text Box
ATTACHMENT No A7

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1044 PM

Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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1 of 2 632013 1046 PM

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

Ballot Results

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

Public Comment No 9-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType AbovegroundStorage Tanks

Liquid Classification Capacity gal L I 12000 45400 II and IIIA 20000 75700

maximum capacity allowed by the listing for shop fabricated secondary containment tankconstruction

Additional Proposed Changes

File Name Description Approved

30_221141docx 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 amp III liquids over 20000 gals The 10 safety features required for tanks below the above capacities should be adequate for capacities over the above capacitiesIt doesnt 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 082407 EDT 2013

Copyright Assignment

I ALEX RALSTON hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 Assignmentand the terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 632013 1044 PM

Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 2 632013 1045 PM

Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 2 632013 1046 PM

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

Public Comment No 12-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

DOC043013-04302013120847pdf 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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name JASON GREER

Organization GREER TANK amp WELDING INC

Submittal Date Tue Apr 30 121718 EDT 2013

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 2 632013 1045 PM

Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 2 632013 1045 PM

Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 2 632013 1046 PM

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

Ballot Results

This item has not been balloted

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

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1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

Public Comment No 15-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType 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 Description Approved

30_Mott-Smith_M-SCG_Comments_on_Secondary_Containment_Tanks_as_Spill_Controlpdf

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 protectionshut-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 ASTrsquos

Submitter Information Verification

Submitter Full Name Marshall Mott-Smith

Organization Mott-Smith Consulting Group

Submittal Date Thu May 02 075514 EDT 2013

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1 of 2 632013 1045 PM

Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

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1 of 2 632013 1046 PM

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

Public Comment No 24-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Greerpdf

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 221142 through 2211410 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 50000 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 2135]

Submitter Information Verification

Submitter Full Name Carl Greer

Organization Service Welding amp Machine Co

Submittal Date Thu May 09 124444 EDT 2013

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 2 632013 1046 PM

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 2 632013 1046 PM

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

Ballot Results

This item has not been balloted

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1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

Public Comment No 26-NFPA 30-2013 [ Section No 221141 ]

221141

The capacity of the listed primary tank shall not exceed the capacities given in Table 221141

Table 221141 Maximum Capacities for Secondary ContainmentndashType Aboveground Storage Tanks

Liquid Classification

Capacity

gal 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_Roggelinpdf

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 221142 through 2211410 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 50000 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 ASTs

Submitter Information Verification

Submitter Full Name ERNEST M ROGGELIN

Organization PINELLAS CHD

Submittal Date Thu May 09 132614 EDT 2013

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 2 632013 1046 PM

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

Ballot Results

This item has not been balloted

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

Committee Input No 17-NFPA 30-2012 [ Section No 2744 ]

2744 Low Melting Point Materials

Low melting point materials such as aluminum copper and brass materials that soften on fireexposure such as plastics or nonductile materials such as cast iron shall be permitted to be usedunderground within the pressure and temperature limitations of ASME B31 Code for PressurePiping

27441

Such materials shall be permitted to be used outdoors above ground or inside buildings providedthey 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 importantbuildings or structures

(3) They are located where leakage can be controlled by operation of one or more accessibleremotely located valves

27442

The piping materials chosen shall be compatible with the liquids being handled

27443

Piping systems of these materials shall be designed and built in accordance with recognizedstandards of design for the particular materials chosen or with approved equivalent standards orshall be listed

Submitter Information Verification

Submitter Full Name [ Not Specified ]

Organization [ Not Specified ]

Submittal Date Thu Sep 27 115320 EDT 2012

Committee Statement and Meeting Notes

CommitteeStatement

In response to Recommendation 2006-3-I-FL-5 made by the U S Chemical Safety andHazard Investigation Board in its report on a storage tank explosion at the Bethune PointWastewater Treatment Plant the NFPA 30 Technical Committee on Tank Storage and PipingSystems is considering revising the provisions for use of low-melting point piping materialsas set forth in Subsection 2744 to restrict or prohibit the use of thermoplastic piping inaboveground flammable liquids service The Technical Committee invites public comment onthis issue

ResponseMessage

Ballot Results

This item has not been balloted

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 632013 1042 PM

bbenedetti
Text Box
ATTACHMENT No A8

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

From Stephen HainesTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Friday June 07 2013 15503 PMAttachments 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEIPresidentPrincipal Consultant - II Haines Fire amp Risk Consulting1 Linda Lane Suite BSouthampton NJ 08088Phone 609-388-4467Fax 609-388-4468Cell 609-661-2860Skype stephenhainesWebsite httpwwwhainesfire-riskcom

Notice - Haines Fire amp Risk Consulting (HFRC) accepts no liability for the content of this email or for the consequences ofany actions taken on the basis of the opinions recommendations or information provided unless they are confirmed in awritten 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 strictlyprohibited

See our website for info on TurboDraft Fire Eductor WATERWAY FIRE HOSE TESTING From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 03 2013 1110 PMTo Benedetti BobCc Matthews DianeSubject 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 DraftMeeting)- 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 toweigh in

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

It is not part of the tankrsquos normal or emergency venting

It is connected above the normal operating liquid level of the tank

It is connected below the normal operating liquid level of the tank and any of the following conditions are met

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

The material is protected from fire exposure such as by materials having a fire resistance of not less than 2 hours

the piping is not within the secondary containment area of a tank it is connected to and

SWH ndash consistent with 27432 for valves

SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during call

SWH ndash 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 27433

image1png

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

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

SWH ndash Eliminate potential pipe closure issue under fire conditions as brought up during callconnected to unless it is required by the properties of the material stored and

1 It is not part of the tankrsquos 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 SWH ndash consistent with 27433 for valves

SWH ndash No significant impact on the fire situation

under fire conditions as brought up during call

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 ndash consistent with 27432 for valves

SWH ndash 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 27433

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

From Sully CurranTo Benedetti BobSubject Re NFPA 30 FLC-TAN Task Groups Conference CallDate Friday June 07 2013 43259 PMAttachments NFPA 30 comment on FRP pipe 6-7-13doc

Bob Sorry I missed the earlier conf callMy vote is in favor of prohibiting the use of thermoplastic pipingin aboveground flammable liquid service but not reinforced fiberglass piping Attached is a paper Ideveloped describing the use of FRP pipe in marine vessels and off-shore platforms where there is aneed to reduce weightSully Curran

-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Benedetti Bob ltbbenedettiNFPAorggtCc Matthews Diane ltDMatthewsNFPAorggtSent Mon Jun 3 2013 1020 pmSubject 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 1000 AM Eastern Time to discuss the fiveissues 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 ofdiscussionIt is understood that not all will be able to participate in the call so I ask you to review the material that will besent 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 ldquoStandard Method of Test for Surface Burning Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos 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 Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe400755

Coated FRP Pipe 5 0 30

Index Improvement350725

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 200(FSully Curran June 7 2013

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

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 ldquoStandard Method of Test for Surface Burning

Characteristics of Building Materialsrdquo or other similar test methods specified in ANSI No 25 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 Webesterrsquos

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

Indices

Test Specimen Flame Spread Fuel Contribution Smoke Developed

FRP Pipe 40 0 755

Coated FRP Pipe 5 0 30

Index Improvement 35 0 725

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 Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

From Sully CurranTo Benedetti Bob wgeyersteeltankcom stephenhainesfire-riskcom petrosafetyverizonnet

rrenkespeiorgCc joiefolkersnovcomSubject Re NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Monday June 10 2013 22421 PM

Dear All1 Suggest revising 2744 as follows Low melting point materials such as aluminum copper andbrass materials that soften on fire exposure such as (delete plastics) thermoplastics etcThe US Chemical Safety and Hazard Investigation slide 15 identified that it was a thermoplastic pipethat 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 isremoved Thus fiberglass pipe is used on marine amp Navy vessels and off-shore petroleum platforms insalt water fire deluge protection systems that would be exposed to fire It is also used on marinevessels 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 isconnected to and in 274412 Do not agree with deletion of 27441 (1) They are resistant to damage by fire Insteadwould change (1) as followsThey are resistant to damage by fire according to burning tests in accordance with ASTM E84-81a orother similar test methods specified in ANSI No 25 NFPA 255 UL 723 and UBC 42-1 that call for aflame spread rate of less than 200 3 Also do not agree with deleting existing language (2) amp (3)4 Do not agree with addition of new language 1 2 amp 3 all of which is redundantthus confusing Regards Sully CurranFiberglass Tank amp Pipe Institute-----Original Message-----From Benedetti Bob ltbbenedettiNFPAorggtTo Curran Sully ltsullycurraaolcomgt Geyer Wayne ltwgeyersteeltankcomgt Haines Steveltstephenhainesfire-riskcomgt Kraus Dick ltpetrosafetyverizonnetgt Renkes BobltrrenkespeiorggtSent Mon Jun 10 2013 1112 amSubject 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 [mailtostephenhainesfire-riskcom] Sent Friday June 07 2013 155 PMTo Benedetti BobSubject 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 17-NFPA 30-2012 [ Section No 2744 ]) Please take a look word smith and circulate asyou see fit Thanks Stephen W Haines PE (PA NJ) CFEI

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

From Wayne GeyerTo Sully Curran Benedetti Bob stephenhainesfire-riskcom petrosafetyverizonnet rrenkespeiorgCc joiefolkersnovcomSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 13004 AM

As an fyi the following is what appears in the International Fire Code

570362 Design fabrication and installation of piping systems and componentsPiping system components shall be designed and fabricated in accordance with theapplicable standard listed in Table 570362 and Chapter 27 of NFPA 30 except asmodified by Section 5703621

TABLE 570362 PIPING STANDARDS

PIPING USE STANDARDPower Piping ASME B311Process Piping ASME B313Pipeline Transportation Systems forLiquidHydrocarbons and Other Liquids

ASME B314

Building Services Piping ASME B319

5703621 Special materialsLow-melting-point materials (such as aluminum copper or brass) materials thatsoften on fire exposure (such as nonmetallic materials) and nonductile material (suchas cast iron) shall be acceptable for use underground in accordance with theapplicable standard listed in Table 570362 When such materials are used outdoorsin above-ground piping systems or within buildings they shall be in accordance withthe applicable standard listed in Table 570362 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 accessibleremotely located valves

In all cases nonmetallic piping shall be used in accordance with Section 2746 ofNFPA 30

Wayne Geyer

From Sully Curran [mailtosullycurraaolcom] Sent Monday June 10 2013 124 PMTo bbenedettiNFPAorg Wayne Geyer stephenhainesfire-riskcom petrosafetyverizonnetrrenkespeiorg

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

From Wayne GeyerTo Benedetti Bob Robert RenkesCc Curran Sully Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion MaterialsDate Tuesday June 11 2013 125745 AM

There are so many different types of aboveground storage tank installations With this section Irsquomsure most people are thinking of large terminal facilities with the piping installed aboveground Butthe 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 plantsfor fleet fueling and for fuel storage for emergency power Aboveground shop-fab steel tanks usedfor motor vehicle fueling had to emulate a buried tank by code and were tested for two hours at2000 degrees I think it used UL 1709 as its basis and then became UL 2085 Wouldnrsquot it look unusual to have a UL 2085 fire rated AST connected to aboveground non-metallicpipe that is not fire resistant A lot of these tanks are installed closer to buildings and property linesdue to their construction That being said I have not seen non-metallic tank being usedaboveground for these applications but the Code does allow it Wayne Geyer

From Benedetti Bob [mailtobbenedettiNFPAorg] Sent Monday June 10 2013 1029 AMTo Robert RenkesCc Curran Sully Wayne Geyer Haines Steve Kraus DickSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials I know Thatrsquos always bothered me We should have some kind of definitive description orreference to a test From Robert Renkes [mailtorrenkespeiorg] Sent Monday June 10 2013 1124 AMTo Benedetti BobSubject RE NFPA 30 FLC-TAN Task Group Discussion Materials Do we need to say what we mean by ldquoresistantrdquo to damage by fire We donrsquot define resistant Bob Bob RenkesExecutive Vice PresidentGeneral CounselPEIP O Box 2380 Tulsa OK 74101918-494-9696 Follow me on Twitter

From Benedetti Bob [mailtobbenedettiNFPAorg]

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9

Public Comment No 2-NFPA 30-2013 [ Section No 21411 ]

21411

The materials of construction for tanks and their appurtenances shall be compatible with theliquid to be stored In case of doubt about the properties of the liquid to be stored thesupplier producer of the liquid or other competent authority shall be consulted Pipingmaterials of construction shall be in accordance with the requirements of Chapter 27Section 274 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 APIPetroleum Safety Consultan

Affilliation API

Submittal Date Fri Mar 01 085228 EST 2013

Copyright Assignment

I Richard Kraus hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation) Iunderstand and intend that I acquire no rights including rights as a joint author in any publication of the NFPA in which thisPublic Comment in this or another similar or derivative form is used I hereby warrant that I am the author of this Public Commentand 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 andthe terms and conditions contained therein I understand and intend that by checking this box I am creating an electronicsignature that will upon my submission of this form have the same legal force and effect as a handwritten signature

National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC

1 of 1 6112013 1149 AM

bbenedetti
Text Box
ATTACHMENT No A9