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
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
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
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
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
22411
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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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3 of 8 632013 1037 PM
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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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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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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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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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
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
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
Ballot Results
This item has not been balloted
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1 of 1 632013 1042 PM
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
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
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
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
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
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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22411
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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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3 of 8 632013 1037 PM
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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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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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
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
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
Ballot Results
This item has not been balloted
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1 of 1 632013 1042 PM
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
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
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
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
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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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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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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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
This item has not been balloted
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1 of 1 632013 1040 PM
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
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
Ballot Results
This item has not been balloted
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1 of 1 632013 1042 PM
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
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
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
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
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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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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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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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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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
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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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Ballot Results
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1 of 1 632013 1041 PM
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
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
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
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
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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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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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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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
Ballot Results
This item has not been balloted
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1 of 1 632013 1040 PM
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
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
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
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
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
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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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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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
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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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
Ballot Results
This item has not been balloted
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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
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
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
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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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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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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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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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
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
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
Ballot Results
This item has not been balloted
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1 of 1 632013 1042 PM
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
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
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
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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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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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
Ballot Results
This item has not been balloted
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1 of 1 632013 1040 PM
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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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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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
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
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
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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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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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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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
National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC
1 of 1 632013 1040 PM
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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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
This item has not been balloted
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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
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
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
This item has not been balloted
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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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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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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
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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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
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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Ballot Results
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1 of 1 632013 1041 PM
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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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
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
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
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
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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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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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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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
National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC
1 of 1 632013 1040 PM
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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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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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
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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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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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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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
Ballot Results
This item has not been balloted
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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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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
Ballot Results
This item has not been balloted
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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
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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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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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
This item has not been balloted
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1 of 1 632013 1040 PM
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
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
Ballot Results
This item has not been balloted
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1 of 1 632013 1042 PM
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
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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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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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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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
National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC
1 of 1 632013 1040 PM
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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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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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
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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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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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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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
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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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
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
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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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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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
Ballot Results
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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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Ballot Results
This item has not been balloted
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1 of 1 632013 1041 PM
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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Ballot Results
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1 of 1 632013 1042 PM
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
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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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
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
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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
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
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
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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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
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
This item has not been balloted
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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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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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Ballot Results
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1 of 1 632013 1042 PM
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
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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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
This item has not been balloted
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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
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
Ballot Results
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1 of 1 632013 1042 PM
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
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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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
This item has not been balloted
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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
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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Ballot Results
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1 of 1 632013 1042 PM
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
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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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
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
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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
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
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
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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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
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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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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
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
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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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
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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Ballot Results
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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
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
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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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
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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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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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
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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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
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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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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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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
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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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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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
National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC
1 of 1 632013 1040 PM
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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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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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
This item has not been balloted
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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
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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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
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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
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
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
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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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
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
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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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
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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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
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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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
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
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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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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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
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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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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1 of 1 632013 1042 PM
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
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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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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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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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
Ballot Results
This item has not been balloted
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1 of 1 632013 1042 PM
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
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
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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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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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
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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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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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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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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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
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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1 of 1 632013 1053 PM
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
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
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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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
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
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Ballot Results
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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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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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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
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
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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
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
Ballot Results
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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
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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1 of 1 632013 1040 PM
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
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
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
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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1 of 1 632013 1053 PM
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
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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
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
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
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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1 of 1 632013 1053 PM
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
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
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
National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC
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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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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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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
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
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
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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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
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
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
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
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
National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC
1 of 1 632013 1041 PM
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
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
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
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
National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC
1 of 1 632013 1041 PM
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
National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC
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
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
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
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
National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC
1 of 1 632013 1041 PM
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
National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC
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
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
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
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
National Fire Protection Association Report httpsubmittalsnfpaorgTerraViewWebFormLaunchid=TerraViewC
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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 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
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
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
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
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