NFPA 30 FLC-OPS Public Comment Report. Public Comment No. 41-NFPA [ Section No [Excluding any

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88 of 224 9/6/2016 1:13 PM Public Comment No. 41-NFPA 30-2016 [ Section No. 18.5.4 [Excluding any Sub-Sections] ] The quantity of liquid located outside of identified storage areas, such as storage cabinets, other inside liquid storage areas, general-purpose warehouses, or other specific processing areas that are cut off from the general plant area by at least a 2-hour fire separation in operational areas separated from dedicated storage areas in accordance with Section 9.9, or separated from specific processing areas in accordance with Section 17.6, shall meet the requirements of 18.5.4.1. Statement of Problem and Substantiation for Public Comment Provides clearer lead-in text for the quantity limits in 18.5.4.1, coordinates with the proposal to Section 11.3, and adds reference to related requirements in Chapters 9 and 17. Related Public Comments for This Document Related Comment Public Comment No. 39-NFPA 30-2016 [Section No. 11.3] Public Comment No. 43-NFPA 30-2016 [Section No. 18.5.4.1] Related Item Committee Input No. 107-NFPA 30-2015 [Section No. 18.5.4] Relationship Complement each other. Submitter Information Verification Submitter Full Name: Alwin Kelly Organization: Jensen Hughes Affilliation: N/A Street Address: City: State: Zip: Submittal Date: Fri May 13 14:30:46 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-102-NFPA 30-2016 Statement: The changes to section 18.5.4 establish MAQs for incidental operations and incidental use that are coordinated with the MAQs given in section 9.6 for storage. These new MAQs parallel those given in model fire codes. The new MAQs replace the prior quantity limits which permitted significantly greater amounts of Class I flammable liquids in operating areas than would have been permitted by section 9.6 for storage areas (which are generally in closed containers). Page 1 of 11

89 of 224 9/6/2016 1:13 PM Page 2 of 11

90 of 224 9/6/2016 1:13 PM Public Comment No. 43-NFPA 30-2016 [ Section No. 18.5.4.1 ] Page 3 of 11

91 of 224 9/6/2016 1:13 PM 18.5.4.1 Page 4 of 11

92 of 224 9/6/2016 1:13 PM The maximum quantity of liquids permitted for incidental operations in a single fire area shall not exceed the greater of the following: (1) * The amount required to supply incidental operations for one continuous 24-hour period, provided the hazard analysis required in Chapter 6 accounts for these quantities. (2) The aggregate sum of the following in containers : 25 10 gal ( 95 38 L) of Class IA liquids in containers 120 30 gal ( 454 115 L) of Class IB, and/or Class IC, Class II, or Class III liquids in containers 1585 30 gal ( 6000 115 L) of any combination of the following: Class IB, IC, II, or IIIA liquids in metal portable tanks or metal intermediate bulk containers, each not exceeding 793 gal (3000 L) (3) Class II or Class IIIA liquids in nonmetallic intermediate bulk containers, each not exceeding 793 gal (3000 L) (4) 20 portable tanks or intermediate bulk containers each not exceeding 793 gal (3000 L) of Class IIIB liquids Page 5 of 11

93 of 224 9/6/2016 1:13 PM liquids (b) 80 gal (303 L) of Class IIIA liquids (c) 3,300 gal (12,500 L) of Class IIIB liquids 18.5.4.1.1 The quantities in 18.5.4.1(2) shall be permitted to be increased 100 percent where stored in approved flammable liquids storage cabinets or in safety cans in accordance with the fire code. 18.5.4.1.2 The quantities in 18.5.4.1(2) shall be permitted to be increased 100 percent in buildings equipped throughout with an approved automatic sprinkler system installed in accordance with NFPA 13, with protection at least equivalent to that for Extra Hazard (Group 2) occupancies. 18.5.4.1.3 Where both 18.5.4.1.1 and 18.5.4.1.2 are applicable, the increase shall be permitted to be applied accumulatively. Additional Proposed Changes File Name Description Approved NFPA_30_- _proposed_revisions_to_section_18-5-4.docx Microsoft Word 2013 version document with track changes to code text. Statement of Problem and Substantiation for Public Comment Coordinate quantity limits for incidental operations (potentially open use of liquids) with the storage maximum allowable quantities (MAQs) in NFPA 30 Chapter 9, and the MAQ in fire codes (including IFC). IFC open use scenarios are considered to be comparable to the NFPA 30 incidental operations scenarios. The prior quantity limits in 18.5.4.1 potentially permitted significantly greater quantities of Class I liquids in incidental operational areas than permitted in Chapter 9 for storage areas, which are generally closed containers. Related Public Comments for This Document Related Comment Public Comment No. 41-NFPA 30-2016 [Section No. 18.5.4 [Excluding any Sub-Sections]] Public Comment No. 39-NFPA 30-2016 [Section No. 11.3] Related Item Committee Input No. 107-NFPA 30-2015 [Section No. 18.5.4] Relationship Parent and child sections Complementary content Submitter Information Verification Submitter Full Name: Alwin Kelly Organization: Jensen Hughes Affilliation: N/A Street Address: City: State: Zip: Page 6 of 11

Proposed revised and new text for NFPA 30 Section 18.5.4 18.5.4 The quantity of liquid located in operational areas separated from outside of identified dedicated storage areas in accordance with Section 9.9, such as storage cabinets, other inside liquid storage areas, general-purpose warehouses, or other separated from specific processing areas that are cut off from the general plant area by at least a 2-hour fire separation in accordance with Section 17.6, shall meet the requirements of 18.5.4.1. 18.5.4.1 The maximum quantity of liquids permitted for incidental operations in a single fire area shall not exceed the greater of the following: (1)* The amount required to supply incidental operations for one continuous 24-hour period, provided the hazard analysis required in Chapter 6 accounts for these quantities. (2) The aggregate sum of the following in containers: 25 10 gal (95 38 L) of Class IA liquids in containers (b) 120 30 gal (454 115 L) of Class IB, and/or Class IC liquids, (c) 30 gal (115 L) of Class II liquids, or Class III liquids in containers (d) 80 gal (303 L) of Class IIIA liquids (e) 3,300 gal (12,500 L) of Class IIIB (c) 1585 gal (6000 L) of any combination of the following: i. Class IB, IC, II, or IIIA liquids in metal portable tanks or metal intermediate bulk containers, each not exceeding 793 gal (3000 L) ii. Class II or Class IIIA liquids in nonmetallic intermediate bulk containers, each not exceeding 793 gal (3000 L) (d) 20 portable tanks or intermediate bulk containers each not exceeding 793 gal (3000 L) of Class IIIB liquids Formatted: Strikethrough Formatted: Strikethrough Formatted: Strikethrough Formatted: Strikethrough Formatted: Strikethrough 18.5.4.1.1 The quantities in 18.5.4.1(2) shall be permitted to be increased 100 percent where stored in approved flammable liquids storage cabinets or in safety cans in accordance with the fire code. 18.5.4.1.2 The quantities in 18.5.4.1(2) shall be permitted to be increased 100 percent in buildings equipped throughout with an approved automatic sprinkler system installed in accordance with NFPA 13, with protection at least equivalent to that for Extra Hazard (Group 2) occupancies. 18.5.4.1.3 Where both 18.5.4.1.1 and 18.5.4.1.2 are applicable, the increase shall be permitted to be applied accumulatively. Page 7 of 11

94 of 224 9/6/2016 1:13 PM Submittal Date: Fri May 13 14:59:15 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-102-NFPA 30-2016 Statement: The changes to section 18.5.4 establish MAQs for incidental operations and incidental use that are coordinated with the MAQs given in section 9.6 for storage. These new MAQs parallel those given in model fire codes. The new MAQs replace the prior quantity limits which permitted significantly greater amounts of Class I flammable liquids in operating areas than would have been permitted by section 9.6 for storage areas (which are generally in closed containers). Page 8 of 11

95 of 224 9/6/2016 1:13 PM Public Comment No. 28-NFPA 30-2016 [ Section No. 19.7.2.2.2 ] 19.7.2.2.2 Nonmetallic cooking oil storage tanks shall meet the following requirements:tanks shall be listed for use with cooking oil, unless otherwise approved.tanks in accordance with UL 2152, Outline of Investigation for Special Purpose NonMetalic Containers and Tanks for Specific Combustible or Noncombustible Liquids. Nonmetalic tanks shall not exceed 200 gal (757 L) per tank. Statement of Problem and Substantiation for Public Comment Public Comment The committee raised 2 points at the 1st Draft meeting, which we have responses to, for re-consideration of the original proposal (PI#79) to reference UL2152 in the Code body under 9.7.2.2: The standard has not yet been published - Since discussion of this proposal at the first draft meeting, UL2152 was published on October 2, 2015 so is no longer a draft document, and is available for members to verify the comprehensive tank requirements developed in collaboration with this technical committee during the last Code cycle to support revisions to the new Ch 19.7. The proposal would eliminate the opportunity for other listings - First, there is no other standard currently available to address the specific use of nonmetallic tanks for the storage of new or used cooking oil in restaurants or similar commercial food preparing applications having engineered transfer systems. We worked with industry, the fire service and this committee to develop the UL2152 requirements, and one manufacturer has already been Listed to them. Second, UL has a number of product safety standards adopted in the NFPA family of codes, and this does not eliminate the opportunity for other product certifiers, who are competitors of UL, to test to UL standards and certify products, which is done on a regular basis. Nor does it prohibit anyone else to propose addition of another standard with an equivalent level of safety, should it exist in the future. Related Item Public Input No. 79-NFPA 30-2015 [Section No. 19.7.2.2] Submitter Information Verification Submitter Full Name: Ronald Farr Organization: UL LLC Street Address: City: State: Zip: Submittal Date: Wed May 11 14:41:59 EDT 2016 Committee Statement Committee Action: Accepted Page 9 of 11

96 of 224 9/6/2016 1:13 PM Resolution: SR-101-NFPA 30-2016 Statement: When section 19.7 was originally adopted in 2015, no listing requirements existed for nonmetallic cooking oil storage tanks. This situation has been remedied with the development of UL 2152, and it is therefore appropriate to reference it here. Page 10 of 11

97 of 224 9/6/2016 1:13 PM Public Comment No. 40-NFPA 30-2016 [ Section No. 19.7.2.2.2 ] 19.7.2.2.2 Nonmetallic cooking oil storage tanks shall meet the following requirements:tanks shall shall be listed for use with cooking oil, unless otherwise approved.tanks shall in accordance with UL 2152, Outline of Investigation for Special Purpose Nonmetallic Containers and Tanks for Specific Combustible or Noncombustible Liquids. Nonmetallic tanks shall not exceed 200 gal (757 L) per tank. Statement of Problem and Substantiation for Public Comment Public Input No. 79-NFPA 30-2015 [Section 19.7.2.2] was rejected by the Committee because the standard referenced, UL 2152, had not been issued at the time. This standard has since been issued. This Public Comment proposes that the language from PI-79 be reinstated, as doing so will simplify the code enforcers ability to determine compliance to construction and performance criteria listed in the code. Related Item Public Input No. 79-NFPA 30-2015 [Section No. 19.7.2.2] Submitter Information Verification Submitter Full Name: Andrew Burke Organization: Restaurant Technologies Inc Street Address: City: State: Zip: Submittal Date: Fri May 13 14:29:35 EDT 2016 Committee Statement Committee Action: Rejected Resolution: This comment is addressed by SR#101. Page 11 of 11