12,000+ Gallon Tanks and Fire Codes 1

[cwigg66]

I am having an issue with a local fire marshall in Mississippi. He cannot find any regulation or code that would allow me to use multiple 20,000 gallon tanks to store Jet-A fuel on an airport. My design calls for three 20K tanks. He has said that the limit on size is 12,000 gallons. These are single wall aboveground horizontal steel tanks. My problem is that he wants proof that I can use these tanks. Codes tell you what you CANNOT do, not what you CAn do. No fire code specifically forbids tanks larger than 12K except when double wall tanks are used. Anyone ever run into this problem before? Any help would be appreciated. By the way, he seems to be drawing info from IFC 2000 (Fuel Stations and Repair Garages Section) and is ignoring the AViation section). Thanks in advance.

Chris
Mechanical Engineer

 

[BigInch]

Do what I do with local officials, offer to bury them in their own paperwork.

First, check that your design is in accordance with DOD, Air Force requirements and all the CFRs quoted for "Aboveground Storage Tanks", here

http://www.afcee.brooks.af.mil/pro-act/fact/stortank.asp#3

Then have a look at this one, (309 pages) DOD
"MIL-Handbook-1022, Petroleum Fuel Facilities"
available for free at,

http://www.hnd.usace.army.mil/techinfo/misc/HD1022.pdf

Sorry about your weekend.

Going the Big Inch!

http://virtualpipeline.spaces.msn.com

 

[JStephen]

DFW Airport in the Dallas area has 6 or 8 tanks roughly 3 million gallons each. DIA in Denver has similar fueling facilities. Atlanta probably has similar facilities. I find that the airport at Jackson MS has 90,000 gallon capacity in 3 tanks:
"The existing fuel farm has a Jet-A storage capacity of approximately 90 thousand gallons, stored in three (3) above ground storage tanks."

From this document:

http://www.jmaa.com/uploads/document/JIA-Masterplan Doc.pdf

It may help to point out to him that what you are looking at is not especially large by airport standards.

I'm not familiar with IFC, but is there a section in it about fuel terminals (IE, like the gasoline terminals where they pipe gasoline in, load it on tank trucks, then haul to gas stations?) If so, would your facility fall under something like that rather than the aviation or gas-station sections?

 

[stookeyfpe]

Chris:

The code official is incorrectly applying the fire code. The code official is applying IFC chapter 22 that addresses motor vehicle fuel dispensing. Your not designing a service station - your designing an aviation fueling system. The applicable requirements are in IFC chapter 15 (I'm guessing on this one because I shutdown my fire code computer). NFPA 407 is the correct design document. NFPA 407 requires tanks to meet NFPA 30 so UL 142 aboveground storage tanks, regardless of volume, are perfectly acceptable in your application.

I am employed by the International Code Council, who publishes the International Fire Code (and other construction codes used in the US), as a Product Development Specialist and Fire Protection Engineer. Post an e-mail address or a telephone number and I will walk you through the codes. On Monday. Most everthing can wait until Monday.

I've went down this road a long time ago and I understand why the code official is confused. NFPA 30A currently doesn't exclusively exempt aviation fueling from the standard and I am aware of airports that use conventional motor vehicle fuel dispensing equipment for small aircraft. This is probably the source of your issue. The code official is regulating it a fuel dispensing operation (it is) but doesn't realize that airports are regulated by a different standard (i.e., NFPA 407).

NFPA 407 was developed for large aviation fueling systems like the DFW fuel hydrant system (400 GPM for 25 airplanes/hour). Your in Mississippi so I concluded your dealing with a small local or regional airport. However the requirements of NFPA 407, e.g., hoses meeting API 159, deadman controls, piping in accordance with ASME B31.3, etc. are applicable to your design

It has never been the intent of the NFPA 30A committee to regulate aviation fuel dispening. This problem will be fixed in the 2007 edition of NFPA 30A. Don't blame the regulator because your design is probably a first in his or her respective career.

I hope this helps ...

 

[BigInch]

Found this link from

http://www.search.mississippi.gov

hopefully it will help some,

http://msucares.com/pubs/publications/p1979.htm

Some petroleum storage tanks are regulated by federal and state laws, which apply to installing new tanks, modifying existing tanks, and closing or removing unused under-ground tanks. Currently, under-ground petroleum storage tanks holding 1,100 gallons or more and above-ground tanks holding 660 gallons (1,320 gallons in a combination of tanks) or more are regulated in Mississippi. Farm and residential storage tanks holding less amounts and used to store noncommercial motor fuel are not regulated. Because laws may change, contact the agencies listed on the back cover for updated information. Also, check locally for other laws or codes concerning petroleum storage.

Above-ground tanks subject to regulations are required to have a catch basin or other spill containment large enough to hold the volume of the largest tank plus anticipated rainfall to prevent overflow. [COLOR=black yellow]A written plan, approved by a professional engineer, showing steps to take in case of a spill also is required for above-ground petroleum storage tanks subject to regulations.[/color] For information on controlling a petroleum spill or to report a spill of any hazardous product, contact the Mississippi Department of Environmental Quality at (601) 961-5171 or (601) 352-9100.

Petroleum storage regulations (above-ground tanks)
U. S. Environmental Protection Agency, Region IV
Emergency Response and Removal Branch
345 Courtland St. NE
Atlanta, GA 30365
(404) 347-3931

Seems like this problem should have been discovered when the engineer was designing the installation.

http://www.deltafarm.net/reg.html#above

There are permitting requirements depending on the type of tank. An above ground tank that exceeds 660 gallons is required to have a Federal Spill Prevention Control and Countermeasure Plan (SPCC). This written plan addresses spill prevention measures and action to be taken in case a spill occurs. A containment wall is a part of the SPCC plan. Delta F.A.R.M. can provide landowners with an official document written by EPA that instructs individuals on how they can prepare a SPCC plan themselves.

Technical Assistance Contact:

Richard Ball
[COLOR=black yellow]Mississippi Department of Environmental Quality[/color]
(601) 961-5353"

Going the Big Inch!

http://virtualpipeline.spaces.msn.com

 

[stookeyfpe]

Those requirements are for an SPCC. That is different than the issues facing the original poster. His issue is the limitation on the tank volume and the incorrect application of NFPA 30A.

 

[JStephen]

There's not any indication in the original post that those issues weren't already taken care of.

 

[BigInch]

He (Fire Inspector) cannot find any regulation or code that would allow me to use multiple 20,000 gallon tanks to store Jet-A fuel on an airport.

If he had an EPA or PE approved design, he (Fire Inspector]probably wouldn't be asking that question, would he?
If those issues weren't already taken care of, why are they arising now? Or, maybe this is the permit phase and it is being taken care of now. Agreed, that was a supposition on my part. I don't really know what phase they're in.

Oh well, no harm in knowing too much.

Going the Big Inch!

http://virtualpipeline.spaces.msn.com

 

[stookeyfpe]

Based on the original message I understand that the design is completed and is most likely being reviewed for the required Fire Code construction permit. The design professional is encountering difficulty from the authority having jurisdiction (fire marshal). As I've stated this situation is probably the first time the fire marshal has reviewed a design using aboveground storage tanks for fueling of aircraft and he/she is applying NFPA 30A when the correct standard for this application is NFPA 407.

 

[cwigg66]

Hey guys. THANKS SO MUCH for all your input. The plans are in fact sealed by a PE. This fire marshall IS in fact very unfamiliar with large fuel farms and is just trying to cover his bases (understandable). Using your references I was able to link up references from all the applicable codes and send him a set of guidelines on this kind of thing. We'll see if it is going to be sufficient. He's a reasonable guy and like most fire marshalls, he's over worked and underpaid and has alot of idiots ot deal with. I intend to help him in any way I can. Thanks again for all your input. These forums are an invaluable resource for engineers and designers.

Chris

 

[BigInch]

Stookey, Yes. No worries. I agree with everything you've said. You're right on the money for sure. I was just trying to help get a sufficient volume of backup paper to pile along with it.

Good stuff then.

Going the Big Inch!

http://virtualpipeline.spaces.msn.com

 

[stookeyfpe]

Large Millimeter:

I agree that additional documentation is helpful. But as person who served as the AHJ for some large jurisdictions, I learned that reports with lots of extra fluff wore me out because it took so much longer to figure out what the desired outcome or goal.

With that said, I think the references to the SPCC serves several functions. It confirms that the containment structure has an adequate volume, that emergency response issues are at least contemplated, and a plan is in place for inspections of the tank and piping by the owner or his/her staff. This information is useful when attempting to gain the approval (and permit) from the Fire Marshal.

Chris, let us know how it comes out. Your approach is accurate and the Fire Marshal will appreciate your efforts. I can't count the number of times where I ended up performing the code analysis for the design professional who didn't even own a copy of the applicable standards because the owner was calling a deputy city manager or assistant fire chief, wondering why the project was not approved. You obviously were diligent in your design.