Join Reinhard Hanselka as he answers your questions regarding various issues and hurdles facing code compliance projects. To submit a question to Reinhard, please click here.

Reinhard’s Code Corner: April  -  Codes and Standards for Generator Fuel Storage Tanks.

 

Welcome to the April edition of   the Code Corner. There have been several recent questions concerning the use of  Recognized Standards  for the construction and operation of fuel storage tanks for required Emergency and Standby Generators..

 There are always questions and concerns about which standards to follow and who publishes them. The standards often used are NFPA, ASME ANSI, API, FM, UL etc. Often there will be conflicts between them and even sometimes they will have conflicts with the State Building, Fire , Mechanical or Plumbing Codes.

If we  were to begin our research on how to install a fuel  tank for an emergency diesel generator, we would have a complex set of steps to take.  We would begin with the California Fire Code (CFC), California Building Code (CBC), California  Electrical Code (CEC), The California Mechanical Code (CMC) , and the Bay Area Air Quality Management District Guidelines . The CFC will prescribe proper separations, construction methods, fire and explosion mitigation safeguards. The CBC will indicate what type of occupancy and building safeguards. The CEC will instruct me how to use the vessel and safely interface with the Fuel Storage. The CMC will dictate to ventilation rates and vapor containment and extraction systems. The BAAQMD has guidelines and policies for system operation and installation of abatement systems.  If this sounds complicated for a simple little diesel tank , It is complicated and to further add to the confusion there are a variety of the above mentioned standards such as NFPA “ 110” (Emergency and Standby Generators), which apply directly to the installation.  How many total standards apply?  There are 36 recognized National Standards that apply!

 

QUESTION #1

I have a situation where my Engineer has cited a special API Standard for a solvent storage tank. My facilities manager states that the API ventilation standard is in conflict and not as stringent as the Fire Code requirement.  How do I proceed?

 

RESPONSE #1

The California Fire Code is Law. If anyone, including the engineer of record, on any project designs something in conflict with the published Codes the engineer must request either a Practical Difficulty or an Alternate Method for this specific issue.  The Alternate Method or Practical Difficulty Statement must be made in writing to the Authority Having Jurisdiction (AHJ).  The specific proposed alternate design must meet or exceed the intent of the adopted code, provide at least equivalent protection and must  be approved in writing by the AHJ.

 

Reinhard’s Code Corner: March – UPS /Battery Systems +

 

Virtually every building and facility in the Bay Area has some sort of emergency or back up power source. It may be an Emergency Generator as prescribed by NFPA 110 or it may be a simple battery pack on an emergency light to assure safe egress.

When we choose batteries as a back up power source, we must mitigate the hazards that batteries could impose.  Remember a battery is a source of substantial energy and often a container for toxic/highly toxic, Corrosive, reactive materials.

Stationary storage battery systems having an electrolyte capacity of more than 50 gallons, nickel-cadmium, valve regulated lead –acid (VRLA), lithium and lithium polymer batteries are regulated by the California Fire Code.

 

The required safety features include:

1. The batteries shall have venting caps to relieve pressure, which is often Hydrogen gas.

2. VRLA or other sealed non-venting caps shall be equipped with resealing flame arresting safety caps.

3. Lithium Ion and Lithium metal polymer batteries shall not require vented caps.

4. VRLA and Lithium –ion and lithium metal polymer battery systems shall be provided with a device or other approved method to preclude, detect or control Thermal runaway.

5. Battery systems shall be permitted in the same room or area as they equipment they support.

6. Battery systems shall be housed in a non-combustible locked cabinet or enclosure to prevent unauthorized personnel from accessing the system.

7. The battery rooms shall be located in an area separated from other occupancies by a one hour fire barrier.

8. Spill control and a means of spill response shall be provided.

9. An approved method of control and cleaning up the spill shall be provided.

10. Ventilation systems that ventilate the room or area at a minimum of 1 cfm/sq. ft. shall be provided on a continuous basis.

11. The ventilation system shall be designed to limit the maximum concentration of Hydrogen evolved from charging to 25% of the LEL or 1% Hydrogen.

12. Temperature Control shall be provided to maintain safe operating conditions of the batteries.

13. Signs and placards shall be appropriately posted.

14. Seismic protection shall be provided for the battery storage system at a 1.25 Importance factor

15. Approved smoke detection shall be provided.

 

I have done failure analysis on a small submersible Naval Craft, which had a thermal runaway failure in its battery system. The power source was Lithium Ion battery cells. The runaway condition was so complete that the vessel was a total loss.

Battery systems are necessary, respect them and follow the codes.

 

 

Code Corner: February

 

The Director of California Emergency Services, Chief Ruben Grijalva will resign his position in Sacramento and return to Santa Clara County as the Fire Chief of the City of Milpitas. Chief Grijalva will once again influence us all in Silicon Valley.

The 2009 Building Standards update is on the web. There will be some minor changes that correct some errata and address the issues of the L Occupancy and the utilization of PEX in California.

We a few good questions for the month of February.

 

QUESTION #1

I have a new UPS Room in my facility. What are the code requirements?

 

RESPONSE # 1

The fact that you have a UPS room may or may not be significant with respect to the Code Requirements. If your room has lead –acid batteries, then you are responsible for secondary containment and spill response equipment. The room will need ventilation at 1 cfm/sq.ft, a liquid tight floor and an alarm system.

If the power is supplied by NiCad, LiH, or Gel Cells, ventilation will be required, but no liquid spill equipment.

 

QUESTION #2

I have a small diesel tank that supplies fuel to an emergency generator. The tank is about 70 gallons and is steel. What are my responsibilities?

 

RESPONSE #2

Are you sure the tank is 70 gallons? If it is 59.9 gallons it is not a tank and will have few requirements.  At 70 gallons you must treat the tank as a fuel storage tank, and follow all the rules of an above ground motor fuel tank. If the tank is less than 60 gallons it is a drum with lower requirements. 

 

QUESTION #3

I am considering changing refrigerants in my small chiller. Any suggestions?

 

RESPONSE #3

Wow, why?  If you are simply changing refrigerants for lack of availability choose one that has a similar chemical structure. There is no difference in monitoring requirements they will be based on the PEL. . The abatement system will be dependant on the LC 50 and the discharge will be abated to less than ½ the IDLH.  I really need more info and the real reason for the change.

 

 

 

The 2008 code year was certainly dynamic. As individuals tried to understand the new California Codes, they found that the regulators were as confused about the lower standards of care. Seismic standards, building heights, allowable areas, and control area separations. These were just some of the areas of change. On another note the City of Fremont has recently retained my company to do expedited plan reviews and inspections.

 

2009 brings us some interesting New Codes. The L occupancy (previously discussed), a new NFPA 13 (Sprinkler Code) and a new NFPA 72( alarms) are among some of our new obligations. Remember, California has no provisions for “grandfathering”. You are either compliant or existing Non-compliant.

 

The New Year has brought us some member questions:

 

I have been told that the ASME B 31.3 Process piping code is Law in California. Our local Fire Department is trying to enforce it. What is up?

In order to properly enforce codes and to assure consistency throughout the United States the Fire Codes in Chapter 45 has referenced and acknowledged Standards. Among these standards are many of the ASME and NFPA Standards. ASME B31.3, ASME B31.1 and ASME BPE are directly referenced in the Fire and Building Codes.   These codes are also enforceable with the same authority as the base Codes within the State of California. The local Fire Agency has the responsibility to enforce all referenced Codes and Standards. If an Agency wants to use a Nationally Recognized Standard not published in the Adopted Fire Code, The agency must inform the Business before a design is initiated.

 

We are installing a new process. This process will generate some fumes which may not be compatible with our current exhaust system. Can I combine these outside the building?

Yes.  The Mechanical Code specifically applies to processes and exhaust streams within the building envelope. As long as the emission complies with the BAAQMD requirements and the resultant mixture is not detrimental the the duct,  feel free to proceed.

 

 

 

Interpretations

The Holiday Season is now upon us. On January 1, 2009 several major and minor code changes will become law.. Many errata in the codes will be corrected and most importantly the New “L” Occupancy will officially be a code option for all laboratory users in the State. If you occupy a building of 3 or more stories this should be an option to consider. If you have current control areas and they are unchanged to can remain forever. If you attempt construction, TI or a remodel your current control areas may need to be upgraded throughout the building, including the possibility of upgrading all floors and walls to a two hour rating. The only recommendation I can offer is to be cautious on any construction process. Do not jeopardize what you have.

 

We have several insightful questions.

 

I was told that I need to have my backflow valves checked again in January. The water district just finished certifying the main valve on the street. What are my obligations?

All Backflow devices that serve a potable water line must be certified annually by a trained individual. The individual must be trained in accordance with ASSE or AWWA per the 2008 California Plumbing, Mechanical and Fire Codes.   The law allows no exception; they must be tested and certified annually.  Additionally the backflow valves associated with flammable liquid vessels and hazardous waste vessels must also be certified functional.

 

I recently had a Fire Inspection and was told that I Cannot store or even use the red plastic gas cans I have been using for years. The ones that I purchased say they are approved right on the cans. Can the local Fire Inspector override an approved can?

Unfortunately Yes. The local Fire Department is the authority having jurisdiction in you City.. The California Fire Code in Chapter 34 limits all materials of construction with respect to flammable storage. I might suggest that you can request permission to store the flammable liquid in the plastic containers if they are in a storage container or outside or if for some reason the plastic containers are chemically unsuitable. Begin a dialog and ask. Questions.

 

Our company utilizes large amounts of hydrogen in our factory. Our policy was always to segregate our gases by hazard class. Since hydrogen is non-toxic do. Do we need an enclosure around the piping?

Technically no.  Hydrogen has no toxicity. Its only hazard is flammability and explosion. So as long as there are no mechanical connections no monitoring is requires for welded tubing.  However wherever a mechanical joint or valve occurs you will need to monitor for Hydrogen in an effective manner.

 

 

The Month of November brings us a lull in code development, as we change to standard time and get ready for the shorter winter days. This month has brought us several questions, which we will attempt to fully address.

 

I am a plumbing engineer and recently on a design, I received a plans check comment about utilizing the wrong code section... I designed a plumbing system and specified ASME A 13.1 – 2007 for all the pipe labeling. The Fire Marshal wrote a comment that I must use ASME A 13.1 2002 edition... Can I not use the latest Standard?

No. Even though there may be a more recent edition of a certain standard. The standard adopted by the State of California is published in the 2007 California Fire Code, Chapter 45andc that is ASME A 13.1 2002.  If you contact a code official and request to use a newer version of any standard he or she may allow you to do so, but the base code requires the 2002 published standard.

 

We are being required by the local Fire Marshal to place NFPA Labels on any cabinet which stores acids or bases. These chemicals do not burn. Also containers and especially secondary containers of flammables and hazardous materials require proper labeling per CALOSHA and the Hazardous Communication Standard. NFPA Labels are only one of many systems available. Please clarify my situation.

The requirement for labeling of chemicals does come from the California Fire Code Chapter 27 and 34 and CAL OSHA and HAZCOM.  It is correct there are many overlapping rules and regulations. Some of the regulations are intended to be used by both, your employees and potential emergency responders. I urge you to work with and follow the instructions and policies of your local Fire Department.  In urban California local Fire Departments are the primary regulatory authority and more importantly are your emergency responders. You should ask for clear policy directions from your local Fire Marshal and train your employees accordingly.

 

I had a recent fire inspection. A local Inspector asked us to open our acid storage cabinet. She told us to remove the Acetic Acid and put it into the flammable storage cabinet. We did what she said, but is she correct in her requirement?

Absolutely. Your inspector understood her chemistry. Acetic Acid is an Organic Acid that has as high BTU content as Diesel fuel.  It is a combustible liquid with a flash point of 103oF. At 100oF it would be a flammable liquid. Remember acids are  a broad category- Reducing Acids such as HCl (hydrochloric), oxidizing acids such as HNO3 (nitric) and organic acids such as acetic.  For storage compatibility of the material to its surroundings is what is important.

 

 

 

The New “L” – Occupancy and Questions?

The California Building Standards Commission had their regularly scheduled meeting on September 16, 2008. The agenda was dominated   by the Office of the California State Fire Marshal (SFM)... The main subject brought forward was the new and recently developed L (Lab) Occupancy.

 

The new L Occupancy was approved in a split decision. This occupancy is specifically aimed at laboratories above the third floor.  On the 4th floor all control areas are greatly limited (12.5%) in allowable chemistry. The use as a lab is very limited.  The new building code also requires the construction of 2 hour horizontal floor separations above the third floor and structural reinforcement to the FOUNDATION. That’s right for a new control area above the third floor I need to reinforce the structural members to a full two hour fire resistance and of course the floor itself to two hour fire resistance and all penetrations to two hours. Many Commercial buildings in the Bay Area are Type III -1 Hour.  They are non conforming to the new code.

 

By the way, the control area chemistry is limited to 12.5 % of the base allowable.  So those buildings without the application of an L Occupancy would   be reverted to Chemical Free Office Buildings. The L Occupancy will become very popular around the Bay Area.

Additionally ,the SFM Office issued a memorandum regarding existing Control Areas. If your control area was legally in existence  before this new  Code went into effect on January 1, 2007, the control area can be maintained with the One hour separations that were required under the Old Code.

 

The Month of October brings us a few good questions from our Members:

 

I recently had a routine Fire Inspection. The Inspector indicated our Process Piping needed to conform to the 2007 California Mechanical Code, Chapter 14. Can a Fire Guy use the Mechanical Code?

With the adoption of the International Series of Codes, the piping and process piping regulations were severely diluted.  California adopted the Uniform Mechanical Code, which is written by IAPMO.  IAPMO maintained Chapter 14, which regulates all process piping in the State. The Fire Code references the Mechanical Code and that makes it absolutely appropriate for a Fire Inspector to reference.

 

We are doing a small expansion in our facility. Our Architect indicated that we should use an H-4 Occupancy. Can I have Chemicals with physical hazards in an H-4 or just Health Hazard Chemicals?

Yes!  An H -4 Occupancy is designed to be an occupancy that mitigates the hazards posed by Health hazard materials. This doesn’t mean that there can be no physical hazards in the Occupancy. It does mean that you cannot go over the allowable chemical loading of Physical Hazard Materials (listed on the table). The amount of Health Hazard Materials is UNLIMITED.  For example I can have all of the Sodium Cyanide(Highly Toxic) I needed but, my use and storage of flammable liquids would be limited to the allowable quantity.

 

 

 

Hearings and More.

The summer season is over, the kids are back to school and the new code hearings are upon us.. On September 17th the California Building Standards Commission will hold public hearings on several code topics. The most interesting is the final approval of the L Occupancy as modified. The CA State Fire Marshal’s Office will advocate full acceptance and application to all businesses in California, not just State Regulated facilities. The University of CA and several local agencies have already allowed laboratories to be built.

 

At the end of this month the ICC (International Code Council) will be holding open code hearings in Minneapolis. A variety of code changes in the Model Building Code will be advocated by Government Representatives and Special Consultants. This will be the 2009 I Code, which will then be the basis of the 2010 CBC and CFC.

The month of September brings us several good questions.

 

We are being required by our local Fire Marshal to place NFPA 704 labels on any storage cabinet containing Hazardous materials, including Flammable cabinets or containers that contain Hazardous materials. This includes squeeze bottles jugs, gas cylinders--- every damn thing. Help!

Your local Fire Marshal or more likely you local inspector can ask you to label anything he or she wants; however, there are guidelines and the Authority of Law... The 2007 CFC section 2703.5.1 indicates that any room or storage facility or container should be labeled in accordance with 2004 NFPA 704. All rooms or areas must be labeled; all cabinets and container shall be labeled with the chemical contents. For example, if I had a squirt bottle of IPA (Isopropyl Alcohol) should say IPA. A placard would be 1 – 3 – 0. Any reasonable person would prefer to see the specific contents. Negotiate with your Inspector.

 

During a routine Final Inspection of a Building remodel, a zealous local Electrical Inspector wrote up a clean room we had installed in one of the bays. He spent more time on the modular clean room that the small addition he came to inspect. He actually wrote up the clean room and indicated we would be penalized for” Construction without a Permit” and double fees. He did not even final our small addition. Can he hold us hostage?

Yes! You invited the inspector in! He or she clearly saw the new un-permitted Clean room module during the course of his scheduled work. He or she is absolutely within their authority to withhold any final on any part of your structure. You were caught. My strong suggestion is to pay the double fees and respectfully ask for a re-inspection of your project.

 

I am working on the design of a Mechanical Ventilation System to be used in lieu of a deflagration venting system. As part of the design I will be providing standby power. I wish to treat this as non required systems in accordance with NEC Article 700. Are the conductors required to be fire resistant, such as circuit integrity cable?

Wow. Hold everything. Whenever you deviate from the code it must be done as an Alternate Means or Method. You must work with your local Building Department and respectfully request that your proposal be accepted as an equivalent to what is required by code. If I were your AHJ the answer would be yes the conductors would have to be fire resistant and you would be filing a request for Alternate Means or Method (AM&M)

 

 

The Dog Days of August brings us to a Hot Code time with respect to changes. There are a large number of changes that will go before the California Building Standards Commission. These changes will clarify and correct the many errors that have been found and documented in the 2007 CBC and CFC.

 

This session will also be the final hearing for the L Occupancy in its developed form. In the mean while, Industry has lobbied the State Legislature to broaden the powers of the office the State Fire Marshal. This column will continue to bring AFE Readers up to date on changes to the State Model Codes. The Month of August has brought us a few good questions and situations.

 

What are the requirements for the air abatement systems for vacuum pumps that service Nitride, poly and LTO processes. Our current system exhausts to a “burn box” then to a fume scrubber. Is this legal?

Non-soluble emissions that are currently directed to burn boxes and then to and then to an abatement system , are no longer regulated by the 2007 CFC. The new Fire Code only requires abatement for Highly Toxic gases and then only for emergency conditions.   Toxic or Other Hazardous Gases are not required to be abated. Our local BAAQMD has substantial requirements for BACT (Best Available Control Technologies) for all “Noxious Emissions”.

 

Our Facility has several HPLC Units. We currently use small bottles to contain and deliver the HPLC Solvents to the unit. We drain the spent solvents to a poly container located at the base of the lab bench. Our Fire Inspector indicated that our process is not legal and needs to be stopped. What are our responsibilities?

First one must consider the hazards of the HPLC Solvents. The solvents are generally Flammable and potentially corrosive. As long as the volume of the solvents is under 1 gallon , we can dispense from Glass Containers. If larger than 1 gallon then metallic containers are required. Now the fact that you drain the waste solvent into polyethylene containers, on the floor is a dangerous and non-code compliant practice. The Fire Code indicates that flammable solvents shall not be contained in low melt point materials.   The melt point of Polyethylene is about 300oF and contains about 19,950 btu’s per pound. Any materials that has a melt point under 1981oF is considered Low Melt point and cannot be used for flammable liquids.

 

 

Hydrogen Questions

For the month of July, I have accumulated two pertinent questions and situations from our readers that deal with hydrogen.

Hydrogen is a wonderful clean fuel. It is a gas at room temperature and burns quite well with an LEL (lower explosive limit) of 4 % and an upper explosive limit of 75%. It is stoichiometrically positioned to explode at 8.0% and must be respected. It has a low specific gravity and an extremely high diffusivity constant. In an ambient environment the product of combustion is water (H2O). What a great fuel.

 

As far as the code is concerned, it is a flammable gas with no health effects. The diffusion constants are so high that it is very difficult to get a collection of the gas in a room or area –the perfect fuel.

 

The regulation of this gas is primarily collected in NFPA 55, 2007 California Fire Code (CFC) Chapters 30 “Compressed Gases” and Chapter 35 “Flammable Gases.” All regulations are straight-forward and logical.

 

I have been requested to do a plume analysis for a hydrogen vent in my facility. Is this a normal request?

Hydrogen has no toxicity. People-exposure is never an issue. The explosive potential and re-entrainment potential exist. You should retain an experienced engineer to observe your discharge practices to ensure that the hydrogen is properly discharged into the turbulent area above the structure.

 

We use hydrogen in our labs and store the spare bottles and empties outside. Do we need a monitor for hydrogen use in our lab? We also use a short length of PE tubing to dispense the hydrogen. Any issues?

Yes. The 2007 California Mechanical Code requires you to monitor hydrogen wherever it is used and dispensed in a building or structure. Your monitor should be set at a minimum of 25% of the LEL or 1% hydrogen. You should monitor at a high place where a leak might accumulate.   Now the dispensing of any dry gas will cause a static charge to build in most tubing. This can be catastrophic for hydrogen. The tube should be metallic or be a steel braided tube with a liner.

 

 

 

 

 

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