Report on Comments – June 2011
Rick Thornberry, The Code Consortium, Inc. 30-45 Revise the current text of 188.8.131.52.1 Protected Aboveground Tank as follows: 184.108.40.206.1 Protected Aboveground Tank. An atmospheric aboveground storage tank with integral secondary containment and thermal insulation that has been evaluated for resistance to physical damage and for limiting the heat transferred to the primary tank when exposed to a hydrocarbon pool fire and is listed in accordance with ASNI/UL 2085, Standard for Protected Aboveground Tanks for Flammable and Combustible Liquids, or an equivalent test procedure.
The Committee’s proposed revision to 220.127.116.11.1 Protected Aboveground Tank may satisfy the NFPA Manual of Style but will create potential confusion regarding the definition of “Protected Aboveground Tank” as compared to the definition for “Fire-Resistant Tank” in 18.104.22.168. Please note that the definition for “Fire-Resistant Tank” has been revised similarly by the Committee in Proposal 30-46. We have also submitted a Public Comment to that proposal to address our same concerns.
With the Committee’s revisions proposed to the definitions for “Protected Aboveground Tank” and “Fire-Resistant Tank”, the definitions are virtually identical, especially regarding the thermal insulation component of the definition as it deals with limiting the heat transferred to the primary tank when exposed to a hydrocarbon pool fire.
However, there are significant differences in the two test methods ANSI/UL 2085 for Protected Aboveground Tanks and UL 2080 for Fire-Resistant Tanks. Therefore, we are proposing to delete what we consider to be the requirement contained in the definition that specifies that the tank must be “listed”. We have also proposed to delete the phrase “or an equivalent test procedure” since we agree it is not needed. We believe the revisions we have proposed to the definition of Protected Aboveground Tank in 22.214.171.124.1 of the current NFPA 30 will satisfy the NFPA Manual of Style while also maintaining the distinction between a Protected Aboveground Tank and a Fire-Resistant Tank.
Printed on 9/16/2010