Report on Comments – June 2011
Rick Thornberry, The Code Consortium, Inc. 30-46 Revise the current text of 220.127.116.11 Fire-Resistant Tank as follows: 18.104.22.168 Fire-Resistant Tank. An atmospheric aboveground storage tank with 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 UL 2080, Standard for Fire Resistant Tanks for Flammable and Combustible Liquids, or an equivalent test procedure.
The Committee’s proposed revision to 22.214.171.124 Fire-Resistant Tank may satisfy the NFPA Manual of Style but will create potential confusion regarding the definition of “Fire-Resistant Tank” as compared to the definition for “Protected Aboveground Tank” in 126.96.36.199.1. Please note that the definition for “Protected Aboveground Tank” has been revised similarly by the Committee in Proposal 30-45. 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 “Fire-Resistant Tank” and “Protected Aboveground 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 UL 2080 for Fire-Resistant Tanks and ANSI/UL 2085 for Protected Aboveground 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 Fire-Resistant Tank in 188.8.131.52 of the current NFPA 30 will satisfy the NFPA Manual of Style while also maintaining the distinction between a Fire-Resistant Tank and a Protected Aboveground Tank.
Printed on 9/16/2010