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March/April 2008

Just Ask: Codes and Standards Snapshot
NFPA 30, Flammable and Combustible Liquids Code

NFPA Journal® Online Exclusive,  March 2008

By Lisa Nadile

One of the NFPA standards most responsive to the changing environmental climate, NFPA 30, Flammable and Combustible Liquids Code , is looking at major evolution in light of the strong push for green manufacturing operations and the increased interest in bio-fuels. The 2008 edition of NFPA 30 sets the stage for these developments and is one of the first standards to be reorganized according to the NFPA hazmat template.

NFPA Journal spoke to the standard’s staff liaison, Robert Benedetti, NFPA’s senior flammable liquids engineer, who is seeing heightened interesting NFPA 30, thanks to the current political climate.

LN: Why did this standard come into existence in 1913?

RB: In 1913, the gasoline engine was just starting to come into use, vehicles were just starting to come into use, and people were switching from burning wood to burning kerosene in heaters. There was a need to address the increasing use of hydrocarbon-based fuels.

LN: As it evolved, how has its role changed?

RB: We are [predominately] a petroleum-based economy, and a lot of what’s in NFPA 30 came out of the petroleum industry and the petrochemical industry, in terms of understanding the hazards and how to deal with them. It’s just a reflection of the fact that the world runs on fuels, and fuels burn. A lot of them are flammable liquids. There are also flammable gases, so you saw the development of NFPA 30 for liquids and NFPA 58, Liquefied Petroleum Gas Code, and NFPA 54, National Fuel Gas Code, for the flammable gases that are used as fuels.

LN: Who uses NFPA 30?

RB: Enforcing officials. Anybody who works in the chemical industry is going to use NFPA 30. Manufacturers of products that either use flammable liquids in their manufacturing or who make products that are themselves flammable, like inks or paints.

LN: What has been the major growth point in the standard?

RB: Since 1986, which is when I started working on this standard, the biggest issue has been the development of the mandatory fire protection design information for warehouses that store flammable or combustible liquids. A disastrous paint warehouse fire in 1987 in Dayton Ohio, one that completely destroyed the building and all its contents, triggered a number of programs of full-scale fire testing in warehouses, and all of the information from that testing has found its way into NFPA 30 in what is now Chapter 16, which tells you how to properly protect a warehouse. In terms of bulk storage and storage tanks, most of the key improvements in technology have been with the development of what I would call “new technology” aboveground storage tanks:  fire resistant and protected tanks. These were developed to meet a shift away from underground tanks for small facilities that could not afford the environmental protection insurance that you normally have to carry for an underground tank.

LN: So insurance interests in a sense shaped the industry.

RB: Yes, but not fire protection insurance, not fire insurance. This was for environmental protection. This was insurance that covered you if you had a tank underground that was involved in a release to the environment. So it covered the cleanup.

LN: Is that unique to NFPA 30 that the standards had to evolve or adjust to environmental insurance or other insurance issues?

RB: That I can’t answer. It’s been a big issue with us as far as bulk storage tanks are concerned. And we’ve made some changes in our spill control requirements, so that we’re not out of step with the Environmental Protection Agency’s Spill Prevention, Control, and Countermeasure (SPCC) rules.

LN: That’s a unique issue.

RB: Unique in the sense that it’s something that NFPA historically has not addressed, but it does have an impact on fire safety. In order to solve the environmental problem related to underground storage tanks­, some small operators decided to get rid of their underground tanks and go to aboveground tanks. From a fire protection standpoint, the tanks were safer underground. There’s only one case that I know of where there was a very severe incident with an underground tank, and a lot of things have to go wrong for there to be a problem.

Typically, underground tanks are very safe, and they are widely used. Every gasoline station has two, maybe three, if they’re selling diesel, as well. In an urban area, land being as expensive as it is, that’s where that tank is going to go, maybe at the behest of state fire prevention rules. In an urban area, because of set-back requirements, there might not be enough room to put those tanks above ground.

LN: How does NFPA 30 relate to other standards? Does it affect, or is it affected by, NFPA 101 or other standards?

RB: Probably not NFPA 101 so much. NFPA 1, Uniform Fire Codeä, probably more than anything else. [Also NFPA 70^â, National Electrical Code^â,] because if you’re dealing with flammable liquids, you have to provide special electrical equipment, and that reflects back to the electrical code. We’ve done part of [the recent] major rewrite to NFPA 30 to correlate and dovetail with NFPA 5000^â, Building Construction and Safety Code^â, and other model building codes so that we are now using the concept of maximum allowable quantities and control areas to regulate how much flammable liquid can be in a single building and where it can be located.

LN: You mentioned the Dayton , Ohio fire in 1987. In the past 10 years have there been any incidents that have changed this standard or influenced its evolution?

RB: Not really. There are lots of little fires, and there will continue to be lots of little fires. There was a major [storage tank] incident in 2005 in the UK at Buncefield. That one will have impact on NFPA 30. This incident is still being studied today, and it will definitely result in some changes to the overfill prevention requirements in NFPA 30 and other codes.

LN: Let me get back to that. When someone reads NFPA 30, what are they equipped to do. What do they know once they’ve read it.

RB: Well, it depends on what it is you’re looking for in the code. Generally, you’re looking at NFPA 30 for one of three reasons: You’re involved with warehousing containers, you’re involved with bulk storage and storage tanks, or you’re involved in operations that deal with flammable and combustible liquids. Then there are some people, like the authorities having jurisdiction (AHJs), who have to be cognizant of everything in NFPA 30. Generally, the typical inspector deals with relatively low-level storage in the storage room or warehouse and maybe some small distribution facilities in terms of bulk storage tanks. Then there will be, once in a great while, the inspector who has a very large facility, like a very large fuel depot or a very large refinery or a petrochemical plant—one that’s large and well-integrated.

LN: Are there people who might not realize this standard is very important to them?

RB: Yes, right now there are. My guess is there are a lot of people out there getting involved in bio-fuels, producing ethanol for use as motor fuel or bio-diesel, who aren’t necessarily aware that there is an NFPA 30 out there that applies to them.

I think that’s because some entities are getting involved in the business that have never been involved with flammable and combustible liquids before. They understand the process by which the fuel is made, but they don’t necessarily understand that there may be codes like NFPA 30 that can help them. It also depends on the designers themselves. If I bring in a designer or a consulting firm to design a processing facility for me, then that person has to know about the existence of these codes or at least be familiar with them. If they’re not, it’s because they may not even realize [why they need to check for a code or standard], particularly if they’ve been working with diesel, because it’s considered less hazardous.

LN: Are AHJs aware of NFPA 30?

RB: For the most part, I think they are, yes. One of the things that is coming through loud and clear in terms of the bio-fuels is the question: Is there going to be an NFPA 30 specifically tailored for that industry? At this point in time, I would say there won’t be, because my perception is that NFPA 30 includes right now the information needed by this industry.  But, in the next code revision cycle, the Flammable and Combustible Liquids Code Committee might decide a special code is warranted.)

LN: What are the most important changes made to the 2008 edition?

RB: To me, the biggest effort was to rewrite NFPA 30 in a different format, which we refer to as the “hazmat” template. The idea was that NFPA would come up with an outline to be used for all of the documents that deal with hazardous materials, regardless of what those hazardous materials are. The committee responsible for NFPA 30 decided to take that particular bull by the horns and deal with it as soon as we could, mainly so we could get it done and go back to dealing with technical issues. And there are some technical issues on the horizon. Probably the largest would be whatever comes out of the Buncefield investigation. I believe we are the first to come out with a document that meets the template.

LN: Did you have to rethink the presentation of information in terms of a teaching standpoint or instruction standpoint or was it more just rearranging it?

RB: Essentially, eight chapters [were rewritten as] 28 chapters, and there was some rearranging of the text in the sense that, originally, the bulk storage tank material and piping systems material was what you first saw. Now these topics are at the end. NFPA 30 is set up in four sections now: fundamentals, container storage, operations, and bulk storage. The fundamental section includes material that applies to all uses of flammable and combustible liquids. Each of the other sections applies to a particular area and starts with a basic chapter that applies across the board, and then, in the case of storage, we follow that general chapter with chapters that are specific to occupancies.

When we get into the bulk storage section, we start with a chapter of requirements that apply to all storage tanks, and then we follow that with a specific chapter for aboveground tanks and underground tanks and so on.

LN: Now you have new corrosion protection requirements. Are these critical or more adjustments?

RB: They are more adjustments to follow what is happening out there in the world as far as the evolution of technology. A lot of these changes really are a reflection of what is being done out there now for various reasons. One of the [most significant] changes is to make the spill control requirements more broadly applicable, and that was done to correlate with what’s being done by EPA.

LN: You have changes for overfill prevention requirements. Is this the area you’re going to see the most growth in because of the Buncefield issue?

RB: Right now that’s a little bit in flux. There have been a couple of interim final reports, but there’s a lot of work still being done and that has to work its way through the industry and through changes in technology.

LN: What questions are you most often asked?

RB: Generally, a good percentage of the questions I get asked are from sprinkler system designers who are having trouble figuring out what their options are in terms of fire protection for the warehouse. So it isn’t so much a question of not understanding, it’s a question of which part of the code is a better fit for what they are trying to protect, and they need a better understanding of the sprinkler system design criteria for storage areas. I would say probably one-third of my calls on NFPA 30 have to do with that.

Another area I get a lot of questions about are separation distances for aboveground tanks—how close they can be to a property line, depending on the type of the tank and the size of the tank. And if they don’t have enough room, what options do they have.

LN: What next for the standard?

RB: We haven’t started the next round of meetings yet. We do know that we will be reviewing the reports from the Buncefield incident. Some full-scale fire testing has just been completed under the auspices of the Fire Protection Research Foundation, and that information will work its way through the committee. If the committee accepts it, then it’ll be reflected in an expansion of those tables referring to warehouse fire protection.

In this Section:
			NFPA to Participate in Landmark Fire Prevention Forum At the end of March 2008, the nation’s leading fire prevention professionals will gather  to develop a “comprehensive national strategy for fire prevention."
			Just Ask: Codes and Standards Snapshot NFPA 30, Flammable and Combustible Liquids Code
			Framework for Voluntary Preparedness At an October meeting hosted by the Alfred P. Sloan Foundation NFPA 1600 was proposed as the standard to use for the voluntary accreditation and certification of private-sector preparedness programs.