12
Report of the Committee on Nonvoting Rubber Tires Stephen R. Hoover, Chair Kemper Nat'l Insurance Cos., IL [I] Robert C. Everson, Calabash, NC [SE] James M. Iugalls, Industrial Risk Insurers, CT [I] James E. Long, Michelin Tire Mfg., SC [M] Robert A. Longbottom, The Goodyear Tire & Rubber Co., OH [M] Rep. NFPA Industrial Fire Protection Section Gerald W. OtRourke, O'Rourke & Co., CA [SE] Michael J. Rzeznik, Harrington Group, GA [SE] James 1L Schifiliti, Fire Safety Consultants, Inc., IL [SE] Robert D. Spaulding, Factory Mutual Research, MA [I] Jack Thacker, Allan Automatic Sprinkler Corp. of Southern California, CA [IM] Rep. Nat'l Fire Sprinkler Assn. James IL Townhill, Piedmont Environmental In~, NC [M] Rep. General Tire Robert B. Walker, Bridgestone/Firestone, Inc, TN [M] Rep. Rubber Mfrs. Assn. Alternates Joseph B. Haakins, Jr., Factory Mutual Research Corp., MA [I] (Alt. to R. D. Spaulding) Rich Kaiser,, Star Sprinkler Corp., WI [IM] (Alt. to j. Thacker) Peter J. Paatuso, Rubber Mfrs., Assn., DC [M] (Alt. to R. B. Walker) Todd E. Schumann, Industrial Risk Insurers, IL Ill (Alt. toJ. M. Ingalls) William P. Thomas Jr., Kemper Nat'l Insurance Cos., IL Ill (Alt. to S. R. Hoover) Edward Jefferson, Naugatuck, CT (Member Emeritus) Staff Liaison: Richard P. Bielen This list represents the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A key to classifications is found at the back of this document. Committee Scope: This Committee shall have primary responsibility for documents on the safeguards against fire in the storage of rubber tires. The Report of the Technical Committee on Rubber Tires is presented for adoption. This Report was prepared by the Technical Committee on Rubber Tires and proposes for adoption amendments to NFPA 231Dd994, Standard for Storage of Rubber Tires. NFPA ~31D- 1994 is published in Volume {5of the 1997 National Fire Codes and in separate pamphlet form. This Report has been submitted to letter ballot of the Technical Committee on Rubber Tires which consists of 12 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report. 228

Stephen Committee Scope - National Fire Protection …€¦ · responsibility for documents on the safeguards against fire in the storage of rubber tires. The ... Actual testing and

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Report of the Committee on Nonvoting

Rubber Tires

Stephen R. Hoover, Chair Kemper Nat'l Insurance Cos., IL [I]

Robert C. Everson, Calabash, NC [SE] James M. Iugalls, Industrial Risk Insurers, CT [I] James E. Long, Michelin Tire Mfg., SC [M] Rober t A. Longbottom, The Goodyear Tire & Rubber Co., OH

[M] Rep. NFPA Industrial Fire Protection Section

Gerald W. OtRourke, O'Rourke & Co., CA [SE] Michael J. Rzeznik, Harrington Group, GA [SE] James 1L Schifiliti, Fire Safety Consultants, Inc., IL [SE] Rober t D. Spaulding, Factory Mutual Research, MA [I] Jack Thacker, Allan Automatic Sprinkler Corp. of Southern

California, CA [IM] Rep. Nat'l Fire Sprinkler Assn.

James IL Townhill, Piedmont Environmental In~, NC [M] Rep. General Tire

Robert B. Walker, Bridgestone/Firestone, Inc, TN [M] Rep. Rubber Mfrs. Assn.

Alternates

Joseph B. Haakins, Jr., Factory Mutual Research Corp., MA [I] (Alt. to R. D. Spaulding)

Rich Kaiser, , Star Sprinkler Corp., WI [IM] (Alt. to j . Thacker)

Peter J. Paatuso, Rubber Mfrs., Assn., DC [M] (Alt. to R. B. Walker)

Todd E. Schumann, Industrial Risk Insurers, IL Ill (Alt. toJ . M. Ingalls)

William P. Thomas Jr., Kemper Nat'l Insurance Cos., IL Ill (Alt. to S. R. Hoover)

Edward Jefferson, Naugatuck, CT (Member Emeritus)

Staff Liaison: Richard P. Bielen

This list represents the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A key to classifications is found at the back of this document.

Committee Scope: This Committee shall have primary responsibility for documents on the safeguards against fire in the storage of rubber tires.

The Report of the Technical Committee on Rubber Tires is presented for adoption.

This Report was prepared by the Technical Committee on Rubber Tires and proposes for adoption amendments to NFPA 231Dd994, Standard for Storage of Rubber Tires. NFPA ~31D- 1994 is published in Volume {5 of the 1997 National Fire Codes and in separate pamphlet form.

This Report has been submitted to letter ballot of the Technical Committee on Rubber Tires which consists of 12 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report.

228

N F P A 2 3 1 D ~ A 9 8 R O P

(Log #11) 231D- 1 - (1-2, Table 4-1.2): Accept SUBMITTER: Edward Kaminski, Schirmer Engineering RECOMMENDATION: Delete text as follows:

1. 1-2 (Horizont:d channel. . . .Such channels may bc (are) form 2. Rack....Racks ~ may be f ixed .... 3. Table 4-12 Nor.e l....Actual testing and (i~) ~hc.'al~ n e t bc

-~.c;':c~ a~ a not) ~ definitive....The authority having jurisdiction (shall~ 3l.~z'.:!d use .... SUBSTANTIATION: These proposals revise NFPA 231D to eliminate nonmanda tory language. COMMITTEE ACTION: Accept. The Commit tee has made some editorial corrections to the r e c om m e nda t i on ~: follows:

"form" should be "formed". "a" should no t be struck through.

NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 10 NOT RETURNED: 2 0 ' R o u r k e , Walker

(Log #CP13) 231D- 2 - (1-2 Bundled Tires and Figure 1-3(e)): Accept SUBMITTER: Technical Commit tee on Rubber Tires RECOMMENDATION: Revise Section 1-2 Bundled Tires by changing "Bundled" to "Banded". Rest o f the definition to remain the same.

In Figure 1-3(e) change "bundled" to "banded" and change "unbundied" to unbanded" . SUBSTANTIATION: This is consistent with the change made in Commit tee Proposa~ 231D- (Log #CP6) with the change in the caption. Banded is used more than bundled. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 10 NOT RETURNED: 2 0 ' R o u r k e , Walker

(Log #CP6) 231D- 3 - (Figure 1-3(f#): Accept SUBMITTER: Technical Committee on Rubber Tires RECOMMENDATION: In Figure 1-3(0, revise the caption as follows:

"On-floor storage; on-tread, normally banded." SUBSTANTIATION: The change of delet ing "distance along fire holes no t to exceed 25 ft (7.7 m)" was made to be consistent with the language in 3-1.1. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMII 'TEE ACTION:

AFFIRMATIVE: 1 ~) NOT RETURNED: 2 0 ' R o u r k e , Walker

(Log #CP18) 231D- 4 - (Figure 1-.~,(g)): Accept SUBMITTER: Technical Commit tee on Rubber Tires

[ RECOMMENDATION: The Commit tee on Rubber Tires is making the following corrections to NFPA 231D, Code for the S

[ Figure l-3(g) Typical laced storage.

SUBSTANTIATION: Editorial. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 10 NOT RETURNED: 2 0 ' R o u r k e , Walker

12

(Log #CPl l ) 231D- 5 - (2-1.2(a) and (b)): Accept SUBMITTER: Technical Commit tee on Rubber Tires RECOMMENDATION: I. Modify the second sentence of 2-1.2(a) as follows:

"Columns shall have a 1 hour fire resistance rating for the entire length of the column, or one sidewall sprinkler directed to one side of the column at a 15 ft (4.6 m) level."

2. Change the second sentence of 2-1.2(b) as follows: "Columns shall have a 2 hour fire resistance rating for the entire

length of the column, inc lud ingconnec t ions with structural members; or two sidewall sprinklers, one at the top of the column and the other at 15 ft (4.6 m) level, both directed to the side of the column." SUBSTANTIATION: Fireproofing the entire column clarifies the intent of the requirement. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 10 NOT RETURNED: 2 0 ' R o u r k e , Walker

COMMENT ON AFFIRMATIVE: THACKER: My notes of the two day meet ing indicate that the

commit tee approved, that if and when column sprinklers are provided, their GPM is not additive to the sprinkler design density.

(Log #9) 231D- 6 - (2-1.2(b) Exception No. 2 (New)): Accept in Principle SUBMITTER: Robert A. Longbot tom, The Goodyear Tire & Rubber Co. RECOMMENDATION: Add new "Exception No. 2" to Section 2- 1.2(b) as follows:

Exception No. 2: The above protect ion shall not be required where ESFR sprinkler systems approved for rubber tire storage are installed. SUBSTANTIATION: The inclusion of ESFR sprinkler protect ion in file 231D Rubber Tire Storage Standard not addressed previously.

Two recent test programs enti t led "Rubber Tires: Investigation of A Common Protection For Three Types of Storage" and "Protection Investigation of 25 ft High Rubber Tire Storages" were conducted in 1999 and 1996 in conjunction with the Factory Mutual Research Corporat ion and the Rubber Manufacturers Association p roduced data which demons t ra ted the ESFR sprinkler's superiority over any other currently designed sprinkler for the protect ion of large scale tire warehousing of lacedt i res in open portable steel racks.

NOTE: Support ing Material is available for review at the NFPA Headquar ters . COMMITTEE ACTION: Accept in Principle.

] Revise Exception to Section 2-1.2 to read as follows: [ Exception: The above protect ion shall not be required where ] ESFR or large drop sprinkler systems approved for rubber tire ] storage are installed. Also revise the substantiation to include ] large dro s rinkler rotection

COMMI~I~T~)I~ S T A T ~ N T : The Commit tee added large drop sl3rinklers because the test series men t ioned in the substantiation also pertains to large drop sprinklers. Also, this change is consistent with NFPA 231C.

This Exception is for 2-1.2 no t 2-1.2(b) as stated by the su bmitter. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 9 NEGATIVE: 1 NOT RETURNED: 2 0 ' R o u r k e , Walker

EXPLANATION OF NEGATIVE: INGALLS: It was my unders tanding that a second Exception was

to be added as No. 2 to include ESFR and large d rop sprinklers. It is necessary to retain existing Exception for in-rack sprinklers as No. 1. To rewrite as a single exception will need more work.

229

NFPA 231D - - A 9 8 ROP

C O M M E N T ON AFFIRMATIVE: HOOVER: I believe we all agreed to add s o m e t h i n g about large

drop sprinklers to tile substant ia t ion so tha t is what I show. Also removed the sen tence abou t revising the substant ia t ion f rom the Commi t t ee Action as we did no t in tend that c o m m e n t to be part of tile s tandard.

(Log #CP10) 231D- 7 - (2-2.2): Accept SUBMITTER: Technica l Commi t t ee on Rubbe r Tires RECOMMENDATION: Modify 2-2.2 to read as follows:

"4-hour fire walls shall be provided between tire warehouse and tire manu fac tu r i ng areas. Fire walls shall be des igned in accordance with NFPA 221, S tandard for Fire Walls a n d Fire Barrier Walls." S U B S T A N T I A T I O N : This change was made to make it more consis tent with the fire wall r equ i r emen t s of o ther storage s tandards.

Also, the pr imary concern for fire walls is between manufac tu r i ng a n d warehouse areas a n d no t between adjacent warehouse areas. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 12 VOTE ON COMMITT E E ACTION:

AFFIRMATIVE: 10 NOT RETURNED: 2 O'Rourke, Walker

(Log #CP12) 231D- 8 - (2-3 a n d A-2-3 (New)): Accept SUBMITTER: Technica l Commi t t ee on Rubber Tires RECOMMENDATION: Add a new Section 2-3* to read:

2-3* Travel Distance to Exits. Travel dis tance to exits in s torage occupancies shall be in accordance with NFPA 101, Life Safety Code.

Add a new Section #,-2-3 to read: A-2-3 NFPA 101, Life Safety Code, accurately reflects the travel

dis tance requ i rements . • Based on NFPA 101, Life Safety Code, criteria, tire storage

would be classified as ord inary hazard. • Tire fires begin b u r n i n g slowly. In combina t ion with an

acceptable au tomat ic spr inkler system, this allows t ime for egress. • r i r e s torage warehouses have a low occupan t load. • Large aisle widths (8 ft m i n i m u m ) requi red in Section 3-1.2 of

this s t andard facilitate egress. S U B S T A N T I A T I O N : * Some local authori t ies are impos ing travel dis tance r equ i r emen t s in tire s torage warehouses b a s e d on old, ou tda ted s tandards .

• The mos t r ecen t Life Safety Code (NFPA 101-1994) more accurately reflects the in ten t of travel dis tance requ i rements (refer to suppor t ing mater ia l submi t t ed to NFPA). T he language r e c o m m e n d e d above to be a d d e d to NFPA 231D was taken verbat im ou t of the Life Safety Code.

• The re is an extremely low risk and inc idence of indoor tire fires (due to good pr, even t ion /p ro t ec t i on systems, and the difficulty of igni t ing tires).

• Tire storage warehouses have a low occupan t load - general ly less than 15 people ou t in the s torage area away f rom the dock and office area, on mobi le equ ipmen t .

• Large aisle widths (8 ft m i n i m u m ) requ i red in Section 3-1.2 of NFPA 231D also facilitate egress.

• To impose travel dis tance requ i rements of less t h a n 400 ft is a poo r use of capi ta l / resources . This would requi re escape t unne l s or the equivalent. For all of the reasons n o t e d above, warehouse workers would no t travel to the center of a warehouse center and use a t unne l when they could j u s t as easily travel directly to an outside exit door . (Most likely, the one they used to en ter the building, or file ma in dock.)

• The scope of NFPA 231D is no t l imited to fire p r even t i on /p ro t ec t i on issues. Thus , it is perfectly acceptable to address this l ife safety issue. C O M M I T T E E ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 12 VOTE ON C O M M I T T E E ACTION:

AFFIRMATIVE: 10 N O T RETURNED: 2 0 ' R o u r k e , Walker

(Log #CP14) 231D- 9 - (3.2.2): Accept SUBMITTER: Technica l Commi t t ee on Rubbe r Tires RECOMMENDATION: Change 3-2.2. to read:

"Storage clearance in all direct ions f rom roof s t ructures shall be no t less than 18 in. (.45 m)." SUBSTANTIATION: Modern cons t ruc t ion me thods have changed the m o d e of opera t ion a n d storage ar rangements . COMMITTEE ACTION: Accept . NUMBER OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 10 N O T RETURNED: 2 0 ' R o u r k e , Walker

(Log #4) 231D- 10 - (3-3.2(c) a n d (d), 3-3.3 (New)): Accept in Principle SUBMITTER: Stephen 1L Hoover, William T h o m a s , Kemper Insu rance RECOMMENDATION: Add the words "on-side or on-tread" between the words "storage" and "up" in both sentences.

Add a new Section 3-3.3 to sap "Miscellaneous storage is within the scope of NFPA 13, S tandard

for the Installation o f Sprinkler Systems". SUBSTANTIATION: The original wording left the reader wonder ing if all tire s torage on racks was acceptable or if there were any resu' ict ions at all. The change clarifies the commit tee ' s intent . The new paragraph also clarifies the commit tee ' s in tent by moving a s t a t emen t f rom the append ix to the body of the standard. COMMITTEE ACTION: Accept in Principle.

Accept tile first r e c o m m e n d a t i o n as submit ted . Revised text of new 3-3.3 will now read as follows:

"Miscellaneous s torage shall be pro tec ted in accordance with the r equ i r emen t s of NFPA 13, S tandard for the Installation of Sprinkler Systems". COMMITTEE STATEMENT: The wording o f 3.3.3 was modif ied to make tile s t a t emen t a manda to ry requ i rement . NUMBER OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 10 N O T RETURNED: 2 0 ' R o u r k e , Walker

(Log #CP9) 231D- 11 - (3-4 (New)): Accept SUBMITTER: Technica l Commi t t ee on Rubbe r Tires RECOMMENDATION: Add new 3-4 as follows:

3-4 Mixed Storage. 3-4.1 Where protec t ion in accordance with this s t andard is

provided, s tored tires shall be segrega ted f rom o ther combust ible storage by aisles at least 8 ft (2.4 m) wide.

Delete 2-2.1 and r e n u m b e r . S U B S T A N T I A T I O N : The purpose of this s t andard is to provide a m i n i m u m level of pro tec t ion a n d no t endorse a lesser level of protect ion. Pa ragraph 2-2.1 was modi f ied a n d moved to 3.4 since this sect ion addressed mixed s torage a n d no t fire walls. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 12 VOTE ON C O M M I T T E E ACTION:

AFFIRMATIVE: 10 N O T RETURNED: 2 0 ' R o u r k e , Walker

(Log #CP5) 231D- 12 - (4-1.1): Accept SUBMITTER: Technica l Commi t t ee on Rubbe r Tires RECOMMENDATION: Modify 4-1.1 as follows:

"Automatic sprinklers shall be installed in accordance with NFPA 13, S tandard for the Installat ion of Sprinkler Systems, except as modi f ied by this s tandard." SUBSTANTIATION: Large Scale Tes t ing indicates differing pe r fo rmance criteria as indicated in NFPA 13 for ESFR sprinklers and this s tandard does no t wish to imply tha t unpro tec ted fire s torage is acceptable. COMMITTEE ACTION: Accept . NUMBER OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 10 N O T RETURNED: 2 0 ' R o u r k e , Walker

2 3 0

N F P A 2 3 1 D - - A 9 8 R O P

(Log #6) 231D- 13 - (Table 4-1.2): Accept in Principle SUBMITTER: S tephen R. Hoover, William Thomas , Kemper Insurance RECOMMENDATION: Add an entry for ESFR sprinklers as follows:

Piling Method Pile Height Number of Sprinklers and Minimum Operat ing

Pressure

with Tire Storage at 25 ft (7.6 m) was inadequately protected by 5 /8 in. orifice sprinklers discharging 0.75 g p m / f t 2 (30.6 L / m i n / m 2 ) . NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 10 NOT RETURNED: 2 0 ' R o u r k e , Walker

12

Rubber Tire Stor:tge Up to 25 ft 12 Sprinklers @ 50 PSI on-side or on-l lead in a 30 ft in pailetized portable Building racks, open portable racks, or fixed racks without solid shelves Note 1: Wet systems only Note 2: The shape of the design area shall be in accordance with

NFPA 13. Note 3: Where used in dais application, ESFR protection is

expected to contro~ rather than suppress the fire. SUBSTANTIATION: In previous tests, with other commodities, it has been shown that ELO sprinklers at 50 psi are superior to Large Drop and ELO sprinklers.

Two 1996 tire tesls with Large Drop sprinklers (at 75 psi) control led on-side :rod on-tread storage arrays at 25 ft high with 6 and 8 sprinklers respectively, ff the pressures were converted to density, the ESFR at 50 psi is equal to the Large Drop sprinkler at 75 psi. COMMITTEE ACTION: Accept in Principle.

See Commit tee Action on Proposal 231D-22 (Log #CP4) COMMITTEE STATEMENT: See Commit tee Proposal 231D-22 (Log #CP4). The Commit tee Proposal incorporates the submitter 's recommendat ions . Also, the first "ELO" in the submitter 's Substantiation should be "ESFR". NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: !) NEGATIVE: 1 NOT RETURNED: 2 0 ' R o u r k e , Walker

EXPLANATION OF NEGATIVE: SPAULDING: Note 3 in Table 4-1.2 states that ESFR protect ion

is expected to control ra ther than suppress the fire. The ESFR protection recommenda t ion was based on the results of two large drop sprinkler (LD~S) tests. Although die LDAS tests were used as the basis for reo~mmending F~SFR protection, the assumption, in this case, should be that ESFR sprinklers will provide suppression, irrespective of the results of the LDAS tests. ESFR sprinklers will operate sooner (lower RTI and tempera ture rating) than die LDAS. TI- e result should be suppression rather than control.

(Log #10) 231D- 14- (Table 4.1.2): Reject SUBMITTER: Gar z W. Ponte, The Reliable Automatic Sprinkler Co., Inc. RECOMMENDATION: Add text ~.s follows:

Note 2: The densities and areas provided in the table are based on fire

tests using standard response, s tandard orifice (1/2 in. (12.7mm), and large orifice (1 7/32 in. (13.5mm) sprinklers. The use of extra large orifice (ELO) (5/8 in.) sprinklers shall be permit ted where listed for such use, and where installed at a min imum operating pressure of 10 psi. (60ktM-) (0.7 bat) and very extra large orifice (VELO) (3.4 in.) s[,rinklers shall be permit ted where listed for such use, and where installed at a minimum onerating Dressure of 7 Psi (0.5 bar). In buildings wilere "old style" sprinklers exist, discharge densities :;hall be increased by 25 percent . For use of o ther types of sprinlders, consult the authority having jurisdiction. SUBSTANTIATION: A VELO Sprinkler can control fires at lower operat ing pressures than existing sprinklers allowed under this standard; which is an improved me thod of fire protection. Attached is a copy of UL Listing Report 96NK25107 which details extensive successful testing this sprinkler has had in full scale fire testing. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: This Proposal was rejected because there is no large scale testing to suppor t adding dais sprinkler to the protect ion requirements for tires. Also, the full scale test PTrogram, "Protectio~a Investigation of 25 ft (7.6 m) High Rubber

ire Storage" by FMRC and the Rubber Manufacturers Association

(Log #CP3) 231D- 15 - (Table 4-1.2 Note 2): Accept SUBMITTER: Technical Commit tee on Rubber Tires

I RECOMMENDATION: Delete Note 2 and r enumber subsequent Notes. SUBSTANTIATION: Note 2 is r edundan t with revised paragraph 4-1.2 [see Proposal 231D-18 (Log #CP1)]. Full scale test with tire storage at about 25 ft (7.6 m) was inadequately protected by ELO sprinklers discharging 0.75 gpm/ f t 2(30.6 L / r a i n / m 2 ) .

Old style s rinklers are no Ion er used in this occupancy COMMITT~I~ ACTION: Accepgt. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 10 NOT RETURNED: 2 0 ' R o u r k e , Walker

(Log #1) 231D- 16 - (Table 4-1.2 and Appendix E (New)): Reject Note: This Proposal appeared as Comment 231D-10 which was

held from the Annual 94 TCD on Proposal 231D-13. SUBMITTER: Stephen R. Hoover, Kemper National Insurance Co. RECOMMENDATION: Revise the text under "Piling Method" to read "Laced Tires in Portable Steel Racks. See Annendix E.

. L

Then add Appendix E as follows: Interlaced auto tires were stored in open metal rack modules

measuring 77 in. x 56 in. x 71 in. high. The modules were butted together in the North-South direction but were separated by a 6 in. flue in tile East-West direction. Tile modules were 4 high resulting in a total height of 23 ft 8 in. and a clearance from tile top of storage to the sprinklers of 6 ft 4 in, 286 degree sprinklers were used on a 10 ft x 10 ft spacing. A constant density of 0.60 g p m / s q ft was provided.

After ignition, fire progress was slow with file flames reaching the top of the array at about 4 minutes. The first sprinkler operated at 4m 22s which seemed slow. But the slowness is probably due to the laced storage a r rangement which impedes the movement of heat to tile roof level. At 5m 15s, there were 5 sprinklers operating and the gas temperature over ignition exceeded 1000°F. At 8m 45s, there were 15 sprinklers operating and smoke was descending down to 20 ft f rom the ceiling. By 10m 30s tile fire was obscured from view by smoke. At 12m the fire severity increased as 21 sprinklers ignition peaked at 1889°F and then remained at about 1540°F until the termination of tile test at 20m. The steel temperature exceeded 1200°F for 6 1 /2 rain with a peak of 1526°F at 18m ~8s. The test was terminated at 20m with 77 sprinklers operating. Post fire suppression activities were on for another lh 10m after tile test termination. During that time more sprinklers opera ted with a final operation at l h 7m 34s after ignition thus all 95 t imed sprinklers operated. Also 38 sprinklers used for building protect ion had operated. One sprinkler pipe was broken and two more were deformed. More than two hours of manual fire fighting was required before salvage and overhaul could be started.

During salvage and overhaul, it was found that part of the array had collapsed. A collapse would have opened up the array, allowing better air access with an increase in fire intensity. This may have occurred about file time the 21 sprinklers operated in 7 seconds. At test termination the instruments indicated a severe fire burning in a steady state condition. At terminat ion 77 sprinklers were operating discharged 4800 gal of water. Almost the entire array suffered fire damage, 8 of the stacks had collapsed, and it was estimated that the equivalent of 7 stacks had been consumed. Analysis of ceiling gas temperatures and steel temperatures indicate that steel would have failed. Fire control efforts were still o n g o i n g when data collection was concluded lh 30m from the beginning of the test. Smoke hampered the salvage and overhaul operations. Ground level attack using fire hoses was needed during the salvage and overhaul operations.

231

NFPA 231D - - A 9 8 ROP

SUBSTANTIATION: The laced tire storage arrangement had never been tested before and was not addressed in 231D. In racks of construction other than steel, or at storage heights lower than 24 ft, adequate protection may be feasible but at the present time has not been proved by test. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: This issue was clarified as a result of full scale tests. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 10 NOT RETURNED: 2 0 ' R o u r k e , Walker

(Log #CP7) 231D- 17- (Table 4-1.2 Note 4): Accept SUBMITrER: Technical Committee on Rubber Tires RECOMMENDATION: 1. In Table 4-1.2, delete Note 4 and renumber notes.

2. Delete the reference to "Note 4" in Table 4-1.2(1) (c). 3. Cbange "N/A" in the Table to "Not Allowed".

SUBSTANTIATION: This change makes table 4-1.2 consistent with 3-1.1.

"Not applicable" was changed for clarity. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 10 NOT RETURNED: 2 0 ' R o u r k e , Walker

COMMENT ON AFFIRMATIVE: HOOVER: My notes show that we deleted Note 6 too, so I

added that. SPAULDING: Is recommendation 3 to change each entry

of"N/A" in the table to "Not applicable" or is it to change the definition in the notes, which currently reads: "Note 6: N/A = Not Applicable" to "Note 6: N/A = Not Allowed"? My recommendation would be simply to change the definition in Note 6.

(Log #CP1) 231D- 18 - (4-1.2, Figure 4-1.2): Accept SUBMITI'ER: Technical Committee on Rubber Tires RECOMMENDATION: 1. Revise 4-1.2" as follows:

"Sprinkler discharge and areas of application shall be in accordance with Table 4-1.2(a) for 1/2 in. (12.7 mm) and 17/32 in. (13.5 mm ) sprinklers. For large drop sprinklers and ESFR sprinklers, refer to Table 4-1.2(b) and 4-1.2(c) respectively."

2. In 4-2.1, "Table 4-1.2" should be changed to "Table 4-1.2(a)." 3. Place an "*" after Figure 4-1.2 as "Figure 4-1.2"". 4. Move the second paragraph of 4-1.2" to Appendix A-4-1.2 in

the beginning of the first paragraph: A-4-1.2 To use the graph in Figure 4-1.2, note the example

indicated by the broken line. Read across the graph at a storage height of 14 ft (4.3 m) until the storage height intersects the storage height curve at a sprinkler density of 0.45 gpm/f t 2 [ 18.3 (L /min) /m2] . Then read down until the sprinkler density intersects the sprinkler operating area curves at 3,200 ft2 (297 m 2) for ordinary sprinklers and 2,000 ft 2 (186 m2) for high temperature sprinklers.

SUBSTANTIATION: Recent full scale test using ESFR and large drop sprinklers clearly demonstrates the need for this change. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 10 NOT RETURNED: 2 0 ' R o u r k e , Walker

(Log #5) 231D- 19 - (4-1.2, Table 4-1.2(2)(b), Table 4-1.2 Note 2): Accept in Principle in Part SUBMITrER: Stephen R. Hoover, William Thomas, Kemper Insurance RECOMMENDATION: 1. Revise the first sentence of 4-1.2" to read:

"Sprinkler discharge densities and areas of application shall be in accordance with Table 4-1.2 for 1/2", 17/32", and ELO (extra large orifice) sprinklers."

2. Revise Table 4-1.2(2)(b) as follows: (1) Retain the dual density option as is; (2) Revise the second option to read "0.75 with 1-hr

fireproofing of roof and ceiling assembly", "N/A", "4000"; (3) Delete the third option which presently reads "0.75",

"N/A", "4000." 3. Revise the first sentence of Note 2 of Table 4-1.2 to read: "The densities ...[17/32 in. (13.5 mm)], and extra large orifice

(ELO) sprinklers." The remainder stays the same. SUBSTANTIATION: Reviewing the 1992 tire test series, on which the second option was based, indicated that smoke buildup was a major contributor to both fire control and the number of sprinkler operations (29 sprinklers). By the time the array was obscured by smoke all 29 sprinklers had operated. The steel temperature measured during the test was about 1080 F and raised concern. If the steel temperature had been measured 10 feet to the north of ignition (where the peak gas temperature was nearly 2000 F) it would normally have exceeded the 1180 F critical steel temperature which indicates a need for a density higher than the 0.60 first recommended COMBINED WITH fireproofing of the roof and ceiling assembly. Had the smoke generation, or its descent into the array, been slower, the number of sprinkler operations could have been greater than the 29 that occurred. The standard cannot de end on smoke generation, to limit, sprinkler. . operation.

~ e 1996 test series ruth ELO spnnlders indicated steel temperature problems further indicating the need for fireproofing even at the higher density of 0.75 pgm/sq ft. By the time the array was obscuredby smoke (about 7m 30s) only 11 sprinklers (of a final count of 17) were operating. It has been shown in numerous tests, outside of the tire test series, that ELO sprinklers are superior to 17/32" sprinklers. In a normal, sloping water supply the initial densities would be far superior with ELO sprinklers compared to 17/32" sprinklers. COMMITTEE ACTION: Accept in Principle in Part.

Accept Part 1 in principle. See Committee Action on Proposal 231D-18 (Log #CP1).

Accept Part 2 in principle. Revise Table 4-1.2(2) (b) as follows: Change "fire proofing" to "fire resistive rating" and change "N/A"

to "Not Allowed". Text will now read as shown at the bottom of this page:

Do not Accept Part 3. "The densities..."

Piling Method Piling Height Sprinkler Discharge Density

(gpm/ft 2) Areas of Application (ft ~)

(b) On-side

(See No te 1.) (ft) (See Notes 1 and 2) Ordinal T Temp.

20 to 25 0.60 a n d N o t Al lowed 0.90 (see Note 5); or N o t Al lowed

High T e m p . 5,000 3,000

0.75 with 1-hr fire resistive rat ing of r o o f a n d ceilin~ assembly; or

N o t Al lowed 4,000

232

N F P A 2 3 1 D ~ A 9 8 R O P

COMMITTEE STATEMENT: Part 1 was completed in Committee Proposal 231D-18 (Log #CP1) and Part 2 was changed to use accepted language .and for clarity. Part 3 was not accepted because Note 2 was deleted in Committee Proposal 231D-15 (Log #CP3). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TOVOTE: 1~ VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 10 NOT RETURNED: 2 0 ' R o u r k e , Walker

COMMENT ON AFFIRMATIVE: HOOVER: Editorial but we need to take the "; or" out of the last

entry in the Table.

(Log #CP8) 231D- 20 - (Table 4-1.2(a), (b), and (c)): Accept SUBMITTER: Technical Committee on Rubber Tires RECOMMENDATION: In existing Table 4-1.2, delete item "(6) laced tires in racks. See A-4-1.2" and delete "laced tires" in the last paragraph of A-4-1.2. A-4-1.2 should now read:

A-4-1.2 Density mad areas of application in Tables 4-1.2(a), (b), and (c) have been developed from fire test data. Protection requirements for other storage methods are beyond the scope of this standard at the present time. From recent fire testing with densities of 0.45 gpm/f t 2 [18.3L/min)/m2] and higher, there have been indications that large orifice sprinklers at greater than 50-ft 2 (4.6-m2) spacing produce better results than the 1/24n. (12.7- ram) orifice sprinklers at 50-ft2 (4.6-m2) spacing.

Tables 4-1.2(a) and (b) are based on operation of standard sprinklers. Use of °'quick response", or other spedal ssprinklers should be based on appropriate tests as approved by the autholaty having jurisdiction.

Tables 4-1.2(a), (b), and (c) represent test results from rubber tire fire tests performed at the Factory Mutual Research Center.

Storage heights and configurations, or both, [e.g., automated ~ material handling swstems above 50 ft (9.1 m)] beyond those indicated in the table have not had sufficient test data developed to establish recommended criteria. Detailed engineering reviews of the protection should be conducted and approved by the authority having jurisdiction. SUBSTANTIATION: Laced tires are now addressed in new table 4-1.2 (c). COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: ] 0 NOT RETURNED: 2 0 ' R o u r k e , Walker

(Log #CP2) 231D- 21 - (Table 4-1.2(b) (New)): Accept SUBMITTER: Technical Committee on Rubber Tires RECOMMENDATION: Change Table 4-1.2 to 4-1.2(a) and add new Table 4-1.2(b) as shown at the bottom of this page: SUBSTANTIATION: This table was added based on a test program called "Protection Investigation of 25 ft (7.6 m) High Rubber Tire Storages" by FMRC and the Rubber Manufacturers Association. This added large drop sprinklers to the protection requirements which had not been previously addressed.

COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 9 NEGATIVE: 1 NOT RETURNED: 2 0 ' R o u r k e , Walker

EXPLANATION OF NEGATIVE: SPAULDING:Table 4-1.2(b) of this Proposal indicates that the

protection is appropriate for buildings up to 32 ft (9.8 m). As stated in the substantiation, the table was added based on a test

~ rogram called "Protection of 25 ft (7.6 m) High Rubber Tire torages" by FMRC and the Rubber Manufacturers Association.

The tests were conducted in a building with a floor to ceiling height of 30 ft (9.1 m). The recommendation to increase the building height should not be accepted because: 1. there is no data to substantiate the recommendation and 2. extrapolation of fire. test data beyond storage, or building heights tested is not rehable. Without suffioent data there is no reliable method of determining if the extrapolated recommendation will result in an uncontrolled fire.

COMMENT ON AFFIRMATIVE: HOOVER: Editorial again but the "3" telling the reader where

Note 3 applies was missing so I added it where I think it belongs. THACKER: Footnote should be labeled (see note...) to be

consistent with the standard.

(Log #CP4) 231D- 22 - (Table 4-1.2(c) (New)): Accept SUBMIIq'ER: Technical Committee on Rubber Tires RECOMMENDATION: Add new table 4-1.2(c) as shown on page 234. SUBSTANTIATION: This table was added based on a test program called "Protection Investigation of 25 ft High Rubber Tire Storages" by FMRC and the Rubber Manufacturers Association. This added ESFR sprinklers to the protection requirements, which had not been previously addressed. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 9 NEGATIVE: 1 NOT RETURNED: 2 0 ' R o u r k e , Walker

EXPLANATION OF NEGATIVE: SPAULDING: Comment 1. I recommended in Proposal 231D-

13 that the 12 ESFR sprinkler design, in this case, should be based on "suppression". Suppression with ESFR sprinklers generally implies that a 1 hr duration is required and 250 gpmhose demand is required. If, as in the case with Table 4-1.2(c), these criteria are increased additional substantiation should be provided. I recommend the following should be added as a note to the table: The design of an ESFR sprinkler system has traditionally included a hose stream and water supply duration of 250 gpm (945 L/min) and 1 hr respectively.. . Fire tests with. . rubber tires produce dense smoke, limltang access to the building. Because of the smoke, many authorities having jurisdiction require that the sprinkler be capable of operating at least 90 rain.

Table 4-1.2(b) Large Drop Sprinklers °)

Piling Method

Rubber Tire Storage On-side or on-tread in palletized portable racks, or open portable racks or fixed racks wi,~hout solid shelves

P~e Number of Snrinklers Maximum Duration Height and minimum

oneratin~ pressures 2 Up to 25 ft 15 Sprinklers @ 75 psi 32 ft 3 hours

(7.6 m) (517.5 kPa) (3)

Hosf Demand

500 gpm (1892

L/min)

Note 1: Wet systems only. Note 2: Sprinkler operating pressures and number of sprinklers in the design are based on tests in which the clearance was 5 ft to 7 ft (1.5 m to 2.1 m) between the sprinkler deflector and the maximum height of storage. The authority having jurisdiction should be consulted where clearances exceed 7 ft (2.1 m). Note 3: The design area shall consist of the most hydraulically demanding area of 15 sprinklers, consisting of 5 sprinklers

2 2 on each of 3 braqdl lines. The design shall include a minimum operating area of 1200 ft (111.5 m ), a maximum of 1500 ~2 (139.4 m ~) and utilize a high temperature rated sprinkler.

233

N F P A 2 3 1 D - - A 9 8 R O P

Table 4-1.2(c) ESFR Sprinklers (1,4)

Piling Method

Rubber tire storage on-side or on- t read in palletized portable racks, open portable racks, or fixed racks without solid shelves

Laced tires in open portable steel rack [see Figure l-3(g)]

Pile Maximum Number of Sorinklers and Height Building minimum operating

Height oressures (2.3)

Duration Hose Demand

U p t o 25 ft 3Oft 12 sprinklers @ 50 psi 3 hours (7.6 m) (9.1 m)

U p t o 25 ft 35 ft 12 sprinklers @ 75 psi 3 hours (7.6 m) (10.7 m)

Up to 25 ft 30 ft 20 sprinklers @ 75 psi (5) 3 hours (7.6 m) (9.1 m)

500 gpm 1892 L/min)

500 gpm 1892 L/rain)

500 gpm 1892 L /min)

Note 1: Wet systems only. Note 2: Sprinkler operating pressures and number of sprinklers in the design are based on related tests in wbich the clearance was 5 ft to 7 ft (1.5 m to 2.1 m) between the sprinkler deflector and the maximum height of storage. The authority baying jurisdiction should be consulted where clearances exceed 7 ft (2.1 m) Note 3: The shape of the design area sball be in accordance with NFPA 13. Note 4: Where used in this application, ESFR protection is expected to control ra ther than suppress the fire. Note 5: The design area shal lconsis t of the most hydraulically demanding area of 20 sprinklers, consisting of 5 sprinklers on each of 4 branch lines. The design shall include a min imum operat ing area of 1600 ft. 2 (148.6 m z)

Comment 2. In Table 4-1.2(c) of this Proposal, ESFR sprinklers are r e c o m m e n d e d for t h e p r o t e c t i o n of rubber tires in a building to a maximum height of 35 f t (10.7 m). As stated in the substantiation, the table was added based on a test prol~ram called "Protection of 25 ft (7.6 m) High Rubber Tire Storages by FMRC and the Rubber Manufacturers Association. The tests were conducted in a building with a floor to ceiling height of 30 ft (9.1 m) no t 35 ft (10.7 m). The recommendat ion to increase the building height should no t be accepted because: 1. There is no data to substantiate the recommendat ion and 2. Extrapolation of fire test data beyond storage or building heights tested is not reliable. Without sufficient data there is no reliable me thod of de termining if the extrapolated recommenda t ion will result in an uncont ro l led fire.

Comment 3. Table 4-1.2(c) r ecommends that 20 ESFR sprinklers at 75 psi be used to protect laced tires. The tests used for this r ecommenda t ion resulted in 14 sprinklers operating. I r e commend that the criteria for protect ion be based on a safety factor of 1.5 times the operating area of the sprinklers with that result rounded up to the nearest square area. Although the test results are clearly positive I r e c o m m e n d that this me thod be used because: 1. It is consistent with other NFPA recommendat ions when designin~g protect ion recommendation, for high challenge fire and sprinklers and 2. ThLs recommenda t ion based on the results of one test. With only one test the recommenda t ion should be based on a conservative ra ther than a liberal protect ion requirement , irrespective of the test results. COMMENT ON AFFIRMATIVE:

HOOVER: Editorial but the "3" for Note 3 was in the wrong place and I moved it to where it applies.

THACKER: See commen t on Proposal 231D-21 (Log #CP2) in regards to footnotes. Footnote (3) should be relocated after 12 sprinklers @ 50 psi and 12 sprinklers @ 75 psi.

(Log #7) 231D- 23 - (Table 4-1.2(c) (New)): Accept in Principle SUBMITTER: Robert A. Longbot tom, The Goodyear Tire & Rubber Co. RECOMMENDATION: Add new Table 4-1.2(c) as shown at the bot tom of this page: SUBSTANTIATION: To add ESFR sprinklers protect ion for 25 ft high laced tire storage in open portable steel racks to the protect ion requirements which have not been previously addressed.

Two recent test programs ent ided "Rubber Tires: Investigation of A Common Protection For Three Types of Storage" and "Protection Investigation of 25 ft. High Rubber Tire Storages" were conducted in 1992 and 1996 in conjunction with the Factory Mutual Research Corporat ion and the Rubber Manufacturers Association p roduced data which demons t ra ted the ESFR sprinkler's superiority over any other currently designed sprinkler for tbe protect ion of large scale tire warehousing of lacedt i res in open portable steel racks.

NOTE: Support ing Material is available for review at the NFPA Headquar ters . COMMITTEE ACTION: Accept in Principle. COMMITTEE STATEMENT: See Commit tee Proposal 231D-22 (Log #CP4). The Commit tee changed the submitters recommenda t ion f rom 18 sprinklers to 20 sprinklers as an additional safety factor. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 9 NEGATIVE: 1 NOT RETURNED: 2 0 ' R o u r k e , Walker

Table 4-1.2tc ) ESFR Sprinklers

Pilimr Method Pile Height Number of ESFR Sorinklers and minimum operating nressures

Laced tires in open portable steel racks Figure 1-3(g)

Up to 25 ft (7.6 m)

18 Sprinklers @ 75 psi#s 155 F Rated (517.5 kPa)

Note 1: Wet systems only. Note 2: Sprinkler operating pressures and number of sprinklers in the design are based on tests in which the clearance was 5 ft (1.5 m) between the sprinkler deflector and the maximum height of storage. The authority having jurisdict ion should be consul ted where clearances exceed 5 ft (1.5 m). Note 3: The design area shall consist of the most hydraulically demand ing area of 18 sprinklers. The design area shall include a min imum of 1440 sq ft. Note 4: Where used in this application, ESFR protection is expected to control ra ther than suppress the fire.

234

NFPA 231D - - A 9 8 ROP

EXPLANATION OF NEGATIVE: SPAULDING: Table 4-1.2(c) recommends that 18 ESFR

sprinklers at 75 psi be used to protect laced tires. The tests used for this recommendation resulted in 14 sprinklers operating. I recommend that the criteria for protection be based on a safety factor of 1.5 times the operating area of the sprinklers with that result rounded up to the nearest square area. Although the test results are clearly positive I recommend that this method be used because: 1. It is consistent with other NFPA recommendations when designing protection recommendations for high challenge fires and sprinklers ~.nd 2. This recommendation based on the results of one test. With only one test the recommendation should be based on a conseJwative rather than a liberal protection requirement, irrespective of the test results.

(Log #2) 231D- 24- (4-1.3.1): Accept SUBMITTER: Paul Roberto, Wausau Insurance Companies

] RECOMMENDATION: Delete entire paragraph 4-1.3.1. SUBSTANTIATION: This paragraph limits maximum discharge pressure of sprinklers to 60 psi. No explanation for this limit is provided in this standard. NFPA 231C currently contains the same requirement with the explanation that the highest pressure in the testprogram was 62.5 psi. With the introduction of new sprinkler heads and results from large scale fire testing, it is clear that end head pressures in ex,zess of 60 psi will not only be desirable, but will be required in some situations. Some current NFPA standards have protection requirements for end head pressures exceeding 60 psi and /o r very high density requirements for which a 60 psi maximum may unnecessarily restrict design options (spacing, sprinkler k-factor, et(.) NFPA 13, 231,231E and 231F currently contain no such maximum pressure limit. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 10 NOT RETURNED: 2 0 ' R o u r k e , Walker

(Log #CP16) 231D- 25 - (4-1.4.1): Accept SUBMITrER: Techlfical Committee on Rubber Tires RECOMMENDATION: In Section 4-1.4.1 change "4-1.4" to "4-1.4.2". SUBSTANTIATION: Editorial. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 10 NOT RETURNED: 2 0 ' R o u r k e , Walker

(Log #GP15) 231D- 26 - (4-1.4.2): Accept SUBMITTER: Technical Committee on Rubber Tires RECOMMENDATION: Delete Section 4-1.4.2 in its entirety and renumber accordingly. SUBSTANTIATION: Installation of in-rack sprinklers is adequately covered by NFPA 231G. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 10 NOT RETURNED: 2 0 ' R o u r k e , Walker

COMMENT ON AFFIRMATIVE: THACKER: I believe 4-1.4.2 should remain since NFPA 231G

does not mandate in-rack sprinklers to be 2 ft 0 in. from rack uprights nor does it mandate clearance below in-rack sprinklers in all storage scenarios and when it does, it is 6 in., not 4 in.

(Log #CP17) 231D- 27 - (4-2.1): Accept SUBMITTER: Technical Committee on Rubber Tires

I RECOMMENDATION: Revise Section 4-2.1" to read as follows: "When only automatic sprinkler protection is specified in Table

4-1.2(a) it is acceptable to reduce densities to one-half the densities specified or 0.24 gpm/ft2, whichever is higher, and install

a properly designed high expansion foam system in accordance with NFPA llA, Standard for Medium- and High-Expansion Foam Systems." SUBSTANTIATION: This change clarifies the intent of combination sprinkler/foam systems. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 10 NOT RETURNED: 2 0 ' R o u r k e , Walker

(Lo)g #8) 231D- 28 - (4-3.2(c) Exception No. 2 (New)): Accept in Principle SUBMITTER: Robert A. Longbottom, The Goodyear Tire & Rubber Co. RECOMMENDATION: Add new "Exception No. 2" to Section 4- 3.2 as follows:

Exception No. 2: Where ESFR and large drop sprinkler systems approved for rubber tire storage are installed, hose stream requirements shall be permitted to be 500 gpm (1892 L/rain), with a water supply duration of not less than 2 hours. SUBSTANTIATION: The inclusion of ESFR sprinkler protection in the 231D Rubber Tire Storage Standard not addressed previously.

Two recent test programs entitled "Rubber Tires: Investigation of A Common Protection For Three Types of Storage" and "Protection Investigation of 25 ft. High Rubber Tire Storages" were conducted in 1994 and 1996 in conjunction with the Factory Mutual Research Corporation and the Rubber Manufacturers Association produced data which demonstrated the ESFR sprinkler's superiority over any other currently designed sprinkler for the protection of large scale tire warehousing of laced tires in openportable steel racks.

NOTE: Supporting Material is available for review at the NFPA Headquarters. COMMITTEE ACTION: Accept in Principle.

] Add new Exception No. 2 to read as follows: [ Exception No. 2: Where ESFR and large drop sprinkler systems ] approved for rubber tire storage are installed, hose stream I requirements shall be permitted to be 500 gpm (1892 L/min).

COMMITTEE STATEMENT: The Exception also applies to large drop. The water duration was dropped because it is already covered in the paragraph. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 1O NOT RETURNED: 2 0 ' R o u r k e , Walker

(Log #3) 231D- 29 - (Appendix C): Accept in Principle SUBMITTER: Michael Blumenthal, Brady WiUiamson, Waddell Hill, Scrap Tire Mgmt Council RECOMMENDATION: Revise text to read as follows:

Appendix C Guidelines for Outdoor Storage of Scrap Tires C-1 Scope..This ap[pendix, applies to the outdoor, storage of scrape tires m whole, bmled, or processed form, including incidental usage locations.

C-2 Purpose. This appendix has been developed for the purpose of aiding fire oflidals and authorities having jurisdiction in their effort to both prevent and properly manage fire incidents that occur in whole, bailed or processed scrap tire stockpiles. Each individual property has its own unique conditions of tire handling, exposure, and topography. Thus, in this appendix, basic fire protection principles are applied with due consideration of local tactors.

Rubber has a heat combustion of about 15,000 Btus per pound, or roughly twice that of ordinary combustibles (e.g., paper and wood). Once ignited, fire development is rapid, and high temperatures can be expected due to the large exposed surface area of whole tires. In the case of baled or processed tire fires high temperatures can also be expected although the fire behavior will differ. Burning is likely to persist for extended periods of time. In all cases there is a high probability of rekindling in the tire pile even if the fire is controlled.

235

N F P A 2 3 1 D - - A 9 8 R O P

G-3 Definitions. Buru-It (F): A fire f ighting strategy that would allow for the free-

burn of a tire fire.

Bury-lt (F): A fire f ighting strategy that suggests burying a tire pile with soil, sand, gravel, cement dust or o ther cover material.

Concrete (A): A composite material that consists essentially of a binding med ium within which are e m b e d d e d particles or fragments of aggregate, in hydraulic cement concrete, the b inder is formed f rom a mixture of hydraulic cement and water.

Forecasting. The ability to predict the fire progression location prior to the complet ion of the inventory fire break using heavy equipment .

Scrap Tire (ST): A tire which can no longer be used for its original purpose, due to wear or damage.

Shredded Tire (ST): A size reduced scrap tire. The reduct ion in size was accomplished by a mechanical processing device, commonly referred to a "shredder".

Tactics (F): The me thod of securing the objectives laid out in the strategy through the use of personnel and equipment to achieve op t imum results.

Tire Chip (ST): A classified scrap tire p a r t i t e that has a basic

~ eometrical shape, which is generally two inches or smaller and as most of the wire removed (also refer to Chipped Tire).

C,-4 Fire Expedence . Fire exper ience in outdoor storage of scrap tires reveals a number of concerns, including lack of fire codes for scrap tire storage; the genera t ion of large amounts of black smoke; the fact that the storage is often too close to buildings on the same or adjacent premises, which causes fires in these exposed buildings; the generat ion of oil dur ing a fire where the oil contributes to the fire or where the runoff contaminates the sur rounding area; delays in repor t ing fires; and the lack of fire- f ighting capabilities. The fire hazards inhe ren t in scrap rubber tire storage are best controlled by an aggressive fire prevention program that includes a pre- incident plan.

C-5 General Fire Prevention. The fire hazard potential inheren t in scrap rubber tire storage operat ions can best be control led by a aggressive fire prevention program. The me thod of storage should be solid piles in an orderly manne r and should include:

(a) Fire lanes to separate piles and to provide access for effective fire-fighting operat ions should be a min imum of 40 ft wide in accordance wath Table C-4-2.3;

(b) Separat ion of yard storage f rom buildings, vehicles, f lammable materials, and o ther exposures should be a min imum of 200 ft;

(c) The area within 200 ft of pile should be totally void of trees, plants or vegetation;

(d) Topography will be a factor in the manne r of tire fire tactics and environmental mediation.

(e) Tires should no t be s tored on wedands, f lood plains, ravines, canyons or on steeply graded surfaces. Scrap tire storage preferably should be on a level area. The pre fe r red surface for the storage area is concrete or hard packed clay, no t asphalt or grass;

(f) Smoking should be prohibi ted within the tire storage area. Other types of potential ignition sources such as cutting and welding, heat ing devices, and open fires should be prohibited. Suitable safeguards should be provided to minimize the hazard of sparks from such equ ipmen t as refuse burners, boiler stacks, and vehicle exhaust.

(g) Piles should no t be permi t ted beneath power lines; or structures.

(h) Lightening protect ion systems, conforming to local and state codes, should be placed on the facility, but away from the tire piles.

(i) Piles should be at least 50 ft f rom the fences; lanes should be kept clear o f debris or vegetation;

Fire Depar tment Access to Site. Each fire storage yard should be provided with fire access routes:

(a) Each tire storage yard or pile should be provided with emergency vehicle access routes, such that no por t ion of the pile is more than 150 ft f rom an access road or fire break;

(b) All roads and accesses should be des igned to support the loads imposed by fire f ighting equipment .

(c) All bridges and structures, including drainage structures on access roads, should be capable of carrying a min imum design load of HS-20 per American Association States Highway Transporta t ion Officials AASHTO "Standard Specifications for Highway Bridges". The design and as-built plans for all bridges should be certified by a l icensed structural engineer; routes should be surfaced with material des igned to permi t accessibility under all climatic conditions;

(d) All emergency vehicle accesses should have unobstructed vertical clearance of no less than 13 ft 6 in., or as is needed to allow for passage of large fire f ighting equipment with a min imum outside turning radius of 45 ft should be provided for emergency vehicle access.

(e) All dead-end accesses in excess of 150 ft long should be provided with a turn-around area;

(f) Accesses should be well-maintained and remain accessible to the fire depar tment at all times, and; the fire chief may allow the use of alternative materials or processes to provide equivalent fire protect ion.

C-7 Site Security. Appropria te steps should be taken to limit access to the tire storage area:

(a) The facility should have a chain link fence at least 10 ft high with in t ruder controls on top (in accordance with local laws);

(b) There should be gates protect ing each access point (a min imum of one on each side), that can be locked when the facility is no t open for business.

(c) All gates should have a 20 foot open width and remain unobst ruc ted at all times;

(d) Gates should have rapid entry design compatible with local fire depa r tmen t requirements.

(e) Gates should have an op t imum activation system or equivalent and a compatible system approved by the local government . All electrically activated gates should have default capabilities to the unlocked position;

(0 A certified security a t tendant or site manager should be on site at all times when the facility is open;

(g) Clearly visible signs with business hours and regulations should be posted near the facility entrance.

C-8 Pre-Incident Planning. Pre-incident plans are developed by fire depar tments too identify special features and hazards at a particular site or property and specify the depa r tmen t operational plan. Pre-incident plans are specific to a location; analytical forecasting of types of emergencies that may be encountered complemen t the readiness efforts that are generally employed to manage emergency incidents.

It is strongly r e c o m m e n d e d that the fire depar tment adopt a model incident managemen t system that is published, taught to all members and regularly utilized. Neighboring (mutual aid) depar tments and outside agencies with whom the depa r tmen t must interact should be familiar with the depar tment ' s model incident managemen t system. Operational drills at the scrap tire facility involving mutual-aid companies and related agencies will be useful in evaluating shortfalls in the depar tment ' s response capability and fire g round effectiveness.

A thorough survey of the area under the jurisdiction of the fire depar tment should be under taken to detect the existence of scrap tire piles. In many areas the piles are remotely and illegally dumped. Once the areas have been surveyed and the existence of scrap tire piles identified, the magnitude of the problem should be

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N F P A 2 3 1 D ~ A 9 8 R O P

assessed and an appropriate fire prevention methodology developed.

Topographical maps and detailed area plot plans should be compiled, noting all features of the terrain and property, hydrants and water supply sources, accesses, interior lane-s or passages and fuel load configuration.

Ingress and egress plans should be developed for apl?aratus and equipment. The development of additionalaccess points, pre or post incident, should be analyzed and planned and the means of maintaining or expanding accesses provided.

Incident emergency contact personnel lists (names, addresses and multiple telephone/pager numbers) for the facility, appropriate agencies, contractors, mutual aid agreements, etc should be obtained. These lists should be updated on a semi- annual basis.

A water supply usage plan with estimated gallons per minute requirements should be developed.

G-9 Water Supplies. A public or private fire main and hydrant system should be provided. A water system should be provided to supply a minimum of 1,000 gpm (3,780 L/min) for less than 20,000 units storage (50,000 cu ft), or 2,000 gpm (7,560 L/min) for 20,000 units or more for a duration of 6 hours.

If there is access to a lake, stream, pond, or other body of water in the vicinity of the storage area, a tire department suction connection should be provided.

C-10 Pile Geometry ;rod Spacing. Maximum pile height should be 20 ft (6 m), pile width 50 ft (15 m), and length should not exceed 250 ft (76.2 m) without a separation according to Table G-10. (See Figure C-10.)

250 ft Mar. ~ Distance per Table C-10

Tire Pile .... Tire Pile SO ,t Max. F ...... , - - ' ~ - ~ ... I

~ - IDistance per Table C-10

I Distance per Table 0-10

I I Figure C-10.

The separation distances in Table C-10 were calculated using NFPA 80A, Recommended Practice for Protection of Building Exterior Fire Exposures, Chapter 2. The percentage of openings in the exposing wall area were considered to be 100 percent, and the severity of the exposing fire was considered severe. The height of exposing fire from burning tires was considered as 1.5 times the height of the tire pile since flames extending above the burning tires contribute to the size of the radiation surface area. In

accordance with NFPA 80A, the height of the exposing fire equals the building height. The height of combustibles stored within the building is not covered; it depends on the severity of the exposure fire. A comparative building height would have to exceed the height of piling by several feet at least, and it could be substantially higher. Furthermore, the height (and width) of flames above a fire-penetrated roof would be substantially influenced by the debris of the fire-damaged or collapsed roof, whereas flame height above yard storage would have no such restriction.

The width limitation of 50 ft means that as the exposed face exceeds 100 ft the pile takes on the appearance of a "wind row", and there is litde likelihood that the entire face would be burning at one time. Thus, in Table G-10 the minimum exposure separation distances are held constant for exposed face dimensions greater than 100 ft.

For 500 units or less, the minimum separation between scrap rubber tires and structures should be 25ft (7.6 m) or as reduced by Chapter 3, "Means of Protection," and Chapter 4, "Application of Means of Protection," of NFPA 80A, Recommended Practice for Protection of Buildings from Exterior Fire Exposures.

Fore Morethan500Uni ts .

In order for storage~iles to be considered isolated piles, the minimum separation distance between piles should be in accordance with Table C-4-2.3.

The width of the exposing fire should be taken as the combined width of piles facing the exposed building, disregarding the nominal separation between piles provided by narrow access aisles and roadways.

Because of the extensive fire expected in scrap tire storage, some form of exposure protection for adjoining properties should be considered, ff the clear space as recommended in Table C-10 cannot be provided, provide a dirt berm 1.5 times the height of the tire storage or other protection meeting the requirements of the authority having jurisdiction.

When baled tires are stored the storage should be vertical rather than horizontal. Under fire conditions the bands release allowing for sudden, drastic movement of burning tires.

C-11 Outdoor Tire Pile Fire Fighting Tactics and Strategy. The guidelines, contained, in this ap p endix, are based, upon the collective expermnces of fire serxqce professtonals who have managed major scrap tire tires and are presented as an adjunct to the strategic and tactical practices of an incident command system.

Conventional fire suppression tactics are ineffective for scrap tire fires. Fire fighting tactics and strategies for suppression of fires in whole tires versus processed tires differ. The unique shape of whole fires allows the storage of enough air to support combustion throughout the pile and it is difficult to reach all the burning surfaces. Because of these complications tire fires can continue for weeks, and even months despite aggressive fire suppression tactics.

The foundation of fire suppression should be based upon the data collected before the fire. With an established pre-incident plan utilizing a model incident command system, decisions regarding size-up, tactics, strategies, and overhaul can be resolved t~uickly. Familiarity with what has worked historically in tire fires

aroughout the country will also aid in the decision making process. These decisions should be based upon your understanding of the dynamics and behavior of a tire tire.

Table C-10 Representative Minimum Exposure Separation Distances 1 Tire Storage Pile Height (It)

Exposed Face Dimensions (ft)

8 10 12 14 16 18 20 25 56 62 67 73 77 82 85 50 75 84 93 100 107 113 118

100 100 116 128 137 146 155 164

150 100 116 128 137 146 155 164 200 100 116 128 137 146 155 164 250 100 116 128 137 146 155 164

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N F P A 2 3 1 D - - A 9 8 R O P

The environmental consequences of all suppression techniques should be evaluated carefully. Communicat ions between the incident commander and on-scene environmental specialist is critical.

Tactics/Strategies for Whole Tire Fires. Impor tant tactical considerations include protect ing exposures, separating burning tires from the rest of the inventory, and forecasting. Forecasting for an effective location for separation should include arrival time of equipment and t ime necessary to develop the needed fire break. Heavy equ ipment can be used to accomplish these tasks.

Protection of exposures will be an impor tant tactical decision.

The initial approach to a tire fire should begin with isolating the tire inventory from the fire. Creating fire breaks in a large scrap tire pile is a long and consuming process. But it can be accomplished with heavy machinery and front end loader.

Bulldozers, f ront-end loaders, and similar equ ipment may be permit ted to be used to move fires no t yet involved in the fire, to create breaks in the tire pile, or to cover burning fires with soil.

Equipment breakdown--scrap tires caught between the wheels, tracks, and undercarriage of heavy equ ipment - -have been reported. Firelines should be deployed to provide protect ion to operators and equipment alike.

Recognized strategy options are:

Let-it-burn Bury-it Drown-it. Lit-it-burn. Lett ing a tire pile burn has its merits. Factors

influencing this decision includes but no t l imited to, level of fire involvement, resources available, location of the fire, environmental and economic impact.

Soil and water pollut ion as well as the clean-up costs may be drastically reduced when many of the products of combust ion are consumed .

A preceden t for the let-it-burn strategy appears in fire responses to chemical fires.

The fire service must manage and control the burn process. Protecting exposures and separating tires from the burn area will still be a tactical priority.

Bury-it. The decision to bury a tire pile also has merits. Materlals as diverse as the soil on site, cement kiln dust, sand, gravel, and even crushed coral have been employed to cover the burn ing material.

The bury-it strategy could be employed in areas that have minimal water supply or in areas that densely populated. The decision to bury a tire fire should take into consideration reducing the toxic smoke for the sake of public health.

Geological considerations play an impor tant role in the bury-it strategy. While the tire fire is entombed, fires can pyrolize and oil can be genera ted and released into the soil or unde rg round water sources.

Drown-it. The drown-it strategy is best employed with fo re thought and careful pre-planning. Knowing in advance the topography, having the water supply available, and exposure hazards to above g round water sources will be critical. Planning for the control and con ta inment will facilitate this tactic.

The drown-it strategy also has some drawbacks. Cooling the fire will increase the air emissions as the combust ion process is slowed down. An inordinate amoun t of water runoff combined with pyrolitic oil can result form the drown-it tactic.

Tactics/Strategies for Processed Tire Fires.

Impor tant tactical considerations include protect ing exposures, separating burning tires f rom the rest of the inventory, and forecasting. Heavy equ ipmen t can be used to accomplish these tasks.

To effectively combat this type of fire, a fogging application of water or o ther fire retardant, should be applied. Cooling the plane of fire should put the fire out. Using a mist will also reduce the amount of water used, and the subsequent run-off that may be generated.

Unde r no circumstances should a processed tire pile be broken open or doused with streams of high pressure water, directed into the piles. Water actually increases the severity and duration of the fire by introducing oxygen into the pile and by breaking up the

~ ile, causing the fire to burst into flames and emit incompletely urned hydrocarbons and other contaminates to the atmosphere.

Once the surface fire is put out, the cooled chips should be removed, allowing water or fire retard,ant to r each under layers that are hot and still burning. This process should be repeated until chips are no longer smolder or hot.

Ancillary Issues. These include Fire Dynamics, Stages of Combustion, Size-Up, and Environmental Concerns. Refer to "Guidelines for the Prevention and Management of Scrap Tire Fires", International Association of Fire Chiefs and The Scrap Tire Management Council, 1400 K Street, N.W., Washington, DC 20005.

Add References unde r Other Publications.

"Rings of Fire, Fire Prevention and Fire Suppression of Scrap Tire Piles", Rodney Slaughter, Office of the State Fire Marshal. Available from CFSTES Bookstore, 7171 Bowling Drive, Suite 600, Sacramento, CA 95825-2034. SUBSTANTIATION: The modifications to Appendix C were done to update and clarify the previous appendix material. Many of the changes are based on research andac tua l field experience. The proposed changes to Appendix C provides details to the existing and sound guidelines found the appendix.

A scope and purpose . . . . s tatements were added to include baled and processed tares and to introduce the new material into the appendix.

General Fire Prevention, Fire Depar tment Access, Site Security and Pre-Incident Planning were modif ied and based on the "Guidelines for the Prevention and Management of Scrap Tire Fires" developed jointly by the International Association- of Fire Chiefs and the Scrap Tire Management Council. Tire piles were prohibi ted beneath powerlines and structures as a result o f a real fire beneath a bridge.

The water supply section was modif ied by increasing the 3 hr durat ion to 6 hr because experience and historical fire fighting tactics have shown that this new time durat ion is effective. The change in number of units are consistent with the new tire pile size geometry.

Existing section C-4, Exposure Protection was ret ided to Pile Geometry and Spacing. The pile geometry was modif ied based on fire f ighting experience which indicated that this new configuration allowed for both a storage pile and acceptable radiant flux level. The min imum exposure separation distances were left unchanged for exposed face dimensions of 100 ft or less. For exposed faces greater than 100 ft, the separation distances were he ldcons t an t because of real fire experience shows that with a 50 ft tire pile width no more than 100 ft of t h e p U e face is burning at one time. Many of these changes were b a s e d o n the paper "Fire Safety Assessment of the Scrap Tire Storage Methods," by Robert Brady Williamson, Ph D and Robert Allen Schroeder , MS presented at the I N T E ~ "96", March 26-28, 1996 at S t . Johns College, Cambridge England.

The new section on Outdoor Tire Pile Fire Fighting Tactics and Strategies for both whole tires and processed tires is new informat ion based on the "Guidelines" men t ioned above. The informat ion on processed tires is new information that has no t been previously addressed.

New definitions and references were added as needed. COMMITTEE ACTION: Accept in Principle. Accept the text as submit ted with the exception of the following:

Appendix C Guidelines for Outdoor Storage of Scrap Tires C-1 Scope. This appendix applies to the outdoor storage of

scrape tires in whole, baled, or processed form, including incidental usage locations.

G-3 Definitions. Burn-It: A fire fighting strategy that would allow for the free-burn

of a fire fire. Bury-Ie A fire f ighting strategy that sug~gests burying a tire pile

with soil, sand, gravel, c emen t dust or otlaer cover material.

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N F P A 2 3 1 D m A 9 8 R O P

Forecasting. The ability to predic t the fire progress ion location prior to the complet ion of the inventory fire break us ing heavy equ ipment .

Scrap Tire: A tire which can no longer be used for its original purpose , due to were" or damage .

Sh redded Tire: A .,,ize r educed scrap tire. T he reduc t ion in size was accompl i shed b) a mechan ica l process ing device, c o m m o n l y referred to a "shredder".

Tactics: The m e t h o d of secur ing the objectives laid out in the strategy t h rough the use of personne l a n d e q u i p m e n t to achieve o p t i m u m results.

Tire Chip: A classified scrap tire particle tha t has a basic geometr ical shape, ~ahich is general ly two inches or smaller and has mos t of the wire removed.

C-5 General. The fire hazard potential i n h e r e n t in scrap rubber tire storage operat ions can best be control led by an aggressive fire prevent ion program. The m e t h o d of s torage shou ld b e solid piles in an orderly m a n n e r and shou ld include:

(a) Fire lanes to separate piles and to provide access for effective fire-fighting opera t ions shou ld be in accordance with Table C-10;

C-10 Pile Geometr¢ and Spacing° M a x i m u m pile he igh t should be 20 ft (6 m), pi le width 50 ft (15 m) , a n d length shou ld no t exceed 250 ft (76.2 ra) wi thout a separat ion according to Table G- 10. (See Figure C-1£.)

_L_~--25o fl max.--* 1 Distance per Table C-10 I _ _ t T i r e p i le ] 50 ft max. I Tire pile [- -[

] Distance p e r T a b t e C-10 t

I Tirel, i,e I I Tirepi,e I 200 ft rain.

Building

Delete the second paragraph of G-10, "The separa t ion distances. . ."

500 Tires or Less. The m i n i m u m separa t ion between scrap rubber tires a n d s t ructures shou ld be 25 ft (7.6 m) or as reduced by Chapte r 3, "Means of Protection," a n d Chapter 4, "Application of Means of Protection," of NFPA 80A, R e c o m m e n d e d Practice for Protect ion of Buildings f rom Exterior Fire Exposures.

More than 500 Tires. In order for s to ragep i l e s to be considered isolated piles, the

m i n i m u m separa t ion dis tance between piles shou ld be in accordance with Table C-10.

In C-11, delete "Let-it burn", "Bury-it" and "Drown-it" the first t ime it appears as a list ( immediate ly after "Recognized strategy opt ions are:"). Let-it-burn. Let t ing a tire pile bu rn has its merits. Factors inf luencing this decis ion includes bu t no t l imited to, level of fire involvement, resources available, location of the fire, env i ronmenta l a n d economic impact. COMMITTEE STATEMENT: Edfitorially revised with correct ions to references a n d tables. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 10 N O T RETURNED: 2 0 ' R o u r k e , Walker

COMMENT O N AFFIRMATIVE: HOOVER: This will probably take the Public C o m m e n t but

mis in te rpre t the first sen tence of C-10 when I read it. My interpretat ion is that - - I mus t have a 20 ft pile height , 50 ft width, and 250 ft l eng th if my separat ion is less t han specified in Table C,- 10; but if I comply with Table G-10 I can t hen exceed one or all of the pile d imensions . I th ink we should end the first sen tence after ".. .exceed 250 ft (76.2 m)." T h e n add a second sen tence to the effect, "Pile separa t ion shou ld be in accordance with Table C-10 and Figure C-10."

Figure C-10 Pile geometry and spacing.

Table C-10 Representative Minimum Exposure Separation Distances I

25 Exposed Face 50 Dimens ions (ft) loo

150 2OO 250

Tire Storage Pile Height (ft)

8 10 12 14 16 18 20 56 62 67 73 77 82 85 75 84 93 100 107 113 118

100 116 128 137 146 155 164 100 116 128 137 146 155 164 lO0 l l6 128 137 146 155 164 100 115 128 137 146 155 164

1. Seperat ion distances are based on the paper "Fire Safety Assessment of the Scrap Tire Storage Methods," by Rober t Brady Will iamson, PHD and Rober t Allen Schroeder, MS.

Note to editor: Add the reference to "Fire Safety Assessment of the Scrap Tire Storage Methods" to Appendix D.

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