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fire code, sprinklers and building classification questions

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I'm working on fire permitting and building classification for our new distillery. We are located in an industrial type site, right next to a biodiesel plant. The building is stand-alone, with thick concrete walls and a metal roof, with 5 separate rooms that can be cordoned off easily. I have been looking around and studying online the code references pertaining to a distillery, and wanted to try to clarify a few references, and see what others have used.

IFC sec 3401.2(8) - exempts the storage of spirits in wooden casks. - Is there a storage height limit for this? I had read somewhere, without a reference that there was a 6ft limit, which would just be two barrels high. This may be addressed in 3403.3.6.3(1) - class IB would be 4 foot in unsprinklered and 8ft in sprinklered, or 12 foot in sprinklered with in rack protection. Is that what folks are having to go by? or 3403.3.6.3(3) - ground floor double row 25 ft high, with 15,000 gallons per room?

What is the space required between aisles of barrels, and the clearance for exits? again 3403.3.7.2.2 - 4 foot between aisles?

IFC table 2703.1.1(1) - is the MAQ for ethanol storage in anything other than a wooden cask 60 gallons without appropriate sprinklering, and 600 gallons with? Generally, if we are in seperate rooms that are separated by a fire wall, would that be 60/600 per room or for the whole building?

Is a pot still generally considered an atmospheric tank, or a pressure vessel? Do these generally need to be ASME stamped tanks, or can you have an atmospheric tank fabricated without being stamped?

That's it for now, thanks for the help.

chris

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You should consider hiring a fire code consultant or engineer. If you have them help you prepare a plan you'll have much better luck with your local officials and your own personal safety.

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I'm considering that option, but my partners are really the type that like to DIY whatever we can. We have the code books, so are trying to put it together ourselves.

We come from the biodiesel world, so have permitted a million gallon fuel plant, with 10,000 gallons of methanol in the yard, but it's a little different from Spirits.

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You may not have a choice regarding hiring a fire protection engineer. Talk to your city and see what their requirements are for starting a distillery. I had no choice but to hire a fire protection engineer to tell the city what I already knew, that my building was up to code for a distillery. The city makes you do silly stuff, just so they're protected and so that everyone get's a piece of your ever shrinking budget.

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I see you are in NC so the rules in Pittsboro should be similar to the rules in Chapel Hill and Durham. There is a rule on the books that you can only store 240gl of bulk flamable liquid in one contained room, but for some reason spirits in wooden casks or in bottles are not subject to that rule. So, at least from what the folks in Chapel Hill were told they had to do and what Durham has told us, even though your finished spirits are in a large metal tank you can only have that much per room. All this is so new to the officials down here that most of them are just kind of interpreting the law based off other flamable material regulations. I would meet with the local fire marshall and discuss everything with them. The other local distillers have been very helpful to us by descsribing any issues with local officials they encountered at this early phase, so we were kind of prepared to walk the fire guys through how other cities have interpreted the state regulations and they were fine with it.

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Thanks Revival. Where did you get the 240gal number? My reading was 60 gallons in an unsprinklered area of Class IB liquid. Are you building in Durham or Chapel Hill?

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We are building in Durham. The folks in Chapel Hill were required to do that seperation and that is how the fire guys in Durham interpreted the regulation also. Maybe because both places are in a downtown area with other buildings close by, it may be different where you are planning to build. We wanted to be certain the use was going to be allowed in a building before we purchased it so we met with all the zoning and fire folks very early in the process. Everyone has been very excited and helpful thus far.

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Check your state Structural Specialty Code, it's most likely this for an F1 rating: If ABV is greater than 60% you can have 30 gallons on site, if the building is sprinklered you can have 60 gallons. If the ABV is below 60% you can have 120 gallons, or 240 gallons in a sprinklered building.

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The advice above is good, get an engineer which will cost you some $ upfront but will save you $$$ later when your local Fire/Building Department evaluates your project. They won't be arguing with your engineer but they will with you. Buy the codes and read them.

This is an overview and not all inclusive. An F1 occupancy allows for production of beverage grade alcohol of more than 18%. IFC table 307.1(1) limits a non-sprinklered F1 to 120 gallons of class IB-IC flammable liquids and class II combustible liquids at 120 gallons. Per table 2703.8.3.2 this limit is per control area. A control area is defined as a room with a 2hour fire rated wall and you can have multiple control areas per floor depending on construction and building type. Sprinklers increase the hour rating in a room/building and double this capacity limit, thus the 240 gallon.

The barrel exemption per IFC chapter 27 - 2701.1-9 and IFC chapter 34 3402.1-10 is just that, so the rest of the chapter does not apply including height limitations, etc.

Most spirits are bottled as Class II combustible liquids. Spirits stored in containers less than 1.3 gallons (5L) in storage are excluded from the volume limits per IFC chapter 27 - 2701.1-1 and IFC chapter 34 3402.1-2. Once packaged, the individual bottles should be stored in cases and placed on pallets by product type.

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Thanks for the clarification, Kristian. That is helpful.

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So if i am reading this right and im probably not the limit for storage is 240 gallons with sprinklers? I have been to multiple places where they have had much more than this. Some I have seen have had 4x this amount (4 X 275 gallon totes of GNS) How do these guys do this if the limit is 240? Seems like one tote would put you over it.

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So are all you guys getting away with an F1 rating? My local fire guy is hinting that a distillery might fall into the H-2 category.

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So if i am reading this right and im probably not the limit for storage is 240 gallons with sprinklers? I have been to multiple places where they have had much more than this. Some I have seen have had 4x this amount (4 X 275 gallon totes of GNS) How do these guys do this if the limit is 240? Seems like one tote would put you over it.

They might very well know that their maximum allowable quantity per containment area is 240g in a closed container and 60 in an open container -- they might be choosing to ignore it. Fire inspectors do not stop in on a daily basis. Once they sign off on your operation, it's up to you to stay safe and code compliant.

My distillery is an F1 without sprinklers. I'm held to an MAQ of 30g open and 120g closed. It's tough to stay within those limits but I do my best. Amongst other things, hat means no totes of GNS (who needs GNS anyway ;)

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Since IFC exempts wooden cask from potential hazardous containment classification, local building code shouldn't be able to restrict you capacity. An F-1 Classification due to flammable liquid storage would limit the volume per control room to 120 gallons NS or 240 with a sprinkler given your containment vessel is not exempt. Since it is, there is no fire barrier subdivision or capacity regulation, only a height restriction of 2 ft. from the ceiling. In other words disregard local code pertaining to maximum allowable amounts under F classification with or without sprinklers, IFC exemption supersedes.

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Since IFC exempts wooden cask from potential hazardous containment classification, local building code shouldn't be able to restrict you capacity. An F-1 Classification due to flammable liquid storage would limit the volume per control room to 120 gallons NS or 240 with a sprinkler given your containment vessel is not exempt. Since it is, there is no fire barrier subdivision or capacity regulation, only a height restriction of 2 ft. from the ceiling. In other words disregard local code pertaining to maximum allowable amounts under F classification with or without sprinklers, IFC exemption supersedes.

My understanding is that a local fire/building inspectors' interpretation of the code supersedes all — regardless of how flawed their interpretation (or overall character) might be. Also, the 120g limit is based on spirit being stored in an atmospherically closed container. In open containers that limit drops to 30g. If a 50'some gallon oak cask is filled in an F1 occupancy without sprinklers, the filling beyond 30g, with bung out, would exceed the max allowable quantities. A total technicality, since the container is only "open" for a very short time, but one that my fire inspector would not cut us a break on.

If other folks are not held to such stringent definitions of maq's within an F1... consider yourselves very lucky.

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My local folks are still pushing that barrels are not exempt, the fire folks say OK, then the building folks say 'it is in the fire code, not the building code, so you are extra hazard'..

From what I read, 'in-process' liquids are also exempt from the MAQ's... But then again if you make a control area H-x, MAQ's go out the window and you can do whatever the heck you want...... except have more than 3 people in the room, LOL... I hear a lot of distillers say that that occupancy limit only counts when the still is not operatiing, but have yet to see that in code...

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My local folks are still pushing that barrels are not exempt, the fire folks say OK, then the building folks say 'it is in the fire code, not the building code, so you are extra hazard'..

From what I read, 'in-process' liquids are also exempt from the MAQ's... But then again if you make a control area H-x, MAQ's go out the window and you can do whatever the heck you want...... except have more than 3 people in the room, LOL... I hear a lot of distillers say that that occupancy limit only counts when the still is not operatiing, but have yet to see that in code...

Can you tell me where exactly you found "in-process" liquids are exempt from maq?

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My understanding is that a local fire/building inspectors' interpretation of the code supersedes all — regardless of how flawed their interpretation (or overall character) might be. Also, the 120g limit is based on spirit being stored in an atmospherically closed container. In open containers that limit drops to 30g. If a 50'some gallon oak cask is filled in an F1 occupancy without sprinklers, the filling beyond 30g, with bung out, would exceed the max allowable quantities. A total technicality, since the container is only "open" for a very short time, but one that my fire inspector would not cut us a break on.

If other folks are not held to such stringent definitions of maq's within an F1... consider yourselves very lucky.

Fortunately, the short time the barrel is un-bunged was disregarded or they just don't care. Seems like they really want the distillery. Cant believe your getting that kind of response in Colorado

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Can you tell me where exactly you found "in-process" liquids are exempt from maq?

several places have something about this, here is one from the 2006 IBC(exemption 5):

SECTION 307

HIGH-HAZARD GROUP H

[F] 307.1 High-hazard Group H. High-hazard Group H occupancy includes, among others, the use of a building or structure, or a portion thereof, that involves the manufacturing, processing, generation or storage of materials that constitute a physical or health hazard in quantities in excess of those allowed in control areas constructed and located as required in Section 414. Hazardous uses are classified in Groups H-1, H-2, H-3, H-4 and H-5 and shall be in accordance with this section, the requirements of Section 415 and the International Fire Code.

Exceptions: The following shall not be classified in Group H, but shall be

classified in the occupancy that they most nearly resemble:

1. Buildings and structures that contain not more than

the maximum allowable quantities per control area

of hazardous materials as shown in Tables 307.1(1)

and 307.1(2), provided that such buildings are maintained

in accordance with the International Fire Code.

5. Closed piping containing flammable or combustible

liquids or gases utilized for the operation of machinery

or equipment. (if you still was a closed system, the parrot, cutting valve, etc all not exposed to the atmoshere)

Here is another from 2008 NFP30:

Chapter 9 Storage of Liquids in Containers —

9.1.4 This chapter shall not apply to the following:

(1) Containers, intermediate bulk containers, and portable tanks that are used in operations areas, as covered by Chapter 17

(2) Liquids in the fuel tanks of motor vehicles, aircraft, boats, or portable or stationary engines

(3) Beverages where packaged in individual containers that do not exceed 1.3 gal (5 L) capacity

...

(7) Distilled spirits and wines in wooden barrels or casks

So this one, the same one that exempts bottles in a liquor store and wooden casks, also covers "Containers, intermediate bulk containers, and portable tanks that are used in operations areas"

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My local folks are still pushing that barrels are not exempt, the fire folks say OK, then the building folks say 'it is in the fire code, not the building code, so you are extra hazard'..

From what I read, 'in-process' liquids are also exempt from the MAQ's... But then again if you make a control area H-x, MAQ's go out the window and you can do whatever the heck you want...... except have more than 3 people in the room, LOL... I hear a lot of distillers say that that occupancy limit only counts when the still is not operatiing, but have yet to see that in code...

I would also be interested to know where you read that in-process liquids are exempt from the MAQs. That would change a few things in planning.

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I would also be interested to know where you read that in-process liquids are exempt from the MAQs. That would change a few things in planning.

Read the post previous to yours...

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Just had the County Fire Marshall and Building Inspector out to see the place. It's an empty building right now that I've been cleaning and painting and removing unneeded electric from. The building was originally built for Class 1 explosive, so it's got 1 foot thick concrete walls, a blow-out metal roof, and the electrical in my still and barrel rooms is Class 1 Group D.

I passed Building and Fire, and will NOT need to sprinkler due to the size of the rooms, and am exempt from high storage requirements. The rooms are 16x16x20' high, so I can stack barrels 4-6 courses high. This is major news for our business! There was no question about storage quantities, though I did tell him we would be storing the spirits in oak barrels.

I'm still gonna look into fire/smoke alarms, but I don't think we will go with sprinklering for now.

Chris

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Read the post previous to yours...

I have read it and i still dont see where it ways "liquids in processing are exempt" What am i missing

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We are going through this process now. We are being told that if our still or even our fermenter exceeds 240G, we will fall out of F-1 and fall into high hazard. Does the largest fermenter or still really count towards the 240G cap? We plan to double distill with two sized stills so our larger still will likely never be filled with anything over (at most) 15% ABV. From my quick reading, that low of an ABV doesn't have enough of a flash point to be considered a Class IB flammable liquid. My feeling is that only the stored alcohol of more than about 40% meets this qualification and we should be able to operate a still in excess of 240G if it it never filled with more than 40% ABV low wines. Thoughts?

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