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spirit holding tanks - codes?


nabtastic

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36 minutes ago, Thatch said:

The attached file spells it out pretty clearly.  One hour fire protection between control areas and between your F-1 space and a control area.  

201903050718.pdf 294 kB · 1 download

Wow, thanks, Thatch!   Exciting diagram and text!  That is exactly what we have proposed.   I did not see, or did not understand a requirement for actual sprinklers inside the 3 additional zones, or the combination of building automatic sprinklers with 1-hour-fire-cabinets (our 1-hour sheet-rock/fire-door 'cabinets' or 'closets) is sufficient.  If the latter,then we can skip the fire system modifications!   Hugely helpful.

Let me add my thanks also to each of you who are commenting and educating me on this process. 

The more I know, the more I know the less I knew!    Cheers!

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received this from fire services contractor - to whom I had sent the PDF from Thatch - perhaps that document had not made it to the designer.     Welcome comments:

Ok, this is tricky.

As noted below NFPA #30 excludes barrels of distilled spirits.  Based on that, then it would defer back to NFPA #13.

Based on NFPA #13, I believe the storage areas would be extra hazard 2.  The distillery area would be ordinary hazard II.

5.4.2* Extra Hazard (Group 2).

Extra hazard (Group 2) occupancies shall be defined as occupancies or portions of other occupancies

with moderate to substantial amounts of flammable or combustible liquids or occupancies

where shielding of combustibles is extensive.

 

I think the existing system in the storage area needs to be evaluated/upgraded to meet extra hazard 2 occupancy.

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1 hour ago, et1883 said:

Extra hazard (Group 2) occupancies shall be defined as occupancies or portions of other occupancies

with moderate to substantial amounts of flammable or combustible liquids or occupancies

where shielding of combustibles is extensive.

All I can say is we are not being held to this standard.  I'm not sure what the definition of moderate to substantial is, his interpretation would seem to be the key.  But, given the fact that you would not be exceeding the MAQ's in either your distillery nor your control areas it would not seem that this is moderate to substantial.  10,000 gallons is moderate to substantial, 960 is a drop in the bucket.  I did a quick check on the NFPA definition of moderate and substantial but could find nothing in regard to quantity.  I would think that next step would be to get an interpretation from the NFPA.  Hopefully your fire services contractor will read the last thing I sent you closely because it is exactly what you want to do.

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Roger that.  Waiting for reply from the fire services contractor.   There is an unfortunate conflict of interest in that the guy providing sprinklers is the gateway to approvals.  Hopefully, this will be easy (!) :-)  Thanks again!

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19 hours ago, et1883 said:

Roger that.  Waiting for reply from the fire services contractor.   There is an unfortunate conflict of interest in that the guy providing sprinklers is the gateway to approvals.  Hopefully, this will be easy (!) 🙂 Thanks again!

What I sent is commentary from the NFPA.  Although commentary is not code it is a guideline to interpreting code.  I cannot imagine any conflict of interests overcoming what is in black and white.  Stick to your guns and ask for a second opinion.

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  • 1 month later...
  • We are now talking with a 3rd fire services contractor - 1st stopped responding; 2nd wanted a month for research and wanted larger projects than ours; 3rd seems to be on the mark.  I did hand him the document you provided on 4 zones (pdf on Mar 5th) and NFPA 30 discussion on barrels.   Expecting a proposal soon for 3 new sprinkler heads in each of 3 new 1-hour-zones (each a tote size closet, generally).   Appreciate the background and insights.  Hoping for early resolution and moving ahead with 4 zones F-1, each with 240gal, not including barrels/bottles.  
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3 minutes ago, et1883 said:

We are now talking with a 3rd fire services contractor - 1st stopped responding; 2nd wanted a month for research and wanted larger projects than ours; 3rd seems to be on the mark.  I did hand him the document you provided on 4 zones (pdf on Mar 5th) and NFPA 30 discussion on barrels.   Expecting a proposal soon for 3 new sprinkler heads in each of 3 new 1-hour-zones (each a tote size closet, generally).   Appreciate the background and insights.  Hoping for early resolution and moving ahead with 4 zones F-1, each with 240gal, not including barrels/bottles.  

Congrats!

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On 3/3/2019 at 3:33 AM, Thatch said:

we were looking into tanks, until the landlord said no outside tanks permitted.  😞

 

 

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  • 2 years later...

I helped a distillery set up a while ago to have outside spirit storage tanks to fall under the MAQ and it worked out well for them. 

If ya need more detail drop me a line Distillerynow@gmail.com

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There is no TTB issue with outside tanks per se.  They have been around since well before the 1970s. 

Such tanks must be included on the registration. §19.74   Description of the plant. "As required by §19.73(a)(8), the application for registration must include a description of the distilled spirits plant. This information must (d) Describe each building and outside tank that will be used for production, storage, and processing of spirits and for denaturing spirits, articles, or wines. The description must include the location, size, construction, and arrangement with reference to each by a designated number or letter.

The security requirement is minimal.  §19.192   Security.  (c) Outdoor tanks.

The security requirement for the pipelines or hoses used to transfer between inside and outside are also minimal, but subject to more interpretation:  §19.187   Pipelines.  All pipelines, including flexible hoses, that are used to transfer spirits, denatured spirits, articles, and wines must be constructed, arranged, and secured so as to ensure protection of the revenue and permit ready examination. The appropriate TTB officer may approve pipelines that cannot be readily examined if they pose no jeopardy to the revenue.

I know the issue is landlords and fire codes, but outside tanks are certainly possible in certain jurisdictions with the blessing of certain landlords.

 

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You can have up to 4 control areas.  Take a look at the doc from my March 5, 2019 post in this thread.

However, this may not be the way to go moving forward.  What are you really trying to do, have a MAQ higher than 240 gallons but remain F-1?  If you could give some background as to the problems you are encountering or your goals, someone here will likely be able to help.

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22 minutes ago, Triangle Distiller said:

No, We have 4 control spaces each with 240 Gallons - total 960 under roof

Okay, so you're all set and do not have a question or problem, right?

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23 minutes ago, sandytoes said:

Does anyone know the implications on MAQ to storing IBC(s) in shipping containers outside? This would offer more security for outside storage.

IBC's may not be used for storage, they are only for shipping.  https://www.dalkita.com/prohibition-on-flammable-liquids-in-plastic-totes/

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1 hour ago, sandytoes said:

Need some help here! My AHJ is saying that the barrels and the bottles are to be treated the same as bulk storage. Can someone please point me to where those are exempt under NFPA?

https://codes.iccsafe.org/content/IFC2018/chapter-50-hazardous-materials-general-provisions

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23 hours ago, sandytoes said:

Thatch - Thank you! We really do appreciate it.

 

On 10/5/2021 at 12:59 PM, Thatch said:

Thatch -

Now I am being told that the exception only applies if in a sprinkled space. Otherwise I am limited to the 120 gallons as a H3 space since the exception only applies to the wood and not the contents of the barrel... I couldn't make this up if i tried...

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21 minutes ago, sandytoes said:

Now I am being told that the exception only applies if in a sprinkled space. Otherwise I am limited to the 120 gallons as a H3 space since the exception only applies to the wood and not the contents of the barrel... I couldn't make this up if i tried...

Unfortunately he is incorrect.  He is your AHJ and it sounds like he does not want any of the devils brew in his domain.  You need to tread very lightly here.  Did you ask him to provide the specification he was referencing?  He may simply tell you that it's that way because he said so.  People like @Dalkita can quote chapter and verse of what is allowed but that will cost you a consulting fee.  Here's their take on MAQ  https://www.dalkita.com/maqs-maximum-allowable-quantities/  I am not an architect or engineer, they are.

Are you a H3 classification now?  The only way you would be classified as H-3 would be if you were exceeding the 120 gallons since you are not sprinkled.  If you stay under 120 gallons you would be F-1 since you are not sprinkled.  The table he should be referring to is at 307.1  check out notation c. at the bottom of the table.  https://codes.iccsafe.org/content/IBC2018/chapter-3-occupancy-classification-and-use  

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