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Toledo Refinery

Site Technical Practices EP 3-5-1

FIRE PROTECTION PHILOSOPHY of 12

June 2012 Revision 1.0

Maintained by E2G – Shaker Heights, OH

TABLE OF CONTENTS

1.0 SCOPE ............................................................................................................................................... 2 2.0 REFERENCES ................................................................................................................................... 2 3.0 DEFINITIONS ..................................................................................................................................... 3 4.0 GENERAL FIRE PROTECTION PHILOSOPHY ............................................................................... 4 5.0 SITE DESCRIPTION .......................................................................................................................... 4 6.0 GENERAL PROTECTION STRATEGY ............................................................................................. 5 7.0 RESPONSE AND INTERVENTION ................................................................................................... 6

7.1 Level 1 ........................................................................................................................................... 6 7.2 Level 1.5 ........................................................................................................................................ 6 7.3 Level 2 ........................................................................................................................................... 6 7.4 Level 3 ........................................................................................................................................... 6

8.0 SPECIFIC ASSET PROTECTION STRATEGIES ............................................................................. 6 8.1 Process Units (ISBL) ................................................................................................................... 7 8.2 Storage Tanks (OSBL) ................................................................................................................ 7 8.3 Loading Facilities ........................................................................................................................ 9 8.4 Buildings and Facilities ............................................................................................................ 10

9.0 TABLES ........................................................................................................................................... 11

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1.0 SCOPE

1.1 The scope of this document is directed at providing a general overall fire protection philosophy. This document will also provide equipment specifications, for the user to ensure that all equipment is standardized across the site.

1.2 The purpose of this document is to provide project engineering teams, maintenance personnel, operations personnel and HSSE (Health Safety Security and Environmental) professionals with a consistent overall guidance framework for protecting people and fixed assets at Toledo Refinery, from explosion and fire.

1.3 The most important part of any fire protection program is the protection philosophy. Site Technical Practices (STP), Group Engineering Technical Practices (ETP), Process Safety Minimum Expectations (PSME’s) and National Standards (NFPA, API) provide the basic minimum design requirement guidance for fire protection. Like all refinery and chemical manufacturing sites across the globe, Toledo Refinery bears its own special set of risks and characteristic hazards. The Fire Hazard Analysis (FHA) and the resulting Fire and Explosion Hazard Management Plan (FEHMP) are vital. BP’s Group Practices GP-24-20, GP-24-21 and GP-24-22 provide guidance and tools that enables engineers, designers and advisors alike, determine how to best protect people and fixed assets based on sound science and astute application of technology can result in inherent “fit for purpose” protection.

1.4 Any deviation from this Practice must be approved by the procedure described in EP 1–1–3.

1.5 An asterisk (*) indicates that a decision by the Owner’s Engineer or Owner is required, or that additional information is furnished by the Purchaser.

1.6 A revision bar indicates all changes made to this Revision.

2.0 REFERENCES The latest edition of the following standards and publications are referred to herein.

STANDARDS AND PUBLICATIONS

Site Technical Practices

EP 1–1–3 Deviations to Site Technical Practices EST 16–1–1 Fire Hydrant and Monitor Fire Hydrants EST 16–2–1 Fire Hydrant Underground Isolation Watch Valve EST 16–3–1 Fire Water U/G Isolation Valves with Trench Adapters EST 16–4–1 Fire Water U/G Isolation Valves with Post Indicators EST 16–5–1 Fire Water U/G Drain Valves EST 16–6–1 Ultra Hydrants EST 16–7–1 Station Monitor EST 16–8–1 Oscillating Fire Monitor EST 16–9–1 Unit Hose Reel with Portable Monitor and Dry Hose Stations EST 16–10–1 Portable Fire Extinguishers EST 16–11–1 Portable Water Thief

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Site Technical Practices (Cont.)

EST 16–12–1 Transportable Portable Foam/Water Monitors EST 16–13–1 Fire Protection Systems, Valves, Strainers and Devices EST 16–14–1 Storage Tank Fire Protection EST 16–15–1 Emergency Safety Shower and Eye Wash

BP Group Practices

GP 24-10 Fire Protection On-Shore GP-24-21 Fire Hazard Analysis GP-24-22 Guidance on Practice for Gas Explosion Analysis GP 24-40 Fire Protection for Atmospheric Storage Tanks GP 30-85 Fire and Gas detection GP 44-10 Plant Layout GP 44-30 Design and Location of Occupied Buildings GP 48-02 HAZOP GP 48-50 Major Accident Risk Process

API

API 2021 Management of Atmospheric Storage Tank Fires API 2023 Guide for the Safe Storage and Handling of Heated Petroleum Products

NFPA

NFPA 11 Foam Systems NFPA 13 Fixed Water Sprays NFPA 20 Fire Pump Performance Specification

3.0 DEFINITIONS

3.1 Contractor - Company or business that agrees to furnish materials or perform specified services at a specified price and/or rate to the Owner.

3.2 Inspector - A Toledo Refinery appointed engineer or inspector.

3.3 Owner – The Toledo Refinery.

3.4 Owner’s Engineer – A Toledo Refinery appointed engineer.

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4.0 GENERAL FIRE PROTECTION PHILOSOPHY

4.1 Minimize the impact of fire by reducing the size and intensity of the size of the fire problem.

4.2 The strategic goal of the philosophy is to: 1) Save lives and prevent injury, 2) Prevent escalation 3) Minimize business economic loss.

4.3 The Priorities of protection that support the philosophy are: 1) Use sound performance based engineering while applying best available technology. 2) Use a balance application of the inherently safe design practice that includes:

• Early detection methods and systems • Risk based application of passive protection to exposed support structures • Strong active protection Fire water system(s) for control and suppression • A robust set of fire prevention and response programs

5.0 SITE DESCRIPTION

5.1 The current kit at Toledo Refinery has been in operation for over 40 years, although there have been several upgrades over this time frame. Capacity averages 140,000 bbls/day depending on crude mix, through 18 processing units. The basic layout sets all of the processing units in core of the site. The refinery processing kit has a variety of processing units that use both high and low pressure catalytic reaction processes and classic thermal cracking distillation processes. These units have a range of capacity and size. There are sizable inventories within the process units that if released and uncontrolled can and will cause significant risk to personnel and potential damage or loss to the facility asset. The core is surrounded by raw and finished product tankage. The largest storage tank is a 220 ft. crude oil tank.

5.2 The processing core is highly integrated. The minimization of piping length and energy efficient design results in a very compact congested layout, with little spacing between unit battery limits. Long multi-tiered pipe racks, some with air coolers resting on top are found bisecting the processing core.

5.3 Operators’ shelters and occupied buildings found inside the operating core are of blast resistant design. There are main structures or pods located on the fringes of the unit plot that house all the operators and staff for the areas, and are suites as “shelter in place structures. There are other smaller blast resistant buildings located deeper in the plot which are used as sign-in stations and general business use structures that are periodically occupied and are NOT designated as shelter in place structures.

5.4 All utilities except for electricity are produced within the operating core. Boiler feed water and steam are produced using three boilers producing 600 psi unsaturated steam. There are two major cooling tower areas; one in the north area the other in the east area. The cooling towers are of wooden design using classic counter-flow induced draft fans.

5.5 All administrative, maintenance shops and warehouses are located on the outer fringes of the site close to and along the south and north boundary fence lines.

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5.6 The firewater ring main has been recently over hauled (started in 1989) with about 90% of the original cast iron underground piping, valves and hydrants being replaced with Class 50 and 52 cement lined ductile iron pipe. The main cross on the grid is 16 inch main. The secondary branches are all 12 inch with 8 inch feeders to all hydrants and station monitors.

5.7 The current primary water supply originates in Lake Erie. The system pressure is maintained at 110 psi by a 2,000 gpm service pump, located at the Water Pump Station (WPS). The primary fire pumps are diesel powered - two 5,000 gpm and one 7,000 gpm - all rated at 150 psi discharge pressure. They are located on the first floor of the Water Pumping Station and are remotely started and controlled from the refinery Central Control Room. Back-up pump capacity of 7,000 gpm is provided by an electric powered 5,000 gpm pump and a diesel powered 2,500 gpm pump. Both are located on alternate water supplies. Both have rated discharge pressure of 130 and 150 psi respectively.

6.0 GENERAL PROTECTION STRATEGY

6.1 Fireproofing should be installed as determined during the Fire Hazard Analysis (FHA) and using guidance found in the BP guidance note (“blue book”) on passive protection and the Site Technical Practice on fireproofing. Intumescent coating is the preferred material of choice due to its inherent strength and durability. Although less durable and requiring more substantial maintenance and upkeep costs, any one or more of the fireproofing material types or systems may be used to achieve fire protection of selected structural elements.

6.2 The use of early fire and gas detection systems and emergency isolation valves should be part of the overall inherent protection and control of flammable/toxic liquids and gases. Emergency Self-Contained Breathing Apparatus must be provided for the protection of personnel during response to toxic releases.

6.3 The total fixed primary/secondary pumping capacity will be sized to 150% of the required flow requirements for single largest fully involved unit or tank fire scenario, whichever one is larger. Process unit flow will be based on The Fire Hazard Analysis approach, which matches fire protection closely to the fire risk. Prescriptive water application rates found in technical practices are the base case, and will generally tend to undersize water flow requirements.

Note: 150% ensures adequate supply for exposure protection and escalation intervention and control. Flows over 100% can be achieved at 80% of the designed line pressures. All can be achieved with any standard NFPA 20 Fire Pump Performance Specification and right sizing of water supplies and fire water main piping system.

6.4 Mobile or portable pumping units must be matched to 125% of the single largest storage tank scenario. This equipment must have matched foam making capacity. There is a strong case for mobile fire apparatus to be fitted with elevated master streams, ladder and platform features to facilitate rescue and water application.

6.5 Storage tank protection will have minimum protection features as required in GP 24-40 Fire Protection for Atmospheric Storage Tanks. Toledo does have a simplified fixed protection methodology that meets the intent of this Group Practice and will be described in the Storage Tank Detail Philosophy.

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7.0 RESPONSE AND INTERVENTION Fire response and intervention at BP Toledo Refining is a tiered system of response that starts with general refinery population, then the “On-unit” Operations Teams, the Emergency Response Team and mutual aid from outside fire departments and industrial teams. ● Level 1 Incipient response (general population) ● Level 1.5 Fire and damage control activities (operations teams) ● Level 2 Post incipient response (ERT inside the fence line resources only) ● Level 3 Post incipient response with outside help

7.1 Level 1 Early incipient intervention by all employees is the first level of Active protection. The general population receives annual training in: ● Emergency response procedures with focus on sounding the alarm ● Evacuation and census procedures ● Portable fire extinguishers

7.2 Level 1.5 This level is in place for those employees who work in operations. The employees are trained to respond to all types of fire and non fire scenarios. All post incipient response activities are expected to be defensive in nature until the size and intensity of the event is reduced to a level that enables them to safety stabilize the situation. These employees receive the entire Level 1 training plus: ● Pre-planning ● Use of hose lines, and portable monitors ● Use of fixed fire hydrants and foam water monitors ● Use of fixed water spray systems

7.3 Level 2 Emergency Response Teams (ERT) are at the core of the site active protection program. Employees who are members receive comprehensive training in Advance Exterior Fire Fighting. Details relating to the ERT can be found in the site ERT organizational statement.

7.4 Level 3 Mutual aid and support will be provided from the Oregon Fire Department. Industrial support will come from Sun Oil Refinery. The Oregon Fire Department receives annual training at the refinery firefighting grounds. Sun Oil has a trained fire brigade.

8.0 SPECIFIC ASSET PROTECTION STRATEGIES A formal review of the asset release and/fire scenarios should be undertaken to ensure that all hazards have been identified. The full FHA (Fire Hazard Analysis) process must be completed for new projects. A Simplified or abbreviated version may be used during for smaller projects, HAZOP or PHA activities, on existing asset to determine the fire hazard management strategy.

The review should include the following steps below. The full FHA process is described in GP 24-21. ● Identify areas where hazardous flammable inventories are present (e.g., from HAZID) ● Determine inventory of fire hazards ● Identify size of each flammable inventory ● Identify fire type ● Identify personnel, equipment, and structures that may be affected by fire

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● Determine size of uncontrolled hazard zones ● Identify size and duration of hazard zones for flame envelope and radiant heat fluxes that

correspond to impairment criteria ● Review location of personnel and muster locations and embarkation areas against hazard

zones for relevant impairment criteria ● Identify which structures and equipment can be exposed to flames for periods longer than

typical failure times ● List paths to escalation

The strategies below are based on historical events and reasonable professional application of fire protection technology.

The chosen protective and mitigation strategies shall: 1) Aim to reduce the risks to personnel both at the facility and offsite locations. 2) Address business losses and the need to prevent escalation to a major incident. 3) Meet targets for individual risk and major accident frequency (See GDP 3.1-0001 which

provides a corporate risk matrix and GP 48-50 - Major Accident Risk Process.)

8.1 Process Units (ISBL - Inside Battery Limits)

8.1.1 As stated in the facility descriptions above, the oil processing area is a compressed moderately congested layout. These conditions encourage the requirement for fixed foam and/or water spray systems and devices. There are strong cases for the use of inherent emergency inventory isolation valves, both fire and gas detection systems and passive fire protection above the minimum technical practices. Equipment within and adjacent to each unit creates the need for higher than normal ring main water supplies. Extraordinary elevated exposures, obstructed accessibility, choked sewers and curbed containment inside the battery limits can foster a higher probability of escalation, requiring innovative fit for purpose application of fire protection engineering standards.

8.1.2 As with all new construction or major modifications, a review of the inherent hazards and associated risk level will form the basis for protection. Determination of the best approach for protection will be based on the collection of standard site safety and protection assessment processes such as: ● HAZOP ● PHSSER (Process Health Safety Security and Environmental Review) ● FHA’s ● The resulting FEHMP will define these measures.

8.2 Storage Tanks (OSBL - Outside Battery Limits) The protection for storage tanks are based on the guidance found in: ● GP 24-40 Fire Protection of Atmospheric Storage Tanks ● GP 24-10 Fire Protection On-Shore Chapter 14 ● NFPA 11 Foam Systems ● API 2021 Management of Atmospheric Storage Tank Fires ● Refining Defined Practices for the materials being handled ● Applicable Site Technical Practices for fire protection

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As with all new construction or major modifications a review of the inherent hazards and associated risk level will form the basis for protection. Determination of the best approach for protection will be based on the collection of standard site safety and protection assessment processes such as: HAZOP, PHSSER, and FHA’s, resulting FEHMP will define these measures.

8.2.1 Open Top Floating Roof The open top floating roof storage tanks are the most prominent storage tank in the facility. The size and spacing is varied based on need and available space. The tiered protection strategy applied ensuring safe effective fit for purpose protection for the most likely fire event are: 1) A completed pre-fire plan for seal and full surface fire scenarios must be completed and

validated. 2) Fixed semi automatic rim seal system of foam makers supplied via multiple dry risers,

connected to no more than two makers. These foam makers are to be sized 25% over the minimum in order to accommodate the failure or under performance of one of the chambers in the system.

3) A gauging platform fire fighting array will be installed on each tank. This will provide a 4-inch dry riser supplying a foam chamber, hose line connection and a portable monitor docking point to support the fixed chamber system and can be used for tank servicing and maintenance.

8.2.2 Covered Internal Floating Roof The covered internal floating roof tank present a complex set of protection challenges and hazards. The use of these types of tanks is to protect product quality and/or the environment. The protection for this type of tank is based on the guidance found in GP 24-40 Fire Protection of Atmospheric Storage Tanks, and NFPA 11 Foam Systems and API 2021 Management of Atmospheric Storage Tank Fires. The preferred protection strategy applied ensuring safe effective fit for purpose protection for the most likely fire event is: 1) A completed pre-fire plan for seal and full surface fire scenarios must be completed and

validated. 2) Fixed semi automatic full surface system of foam makers supplied via single dry riser,

connected to no more than 1 maker. These foam makers are to be sized 50% over the minimum in order to accommodate the failure or under performance of one of the chambers in the system. The dry riser terminal connection will be located outside the dike wall or hill.

8.2.3 Cone/Flat Roof The covered cone or flat top roof storage tank in most cases are used to store high flash point liquids. However, these tanks can be heated and insulated. Often these tanks are directly tied to Gasoil producing units as intermittent storage. The protection for this type of tank is based on the guidance found in GP 24-40 Fire Protection of Atmospheric Storage Tanks, and NFPA 11 Foam Systems and API 2021 Management of Atmospheric Storage Tank Fires and API 2023 Guide for the Safe Storage and Handling of Heated Petroleum Products. Protection strategy on this type of tank can be source of debate due to the inherent physical and chemical characteristics of the materials “usually” stored in these tanks. The preferred protection strategy applied ensuring safe effective fit for purpose protection for the most likely fire event is: 1. A completed pre-fire plan for seal and full surface fire scenarios must be completed and

validated.

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2. Fixed semi automatic full surface system of foam makers supplied via single dry riser, connected to no more than 1 maker. These foam makers are to be sized 50% over the minimum in order to accommodate the failure or under performance of one of the chambers in the system. The dry riser terminal connection will be located outside the dike wall or hill.

8.2.4 Pressurized Storage “Spheres Or Bullets” Pressurized storage vessels are generally used for the storage of low flash point, hi vapor pressure gases and liquids. Whether vertical or horizontal in design, the strategy is to prevent shell failure during fire scenarios. The preferred approach is to provide inherent protection by either using a Cavern for storage or burying the tanks in earthen hills.

In some cases this is not cost effective, unless the risk consequence ranking justifies this approach. For above ground storage of this type and combination of passive and active protection is preferred. The preferred protection strategy applied ensuring safe effective fit for purpose protection for the most likely fire event is:. 1) A completed pre-fire plan. Fire scenarios must be completed and validated 2) For new construction 3 hour intumescent passive fire proofing or automatic sprays tied to a

fire detection system. 3) For above ground non fire proofed vessels, automatic or semi automatic spray ring system

with supporting perimeter fire fighting monitors

8.3 Loading Facilities The protection for loading facilities is based on the guidance found in: ● GP 24-10 Fire Protection On-Shore Chapter 15 ● NFPA 11 Foam Systems ● NFPA 13 Fixed Water Sprays ● API 2021 Management of Atmospheric Storage Tank Fires ● Refining Defined Practices for the materials being handled ● Applicable Site Technical Practices for fire protection

As with all new construction or major modifications a review of the inherent hazards and associated risk level will form the basis for protection. Determination of the best approach for protection will be based on the collection of standard site safety and protection assessment processes such as: ● HAZOP ● PHSSER ● FHA’s

The resulting FEHMP will define these measures.

8.3.1 Road and Rail Tanker The protection of land based loading facilities is based on several factors, the primary factors being the type or class of material being handled. The location of the facility, within the site, and it’s criticality to the business. The tiered protection strategy applied ensuring safe effective fit for purpose protection for the most likely fire events are. 1) Effective use of fire and gas detection systems and emergency isolation valves, for any

facility handling flammable liquids. 2) Fixed water and/or foam systems spray systems will be required on any LPG loading

facility. Flammable liquids will be a risk based installation. 3) Perimeter fixed water/foam monitors and hydrants sized per the FHA.

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8.3.2 Marine Tanker The protection of marine loading facilities is based on several factors. The primary factors are the type or class of material being handled, the location of the facility, and it’s criticality to the business. The tiered protection strategy applied ensuring safe effective fit for purpose protection for the most likely fire events are. 1) Effective use of fire and gas detection systems and emergency isolation valves, for any

facility handling flammable liquids. 2) A robust water supply and fixed water/foam monitors and hydrants sized per the FHA.

8.4 Buildings and Facilities The protection buildings and facilities are based on several factors. The primary factors are the type of occupancy and its intended use. Other factors to be considered are the location of the facility and it’s criticality to the business. In general, local building codes will be applied ensuring safe effective fit for purpose protection for the most likely fire events. BP Group Practice GP 44-10, GP 44-30 and GP 24-10 shall be the primary applicable documents siting and protection of buildings site wide.

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9.0 TABLES

TABLE 1 – EQUIPMENT SPECIFICATION TOPICS INDEX

EST 16–1–1 Fire Hydrant and Monitor Fire Hydrants

FP‐STD‐1.1 3‐Way Fire Hydrant FP‐STD‐2.1 4‐Way Fire Hydrant FP‐STD‐3.1 3‐Way Monitor Fire Hydrant Water Protector/Master 1250 FP‐STD‐4.1 3‐Way Monitor Fire Hydrant Foam Protector/Master 750 Drum Station FP‐STD‐5.1 3‐Way Monitor Fire Hydrant‐Water Monsoon/Master 2000 FP‐STD‐6.1 3‐Way Monitor Fire Hydrant‐Foam Monsoon/Ranger 1500 Tote Station

EST 16–2–1 Fire Hydrant Underground Isolation Watch Valve

FP‐STD‐7.0 Fire Hydrant Underground Isolation Watch Valve FP‐STD‐12.0 Trench Adapter

EST 16–3–1 Fire Water U/G Isolation Valves with Trench Adapters

FP‐STD‐8.0 Fire Water Underground Isolation Valve with Trench Adapter FP‐STD‐12.0 Trench Adapter

EST 16–4–1 Fire Water U/G Isolation Valves with Post Indicators

FP‐STD‐9.0 Fire Water Ring Main Underground Isolation Valve with PIV and Wrench FP‐STD‐10.0 Fire Water System/Device Underground Isolation Valve with PIV and Hand wheel FP‐STD‐11.0 Post Indicators

EST 16–5–1 Fire Water U/G Drain Valves

FP‐STD‐13.0 Size 0.75-inch Underground Firewater Automatic Drain Valve Assembly with Drain Elbow FP‐STD‐14.1 Fire Water Size 2.0-inch PIV Drain Valve and Elbow Assembly

EST 16–6–1 Ultra Hydrants

FP‐STD‐15.1 Ultra 4 Hydrant size 12-inch x (4) x 6-inch x 1 x 4-inch Fire Monitor Outlet FP‐STD‐16.0 Ultra 8 Hydrant size 16-inch x (8) x 6-inch x 1 x 4-inch Fire Monitor Outlet

EST 16–7–1 Station Monitor

FP‐STD‐17.1 Station Monitor Water Protector/Master 1250 FP‐STD‐18.1 Station Monitor Water Monsoon/Master 2000 FP‐STD‐19.1 Station Monitor Foam Protector/Master 750 Drum Station FP‐STD‐20.1 Station Monitor Foam Monsoon/Ranger 1500 Tote Station

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TABLE 1 – EQUIPMENT SPECIFICATION TOPICS INDEX (CONT.)

EST 16–8–1 Oscillating Fire Monitor

FP‐STD‐21.0 Aboveground Oscillating Monitor/Nozzle Package

EST 16–9–1 Unit Hose Reel with Portable Monitor and Dry Hose Stations

FP‐STD‐22.1 Process Unit Hose Reel with Blitzlite Portable Monitor FP‐STD‐23.0 Dry Hose Station

EST 16–10–1 Portable Fire Extinguishers

FP‐STD‐24.0 Hand Portable Purple K Dry Chemical Fire Extinguisher and Outdoor Cabinets FP‐STD‐25.0 Hand Portable Carbon Dioxide Fire Extinguishers FP‐STD‐26.0 Hand Portable Water Type Fire Extinguisher FP‐STD‐27.0 350 lb. Purple K Wheeled Dry Chemical Fire Extinguisher FP‐STD‐28.0 350 lb. PKW Wheeled Hydrochem Fire Extinguisher

EST 16–11–1 Portable Water Thief

FP‐STD‐29.0 3.0-inch Supply Hose Portable Water Thief

EST 16–12–1 Transportable Portable Foam/Water Monitors

FP‐STD‐30.0 Transportable Sentry Trailer Mounted Portable Foam Monitor

EST 16–13–1 Fire Protection Systems, Valves, Strainers and Devices

FP‐STD‐31.0 Automatic Deluge System Control Valves FP‐STD‐32.0 Automatic In‐Line Flow Type DA Motorized Screen Strainer Size 4-inch‐12-inch FP‐STD‐33.0 Manual In‐Line Flow Type DH Rotating Screen Strainer Size 2‐1/2-inch ‐ 12-inch FP‐STD‐34.0 Combination Air Vacuum/Breaker and Air Release Valve

EST 16–14–1 Storage Tank Fire Protection

FP‐STD‐35.0 OTF Storage Tanks‐Rim Fire Protection System

EST 16–15–1 Emergency Safety Shower and Eye Wash

EMSFTYEQP‐STD‐1.0 Outdoor Emergency Safety Shower/Eyewash Booth

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