public comment no. 13-nfpa 22-2016 [ section no. … · public comment no. 24-nfpa 22-2016 [...

Public Comment No. 13-NFPA 22-2016 [ Section No. 2.3.8 ]

2.3.8 AWWA Publications.

American Water Works Association, 6666 West Quincy Avenue, Denver, CO 80235.

AWWA C652, Disinfection of Water-Storage Facilities, 2011.

AWWA D100, Welded Steel Tanks for Water Storage, 2011.

AWWA D102, Coating Steel Water-Storage Tanks, 2014.

AWWA D103, Factory-Coated Bolted Steel Tanks for Water Storage, 2009 including Addendum D103a-14,2014 .

AWWA D108, Aluminum Dome Roofs for Water Storage Facilities

AWWA D110, Wire- and Strand-Wound, Circular-Prestressed Concrete Water Tanks, 2013.

AWWA D115, Circular-Prestressed Concrete Water Tanks with Circumferential Tendons, 2006.

AWWA D120, Standard for Thermosetting Fiberglass-Reinforced Plastic Tanks, 2009.

AWWA D121, Bolted Aboveground Thermosetting Fiberglass-Reinforced Plastic Panel-Type Tanks forWater Storage, 2012.

Statement of Problem and Substantiation for Public Comment

AWWA D103 - AWWA issued an addendum to D103 incorporating important changes to the standard. The reference should incorporate the addendum.

AWWA D108. This reference is needed for a new reference proposed for Sec. 6.2.3.2.

Related Item

Public Input No. 1-NFPA 22-2015 [Chapter 2]

Submitter Information Verification

Submitter Full Name: Leslie Scott

Organization: Paso Robles Tank – Brown-Minneapolis Tank, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Wed Nov 16 00:37:02 EST 2016

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-2-NFPA 22-2017 Added the publication date.

Statement: AWWA D103 - AWWA issued an addendum to D103 incorporating important changes to thestandard. The reference should incorporate the addendum.

AWWA D108. This reference is needed for a new reference proposed for Sec. 6.2.3.2.

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

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Public Comment No. 3-NFPA 22-2016 [ Section No. 4.5.1 [Excluding any Sub-Sections] ]

In addition to complying with the requirements of this standard, it is expected that the manufacturers ofapproved structures will also follow the spirit of the standard by using their experience and ability to createstructures that shall prove reliable under all specified conditions The workmanship shall meet allrequirements of AWWA D100 .


This section deals with workmanship. It is unreasonable to expect a manufacturer to meet additional requirements that the technical committee responsible for this standard cannot identify and delineate.

As written, the language does not provide specific requirements which can lead to conflict between contractor, owner and AHJ.

If there are sections of NFPA 22 that do not include sufficient requirements such that the manufacturer would be expected to provide designs, details or methods to provide adequate equipment, then the technical committee should address these sections and correct the deficiencies.

This standard does not include provisions for all important aspects of welded steel tank construction and only references AWWA D100 for specific requirements. This proposed change will eliminate the unenforceable language of unspecified requirements and establish AWWA D100 for workmanship standards.

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Organization: Paso Robles Tank - Brown-Minneapolis Tank, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Tue Nov 08 16:24:32 EST 2016

Committee Statement

CommitteeAction:

Rejected

Resolution: The reference to the requirements of AWWA D100 is too restrictive. AWWA D100 is a standard forwelded steel tanks only. There are many different styles of tanks and materials of construction andconnectivity systems that fall outside of AWWA standards.


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Public Comment No. 5-NFPA 22-2016 [ Sections 4.10.2, 4.10.3 ]

Sections 4.10.2, 4.10.3

4.10.2

The workmanship shall be of such quality that defects or injuries are not produced during manufacture orerection that cause the specified unit stresses to be exceeded under any specified design loads .

4.10.3

Specified unit stresses shall not be exceeded.

<delete this section>


It is unreasonable to state that defects or injuries to material may not produced during erection without strict definition of 'defects or injuries'. Instead, any defects should be repaired or remediated to meet the requirements of the standard. AWWA D100, for instance, has allowable tolerances for shape and for specific loading conditions requires the manufacture to confirm that the as-built structure conforms to the shape tolerances in order to validate the basis of design. This change aligns the requirements to a reasonable requirement in line with the requirements of tank standards.

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Organization: Paso Robles Tank - Brown-Minneapolis Tank, Inc.

Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:


Resolution: SR-3-NFPA 22-2017

Statement: It is unreasonable to state that defects or injuries to material may not produced during erectionwithout strict definition of 'defects or injuries'. Instead, any defects should be repaired or remediatedto meet the requirements of the standard. AWWA D100, for instance, has allowable tolerances forshape and for specific loading conditions requires the manufacture to confirm that the as-builtstructure conforms to the shape tolerances in order to validate the basis of design. This changealigns the requirements to a reasonable requirement in line with the requirements of tank standards.


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Public Comment No. 24-NFPA 22-2016 [ Section No. 4.12.6.1 ]

4.12.6.1

All steel columns and struts shall be designed in accordance with AWWA D100. the applicable AWWA tankdesign standard for the type of tank being constructed. When no AWWA design standard exists for thetype of tank being constructed, then steel columns and struts shall be design in accordance with AISC 360.


As written, this sections requires steel columns and struts to be designed in accordance with AWWA D100 even if the tank design would generally follow AWWA D103, AWWA D110, AWWA D115, AWWA D120 or AWWA D121. This revision provides clarity to the supposed intent.

I agree with the Technical Committee's response on Public Input #6 to create a Task Group to review Chapter 5 in its entirety to compare and align with AWWA standards. The same effort should be extended to Chapter 4 in addition to other relevant Chapters and annexes.

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Submittal Date: Fri Nov 18 00:50:32 EST 2016

Committee Statement

CommitteeAction:



Statement: As written, this sections requires steel columns and struts to be designed in accordance withAWWA D100 even if the tank design would generally follow AWWA D103, AWWA D110, AWWAD115, AWWA D120 or AWWA D121. This revision provides clarity to the supposed intent.


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4.14.1.1

OSHA-compliant (29 CFR 1910) standard railing shall be placed around the roof manholes roof hatch(es)and other accessories that require access.


This standard does not use the terminology 'roof manhole', only 'roof hatch'. See Sec. 5.7.3, 5.7.4, 5.7.5, 5.7.6, 6.4.1.1.1, 8.7.5 and 8.7.6.

I agree with the Technical Committee's response on Public Input #6 to create a Task Group to review Chapter 5 in its entirety to compare and align with AWWA standards. This effort should also coordinate the requirements of Chapters 4, 5, 6, 12, 13, 14, 17, and 18 with all other requirements and reference standards.

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Submittal Date: Thu Nov 17 23:16:15 EST 2016

Committee Statement

Committee Action: Accepted


Statement: This will provide consistency throughout the standard.


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Public Comment No. 6-NFPA 22-2016 [ Sections 5.2.1.1, 5.2.1.2 ]

Sections 5.2.1.1, 5.2.1.2

5.2.1.1 Plates.

Plate materials shall be of open-hearth, electric furnace, or basic oxygen process steel that conforms toAWWA D100 and one of the following ASTM specifications:

(1) ASTM A36/A36M

(2) ASTM A283/A283M, Grades A, B, C, and D

5.2.1.2 1.1

Where plates of thicknesses greater than 3⁄4 in. (19.1 mm) are used, ASTM A283/A283M, Grade D, shallnot be used. ASTM A131/A131M, Grades A, B, and C; or ASTM A516/A516M, Grades 55 and 60, shall beused as alternatives.

5.2.1.1.2

ASTM A283, grade A steel is to be used only for nonstructural items such as clips, roof sheets, and otherlow-stressed components less than 1 in. (25 mm) thick.

<renumber remaining sections>


AWWA D100 does not allow ASTM Grade A to be used for shell plates because the specified minimum yield strength is considered too low. Since special restrictions are provided in 5.2.1.2 for ASTM A283 Grade D, this proposed restriction on Grade A should be added to this section.

If the desire is to merely make reference to AWWA D100, then delete Sec. 5.2.1.2 since D100 already has restrictions on use of ASTM A283 Grade D. NOTE: D100 only limits A283 Grade D to ¾ inch for use as shell plate but not for other applications. Also, D100 already includes provisions for alternate materials, so the list of alternate in this section would not be needed if these requirements were deferred to AWWA D100. Also, D100 contains other material restrictions not listed in NFPA 22.

ADDITIONAL COMMENTARYMany requirements in NFPA 22 are duplicative requirements to those contained in AWWA tank standards. If the intent of the Technical Committee is that the various tank types at least comply with the minimum requirements of the applicable AWWA standard, then it is recommended that the standard be revised by incorporating that statement and then incorporating any additional special provisions above the AWWA minimum requirements that are deemed necessary by the Technical Committee for tanks to adequately serve fire protection needs. By duplicating limited sections of AWWA tank standards into the NFPA standard, then it is incumbent on the Technical Committee to remain apprised in changes to the requirements in those AWWA standards and keep the NFPA document current. Based on the submitter's review of this NFPA standard, many requirements appear to have not be reviewed for an excessive number of years and editions of related standards.

It is unclear why the Technical Committee has chosen to not require compliance with all requirements of AWWA standards (D100 in this case) but instead only requires compliance of specific sections for specific considerations. It is the submitter's opinion that the requirements of this standard and the limited references to AWWA standards omit many important requirements in the design of a fire protection storage tank that are considered as minimum requirements for water storage tanks under the AWWA standards.

If the Technical Committee believes that the requirements of the relevant AWWA standards are insufficient such that some of the out of date requirements of this standard should stand as minimum requirements, then this submitter recommends that the Technical Committee submit proposed changes to AWWA for those requirements.

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Committee Statement

Committee Action: Rejected

Resolution: See new Chapter 5.


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5.2.1.3 Basis of Furnishing Plates.

Plates shall be furnished, based on weight, with permissible underrun and overrun in accordance with thetolerance table for plates ordered to weight in ASTM A 6 or ASTM A20, as applicable to the particular steelspecification .


In a previous revision cycle it was noted that ASTM A6 did not apply to steel produced to ASTMA516 or ASTM A285 specifications. However, ASTM A6 does apply to ASTM A36, ASTM A283 and ASTM A131 specifications.

The text was incorrectly revised in previous revisions.



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Public Comment No. 8-NFPA 22-2016 [ Section No. 5.4 ]

5.4 Unit Stresses.

The maximum stresses in pounds per square inch (megapascals) that are produced by the loads specifiedin Sections 4.12 and 5.3, or any combination of them, shall not exceed the values in Table 5.4 plus theallowable increased per Sec. 4. 12.7.1, if applicable .

Table 5.4 Maximum Stresses

psi MPa

Tension: On net section, rolled steel 15,000 103.43

Tension:

Anchor bolts†

Mild steel

ASTM A36/A36M or ASTM F1554–36 15,000 103.43

ASTM F1554–55 (weldable) 18,750 129.29

High-strength steel

ASTM A193–B7

1 1 ⁄ 4 in. ≤ diameter ≤ 2 1 ⁄ 2 in. 31,250 215.48

2 1 ⁄ 2 in. ≤ diameter ≤ 4 in. 28,750 198.24

ASTM F1554–105

1 1 ⁄ 4 in. ≤ diameter ≤ 3 in. 31,250 215.48

Tension: Cast steel

Bending:

Tension on extreme fibers, except column base plates 15,000* 103.43

Column base plates 20,000 137.90

Compression on extreme fibers of rolled sections, and plate girders andbuilt-up members for values as follows:

15,000 103.43

9,000,000 62,055

where l is the unsupported length; d is the depth of the member; b is the width; and t is the thicknessof its compression flange; all in in. (mm); except that l shall be assumed to be twice the length of thecompression flange of a cantilever beam not fully stayed at its outer end against translation or rotation.

Pins, extreme fiber 22,500 155.15

Cast steel 11,250 77.57

*For materials with Fy = 36,000 psi, the allowable stress may be taken as 18,000 psi.

†On area based on diameter at root of threads.



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Table 5.4 does not address the increase allowed by 4.12.7.1. As written, Sec. 5.4 overrides the increase allowed by Sec. 4.12.7.1 by specifically requiring that Table 5.4 stress levels not be exceeded for ALL load cases, including wind and seismic, so this change is needed to include the stress increase.

It is unclear why the Technical Committee has chosen to not require compliance with all requirements of AWWA standards (D100 in this case) but instead only requires compliance of specific sections for specific considerations. It is the submitter's opinion that the requirements of this standard and the limited references to AWWA standards omit many important requirements in the design of a fire protection storage tank that are considered as minimum requirements for water storage tanks under the AWWA standards. In the case of this comment, the erroneous language would make compliant structures more costly by exceeding relevant industry requirements, including NFPA 22 itself.

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Submittal Date: Mon Nov 14 16:00:02 EST 2016

Committee Statement




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Public Comment No. 9-NFPA 22-2016 [ Section No. 5.4 ]


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5.4 Unit Stresses.


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The maximum stresses in pounds per square inch (megapascals) that are produced by the loads specifiedin Sections 4.12 and 5.3, or any combination of them, shall not exceed the values in Table 5.4.

Table 5.4 Maximum Stresses

psi MPa

Tension: On net section, rolled steel 15,000 103.43

Tension:

Anchor bolts†

Mild steel

ASTM

ASTM A36/A36M or ASTM F1554–36 15,000 103.43

ASTM

ASTM F1554–55 (weldable) 18,750 129.29

High

High -strength steel

ASTM A193–B7

1 1 ⁄ 4 in. ≤ diameter ≤ 2 1 ⁄ 2 in. 31,250 215.48

2 1 ⁄ 2 in. ≤ diameter ≤ 4 in. 28,750 198.24

ASTM

ASTM F1554–105

1

1 1 ⁄ 4 in. ≤ diameter ≤ 3 in. 31,250 215.48

Tension: Cast steel 11,250 77.57

Bending:

Tension on extreme fibers, except column base plates 15,000* 103.43

Column base plates 20,000 137.90

Compression on extreme fibers of rolled sections, and plate girders and built-upmembers for values as follows:

15,000 103.43

9,000,000 62,055

(see attachment

for corrected value)

(see attachment

for corrected value)

where l is the unsupported length; d is the depth of the member; b is the width; and t is thethickness of its compression flange; all in in. (mm); except that l shall be assumed to be twice the lengthof the compression flange of a cantilever beam not fully stayed at its outer end against translation orrotation.

Pins, extreme fiber 22,500 155.15

Cast steel 11,250 77.57

*For materials with Fy = 36,000 psi, the allowable stress may be taken as 18,000 psi.


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†On area based on diameter at root of threads.

Additional Proposed Changes

File Name Description Approved

NFPA_22_-_Table_5.4_Corrections_LDS_2016_.pdf

Corrections to Table 5.4. Online editor does not allow proper formatting of table contents.


The table as printed is confusing and incomplete and inaccurate. Revise Table 5.4 to correct inaccuracies, provide missing information, and reformat for clarity.

1. For clarity of the groupings of members, add 'Anchor Bolts' for heading of second category rather than appearing to be a third category.

2. For clarity of the groupings of members, indent the two subcategories under anchors bolts (mild steel and high strength steel).

3. Add the values of allowable tension for cast steel where the values are missing.

4. For bending compression on rolled sections where ld/bt does not exceed 600, move the values down in the table to line up with the category.

5. For bending compression on rolled sections where ld/bt does exceeds 600, correct the allowable values to read properly as fractions as shown in the attachment.

ADDITIONAL COMMENTARYMany requirements in NFPA 22 are duplicative requirements to those contained in AWWA tank standards. If the intent of the Technical Committee is that the various tank types at least comply with the minimum requirements of the applicable AWWA standard, then it is recommended that the standard be revised by incorporating that statement and then incorporating any additional special provisions above the AWWA minimum requirements that are deemed necessary by the Technical Committee for tanks to adequately serve fire protection needs. By duplicating limited sections of AWWA tank standards into the NFPA standard, then it is incumbent on the Technical Committee to remain apprised in changes to the requirements in those AWWA standards and keep the NFPA document current. Based on the submitter's review of this NFPA standard, many requirements appear to have not be reviewed for an excessive number of years and editions of related standards.



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COMMENTED PREVIOUSLYWITH SPECIFIC CORRECTIONS.THESE ARE SUPPOSED TO BE FRACTIONS. SEE BELOW.

HEADING. ADD HERE AND

INDENT

in excess of 600bt

ld

bt

ld000,000,9

bt

ld055,62

MOVE DOWN TO LINE UP WITH CATEGORY

11,250 77.57


5.5.1.6

Cylindrical shell plates in contact with water shall have minimum thicknesses as specified in accordancewith Table 5.5.1.6.

Table 5.5.1.6 Minimum Thickness of Cylindrical Shell Plates

Diameter

<50 ft <15.2 m

50 ft–

120 ft

15.2 m–

35.6 m

120 ft–

200 ft

35.6 m–

61 m

>200 ft >61 m

Bottom

rings

ring 1 ⁄ 4 in. 6.4 mm 1 ⁄ 4 in. 6.4 mm 5 ⁄ 16 in. 7.9 mm 3 ⁄ 8 in. 9.5 mm

Upper rings 3 ⁄ 16 in. 4.8 mm 1 ⁄ 4 in. 6.4 mm 5 ⁄ 16 in. 7.9 mm 3 ⁄ 8 in. 9.5 mm


In Table 5.5.1.6 revise ‘Bottom rings’ to ‘Bottom ring’ to clarify the requirement and eliminate the confusion created by the language.

The terms 'Bottom Rings' and 'Upper Rings' are not defined. AWWA D100 defines these thickness ranges based on diameter and height only, not which ring is being considered.

- The term 'Bottom rings' is not defined to specify the limit of which rings are considered as bottom rings. Does this mean all rings below the top ring or all rings below mid height of the shell or something else?- The term 'Upper rings' is not defined to specify which rings are considered as upper rings. Does it mean all rings above the bottom ring or all rings above some other level?

I agree with the Technical Committee's response on Public Input #6 to create a Task Group to review Chapter 5 in its entirety to compare and align with AWWA standards, but also a review to ensure that NFPA 22 is consistent with its own requirements is recommended.

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5.5.2.3

The plates of tanks that are to contain salt or alkaline water shall be 1 ⁄ 16 in. (1.6 mm) thicker thancalculated.


SALT CONTENTThis section includes requirements for tanks that are to contain salt, but no specific requirements with regard to salt levels or types of salts are provided. Many common water supplies might contain salts from various sources include water treatment applications, runoff from road salts in surface water supplies, naturally occurring mineral salts among others. Therefore, if the water supplies can contain salt, all tanks are subject to this requirement to increase the thickness of tank plates by 1/16".

Other questions related to this requirement are:How much salt must be present to be considered a ‘tank that is to contain salt’?Does the chemistry of water source at the time of construction dictate this requirement, or is a time history survey of water chemistry over some period required?Was this intended to mean ‘tanks that are to contain seawater’?

pH LEVELThe pH of pure water is 7. In general, water with a pH lower than 7 is considered acidic, and with a pH greater than 7 is considered basic. The normal range for pH in surface water systems is 6.5 to 8.5, and the pH range for groundwater systems is between 6 to 8.5. I have read that alkalinity can reduce the tendency for corrosion unless the alkalinity is high. No indication here of alkalinity range intended by the requirement, so this applies to any pH value above 7.

I do not believe that the intent of the standard is to require the corrosion allowance for all tanks. Since the standard does not outright require a corrosion allowance for all tanks, this requirement must mean something else unless the committee intends to require corrosion allowance only when desalinated water or purified water is used for fire protection purposes.

I agree with the Technical Committee's response on Public Input #6 to create a Task Group to review Chapter 5 in its entirety to compare and align with AWWA standards, but also a review to ensure that NFPA 22 is consistent with its own requirements is recommended.

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5.7.8.1

Except for the underside of the floor on ground-supported flat-bottom tanks, faying surfaces of boltedconnections that prohibit coatings, and contact and overlapping surfaces of unsealed roof single-weldedlap joints above the high waterline , parts that are inaccessible after fabrication, but that are subject tocorrosion, shall be protected by paint before assembly.

5.7.8.1.1

This requirement shall not apply to the overlapping surfaces of single-welded lap joints above the highwaterline.


Delete section 5.7.8.1.1 and incorporate its content into the exception list of 5.7.8.1.

With the changes incorporated into the 2013 edition, this section has become contradictory. The content of Sec. 5.7. should be revised to include the additional exemption intended by making the revisions noted.

I agree with the Technical Committee's response on Public Input #6 to create a Task Group to review Chapter 5 in its entirety to compare and align with AWWA standards. This revision eliminates ambiguity created by the separate but similar requirements in 5.7.8.1 and 5.7.8.1.1.

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5.7.9.1

All Except where exempted by Sec. 5.7.8.1, all interior surfaces of steel tanks that are exposed to waterimmersion or the vapor phase zone above the high water level shall be cleaned by near-white blasting inaccordance with SSPC SP 10 and shall be primed in accordance with the requirements for “Inside PaintSystem No. 1” in AWWA D102.


Currently, NFPA 22 Sec. 5.7.9.1 requires all interior surfaces that are exposed to water immersion or water vapor above the high water level to be coated. This section does not address the inaccessible areas referenced in 5.7.8.1 that do not require coatings. For this standard to require coatings that could compromise structural integrity by requiring coatings on faying surfaces of bolted connections that prohibit coatings is irrational. Likewise, to require coatings in areas that might compromise weld integrity is equally absurd. To avoid these problems and the conflicting language of 5.7.8.1, revision to Sec. 5.7.9.1 as indicated is required.

I agree with the Technical Committee's response on Public Input #6 to create a Task Group to review Chapter 5 in its entirety to compare and align with AWWA standards. The issue in this comment is addressed in detail in AWWA D102.

An alternate solution is to make reference to coating requirements related to inaccessible areas in AWWA D102.

It is unclear why the Technical Committee has chosen to not require compliance with all requirements of AWWA standards (D100 in this case) but instead only requires compliance of specific sections for specific considerations. It is the submitter's opinion that the requirements of this standard and the limited references to AWWA standards omit many important requirements in the design of a fire protection storage tank that are considered as minimum requirements for water storage tanks under the AWWA standards. General reference for compliance with the requirements of AWWA D100 an D102 is recommended.


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Submittal Date: Tue Nov 15 16:11:13 EST 2016

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6.2.3.2

Aluminum shapes shall be permitted to be used for portions of the tank that are not in contact with waterand shall follow the design criteria in Appendix A of AWWA D103 D108 .


The reference to Appendix A of AWWA D103 is drastically out of date. Appendix A of AWWA D103 has not addressed requirements for aluminum elements for nearly 20 years. Requirements for aluminum dome roofs are no longer incorporated directly in AWWA D103. The new standard, AWWA D108, now contains the requirements aluminum dome roofs.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 13-NFPA 22-2016 [Section No. 2.3.8]

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6.2.3.2

Aluminum shapes shall be permitted to be used for portions of the tank that are not in contact with waterand shall follow the design criteria in Appendix A of AWWA D103 in AWWA D108 .


The Appendix A reference to AWWA D103 has not been valid since the 1997 edition.

I agree with the Technical Committee's response on Public Input #6 to create a Task Group to review Chapter 5 in its entirety to compare and align with AWWA standards. The same effort should be extended to Chapter 6 and the related sections of Annex A and Annex B.

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Public Comment No. 15-NFPA 22-2016 [ New Section after 6.4.1 ]

6.4.1.5 The minimum thickness of tubular columns and struts shall be ⁄ in. (6.4 mm).

6.4.1.6 Roof a achment.

6.4.1.6.1 The roof shall fit ghtly to the top of the shell to eliminate any gap between the roof and the shell.

6.4.1.6.2 Roof Anchorage. Each roof plate shall be securely fastened to the top of the tank.

6.4.1.7 The allowable stress levels and design and detailing requirements for the tank, structural supports, and

accessories shall be in accordance with AWWA D103.

6.4.1.8 Opening Reinforcement.

6.4.1.8.1 All openings of more than 4 in. (102 mm) in diameter that are located in the shell, suspended

bo om, larger steel plate tank riser, or tubular support shall be reinforced

6.4.1.8.2 The reinforcement shall be either the flange of a fi ng, an addi onal ring of metal, excess plate

metal above that actually required, or a combina on of these methods.

6.4.1.8.3 The opening diameter shall be considered to be the maximum dimension of the hole cut in the plate

perpendicular to the direc on of maximum stress.

6.4.1.8.4 Bol ng shall be provided to transmit the full net strength of the reinforcing ring or flange to the

plate.

6.4.1.8.5 In compu ng the net reinforcing area of a fi ng, such as a boilermaker’s flange or a manhole saddle

that has a neck, the material in the neck shall be considered as part of the reinforcement for a distance, measured

from the surface of the parent plate or from the surface of an intervening reinforcement plate, that is equal to

four mes the thickness of the material in the neck.

6.4.1.9. Connec ons shall be provided on the tank for the necessary pipes, braces, frost‐cas ng, and walkway

supports.


The requirements in Sec. 6.4.1.5 for minimum thickness of tubular columns and tight roof construction in Sec. 5 should apply equally to bolted tanks as well as welded tanks. If these requirements are determined to not be required for bolted tanks then delete Sec. 5.5.1.3, 5.6.5.1, and 5.7.2 for the welded tanks. NOTE: this requirement is also applicable in light of Sec. 4.12.6.1

6.4.1.6 is added for consistency with the requirements for welded tanks. If not needed here, then delete the corresponding requirements from Chapter 5. Sec. 6 currently includes no requirements for the design basis of the tank. In its current condition, the designer of the tank could use any basis desired for determining resistance to the specified loads, even if the design basis is not from a recognized industry standard. The proposed change provides a design basis for load resistance that AHJs can use in approving designs.

Sec. 6.4.1.7 needs to be added to establish minimum requirements for design of bolted tanks since no basis for allowable load levels is provided in the standard.


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Sec. 6.4.1.8 needs to be added because the requirements of 5.5.8, 5.5.8.1, 5.5.82. and 5.5.8.3 are equally applicable to bolted tanks as to welded tanks. These issues are covered in detail in AWWA D100 and D103. This important issue should be covered since the Technical Committee has chosen to not incorporate the AWWA Standards in their entirety as the design basis for these tanks.

Sec. 6.4.1.9 is added for consistency with the requirements of Chapter 5. These are the same requirements as for welded tanks contained in Sec. 5.6.5.1 and 5.7.2 .

ADDITIONAL COMMENTARYIt is unclear why the Technical Committee has chosen to not require compliance with all requirements of AWWA standards (D103 in this case) but instead only requires compliance of specific sections for specific considerations. It is the submitter's opinion that the requirements of this standard and the limited references to AWWA standards omit many important requirements in the design of a fire protection storage tank that are considered as minimum requirements for water storage tanks under the AWWA standards, including those provide storage for fire protection.

If the Technical Committee believes that some of the minimum requirements of the relevant AWWA standards are irrelevant to fire protection tanks covered by NFPA 22, then this submitter recommends that the Technical Committee provide commentary describing that position so that the user of the standard is not left guessing about the actual intent.

I agree with the Technical Committee's response on Public Input #6 to create a Task Group to review content of this standard and align with AWWA standards. This same effort should be extended to Chapter 6.

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First Revision No. 6-NFPA 22-2016 [Section No. 14.1.12]




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Public Comment No. 27-NFPA 22-2016 [ New Section after 6.6.1.3 ]

6.6.1.4

Polyethylene sheeting shall not be required for tanks where the tank floor has been leak tested verified tobe leak free by the vacuum method in accordance with AWWA D103, provided the provisions of Section17.1 have been met.


AWWA D103 does not require the tank floor to be leak tested unless specified by the purchaser. When so specified and the floor has been proven to be leak tight by testing similar to the process for welded tanks, then the polyethylene liner for floor leak detection is not necessary.

Since it is not know how the presence of a polyethylene liner in contact with the underside of the floor might affect sliding resistance under seismic or wind loading, the submitter prefers the option to leak test the floor to eliminate the polyethylene.

I agree with the Technical Committee's response on Public Input #6 to create a Task Group to review Chapter 5 in its entirety to compare and align with AWWA standards. The same effort should be extended to Chapter 6.

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Ladders

6.7.1 Ladders — General.

6.7.1.1 Outside and inside steel ladders that are arranged for convenient passage from one to the other and

through the primary roof hatch shall be provided.

6.7.1.2 Ladders shall not interfere with the opening of the hatch cover and shall not incline outward from the

ver cal at any point.

6.7.2 Outside Fixed Shell and Roof Ladder.

6.7.2.1 The outside tank ladder of suc on tanks shall be fixed a minimum of 7 in. (178mm) between the tank side

and the centerline of rungs and shall be rigidly bolted or welded to brackets that are spaced a maximum of 12 (3.7

m) apart and that are welded to the tank plates.

6.7.2.2 The bo om bracket shall be located a maximum of 6 (1.8 m) above the base of the tank cylinder, and the

ladder shall extend up the tank shell with the top bracket located at or near the top of the shell.

6.7.2.3 All ladders shall be equipped with a cage, a rigid notched rail, or other listed ladder safety device.

6.7.3 Inside Ladder.

6.7.3.1 The inside fixed ladder provided for passage between the roof hatch and tank bo om shall not be rigidly

connected to the bo om plates.

6.7.3.2 A ladder shall extend from the top to the bo om of the inside of the large steel tank riser pipes and shall

be secured to the shell plates by brackets that are spaced a maximum of 12 (3.7 m) apart.

6.7.3.2.1 The upper bracket shall be located at the top of the tank riser.

6.7.3.3 All ladders over 20 (6.1 m) high shall be equipped with a cage, a rigid notched rail, or other listed ladder

safety device.

6.7.4 Ladder Bars and Rungs.

6.7.4.1 Ladder side bars shall be not less than 2 in. × ⁄ in. (51 mm × 12.7 mm) or 2 ⁄ in. × ⁄ in. (64 mm × 9.5

mm).

6.7.4.2 Side bars shall be spaced at least 16 in. (406 mm) apart. Rungs shall be of at least ⁄ in. (19.1 mm) round or

square steel and shall be spaced 12 in. (305 mm) on their centers.

6.7.4.3 The rungs shall be firmly welded to the side bars.

6.7.4.4 Ladders and connec ons shall be designed to support a concentrated load of 350 lb (159 kg).


Add the language from Sec. 5.7.4 through 5.7.7 regarding ladder requirements with minor adjustments to address only ground supported tanks.

Chapter 6 is missing requirements for ladders. The access requirements for bolted tanks should be no different than for welded steel tanks or wood tanks.

I agree with the Technical Committee's response on Public Input #6 to create a Task Group to review Chapter 5 in


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its entirety to compare and align with AWWA standards. The same effort should be extended to Chapter 6.

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Resolution: See new Chapter 6. OSHA provides the appropriate safety requirements.


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Roof Hatches

5.7.3 Roof Hatch.

5.7.3.1 An easily accessible roof hatch or roof door having a minimum opening dimension of 24 in. (610 mm) shall

be provided in the roof.

5.7.3.2 The hatch cover shall be built of steel plate with a minimum thickness of ⁄ in. (4.8 mm).

5.7.3.3 The hatch opening shall have a curb that is a minimum of 4 in. (102 mm) high, and the cover shall have a

minimum downward overlap of 2 in. (51 mm).

5.7.3.4 A catch shall be provided to keep the cover closed.


Add the language regarding roof hatches from Sec. 5.7.3 through 5.7.3.4 to Chapter 6.

Chapter 6 is missing requirements for the roof hatch. The roof hatch requirements for bolted tanks should be no different than for welded steel tanks or wood tanks.

NOTE: The secondary roof hatch for ventilation is not considered necessary since these tanks are factory coated and the ventilation hatch of 5.7.3.5 is assumed to be necessary for abrasive blasting and coating operations for the welded tanks. Therefore, the requirement for a secondary hatch has not been included.

I agree with the Technical Committee's response on Public Input #6 to create a Task Group to review Chapter 5 in its entirety to compare and align with AWWA standards. The same effort should be extended to the requirements of Chapter 6 .

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Public Comment No. 18-NFPA 22-2016 [ Section No. 12.2.2 ]

12.2.2

For ringwall foundations, a minimum 10 in. (254 mm) wide reinforced concrete ring wall that extends belowthe frost line and at least 2 1 .5 ft 0 ft (0.76 m 30 m ) below finished grade shall be placed directly beneaththe tank shell where tanks are supported on a cushion of sand, on crushed stone, or granular bases.

12.2.2.1

The ring shall project at least 6 in. (152 mm) above the surrounding grade and shall be reinforced againsttemperature and shrinkage and shall be reinforced to resist the lateral pressure of the confined fill with itssurcharge.

12.2.2.2

The minimum reinforcement shall conform to Chapter 14, Section 14.3 of ACI 318.

12.2.2.3

The tops of ring wall foundations shall be level within ± 1⁄8 in. (±3.2 mm) in one plate length [approximately34 ft (10.4 m)], and no two points on the wall shall differ by more than ± 1⁄4 in. (±6.4 mm).

12.2.2.4

In lieu of a concrete foundation, steel suction tanks of 4000 gal (15.1 m3) or less shall be permitted to besupported on granular berms, with or without steel retainer rings, in accordance with AWWA D100 orAWWA D103, as applicable.


2.5' deep is sometimes excessive, and may require blasting and removal of bedrock. This adds considerable costs to a foundation that may otherwise only require 12" depth as dictated by design and geotech. report. Recommend following AWWA D100 and AWWA D103 Standards dictatingthe minimum depth of concrete ringwall to be 12".

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Submitter Full Name: Keith McGuire

Organization: CST Storage

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CommitteeAction:


Resolution: SR-7-NFPA 22-2017 A 12 in. maximum was added to 12.2.2.1 to match the requirements ofAWWA.

Statement: 2.5' deep is sometimes excessive, and may require blasting and removal of bedrock. This addsconsiderable costs to a foundation that may otherwise only require 12" depth as dictated by designand geotech. report. Recommend following AWWA D100 and AWWA D103 Standards dictatingthe


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minimum depth of concrete ringwall to be 12".


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Public Comment No. 30-NFPA 22-2016 [ Section No. A.5.6.7.1 ]

A.5.6.7.1

In accordance with AWWA D100, the The oiled sand mixture should consist of approximately 18 gal (68 L)of No. 2 fuel oil per cubic yard (cubic meter) of sand. In practice, quantities of 6 gal to 9 gal (22.7 L to 34 L)of oil per cubic yard (cubic meter) of sand have been shown to be acceptable.


AWWA D100 does not reference fuel oil for use in the oiled sand mixture. This reference has not be included since the 1996 edition. The current reference is a heavy base petroleum oil.

I agree with the Technical Committee's response on Public Input #6 to create a Task Group to review Chapter 5 in its entirety to compare and align with AWWA standards. This section should be update for current practice.

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Resolution: This annex language will be deleted due to the re-write of Chapter 5.


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Public Comment No. 17-NFPA 22-2016 [ Section No. B.1 ]


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B.1 General.


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Figure B.1(a) through Figure B.1(x) are included in this annex for illustrative purposes only. They areintended to represent relative locations of components and connections and general details of water tankconstruction.

Figure B.1(a) Pipe Connections to Pressure Tanks.

Figure B.1(b) Alternate Connections for Pressure Tanks.

Figure B.1(c) Details of Tank Roof Construction.


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Figure B.1(d) Section of Conical Roof.

Figure B.1(e) Typical Installation Details of an Embankment-Supported Coated Fabric SuctionTank, Including Fittings.

Figure B.1(f) Inlet-Outlet Fitting Assembly, Vortex Plate Assembly, and Sump Drain Fitting forEmbankment-Supported Coated Fabric Suction Tank.


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Figure B.1(g) Embankment-Supported Coated Fabric Suction Tank Recirculation and HeatingSchematic.

Figure B.1(h) Embankment-Supported Coated Fabric Suction Tank Overfill Alternates —Protected from Freezing.

Figure B.1(i) Typical Tower-Supported Wood Tank.


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Figure B.1(j) Typical Tower-Supported Double-Ellipsoidal Tank.

Figure B.1(k) Typical Pedestal Tank.


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Figure B.1(l) Welded-Steel Suction Tank. (For more information, see Section 14.6 Overflow andSection 4.15 Roof Vent.)

Figure B.1(m) Lap-Jointed Bolted Steel Tank.


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Figure B.1(n) Flange-Jointed Bolted Steel Tank.

Figure B.1(o) Suction Nozzle with Anti-Vortex Plate for Welded Suction Tanks. (See A.14.2.13.2.)


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Figure B.1(p) Typical Suction Nozzle with Anti-Vortex Plate for Lap-Jointed Bolted Tanks. (SeeA.14.2.13.2.)

Figure B.1(q) Typical Suction Nozzle with Anti-Vortex Plate for Flange-Jointed Bolted Steel Tanks.(See A.14.2.13.2.)

Figure B.1(r) Recommended Insulated Metal Frostproof Casings. (For details on waterproofing,see 14.1.1.1 and 14.1.1.2.)


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Figure B.1(s) Arrangements of Multiple Heaters.


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Figure B.1(t) Arrangements of a Circulation Heater for a Tank with a Large Tank Riser.

Figure B.1(u) Arrangement of a Radiator Heater for a Tank with a Large Tank Riser.


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Figure B.1(v) Arrangement of Aboveground Water Heater for Tank with Large Tank Riser.

Figure B.1(w) Typical Fiberglass Underground Water Tank with Bottom Sump.


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Figure B.1(x) Typical Fiberglass Underground Water Tank with Fiberglass Pump Vault.



Figure_B.1_l_Plan.pdf Proposed corrections to Figure 5.1(l), Plan View


1. Delete the notes on the tank plan, on the 3 o'clock side, referencing rafter CLs and arc measurement.These notes serve no purpose, provide no information and are not referenced in the standard. 2. Delete the depicted rail sections on the plan view from the ladder to the side of the roof hatch and add a note below the Plan referencing railing requirements of the standard.

In this detail it appears that railing is provided from the outside ladder (in elevation above) directly adjacent to the roof hatch obstructing access to the roof hatch and leaving no means of access to the tank roof without climbing over the hatch. Also, this will not allow a sufficient landing area when the climber would step onto the roof from the ladder.

Also, it is unclear how the hatch would open and allow access to the interior with the railing directly adjacent to the hatch.

This railing detail does not comply with Sec. 4.14.1.1 that requires guardrails be provided around the roof manholes and other accessories requiring access (such as the vent). This does not mean full perimeter guardrail as previously required, but that would meet the requirement.

3. On the left side of the diagram, replace the word ‘Manway’ with ‘Roof hatch’. This standard does not have any requirements for roof manways, only roof hatches.

See changes to Figure B.1(l) Plan, attached

I agree with the Technical Committee's response on Public Input #6 to create a Task Group to review Chapter 5 in its entirety to compare and align with AWWA standards. The issue in this comment relates to Chapter 5 and the figure that is provided to explain typical installations. The diagram should match the requirements and not add new requirements in the commentary.


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Public Comment No. 19-NFPA 22-2016 [Section No. B.1] correctons to the same figure

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Statement: Revise Figures as shown on marked up on attached plans. Add 2 new Figures. Figure B.1(y) TopMounted Immersion Tank Heater & Figure B.1(z) 2 Compartment FPR Panel Type Tank wFlange Immersion Heater. Clarifies drawings to align with the requirements of the standard.


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NOTE: Roof railing to be provided in accordance with Sec. 4.14.1.1.

Roof hatch



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B.1 General.


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Figure B.1(h) Embankment-Supported Coated Fabric Suction Tank Overfill Alternates — Protectedfrom Freezing.



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<<<< see changes on attached file >>>>



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Figure_B.1_l_Elevation.pdf Figure B.1(l) proposed corrections


1. At the tank roof, delete the roof pitch symbol. Roof pitch symbol is meaningless if no dimensions included.2. At the shell manway near the bottom of the tank, delete the dimension lines and arrows. No dimension is provided and no specific requirements exist in the standard for this dimension. Including this dimension line work with no value misleads the reader into thinking this is important and the standard is just flawed or incomplete. 3. At the base of the tank is a note indicating '¼ in. PL lap welded bottom'. Revise the location of the arrow. As shown it appears to point to the column base plate and is confusing.4. Delete the notation 'Shell manway (two required)'. This standard has no requirements to include shell manways. If it is intended that this diagram impose a requirement to install manways, then change the introductory sentence of Annex B that indicates that the annex is not a part of the requirements of the standard.

See changes to Figure B.1(l), attached

I agree with the Technical Committee's response on Public Input #6 to create a Task Group to review Chapter 5 in its entirety to compare and align with AWWA standards. The issue in this comment relates to Chapter 5 and the figure that is provided to explain typical installations. The diagram should match the requirements and not add new requirements in the commentary.



Public Comment No. 17-NFPA 22-2016 [Section No. B.1]

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B.1 General.


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Figure B.1(h) Embankment-Supported Coated Fabric Suction Tank Overfill Alternates — Protectedfrom Freezing.



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<<<< see changes to Figure 5.1(m) attached >>>>




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Figure_B.1_m_Plan.pdf Proposed corrections to Figure 5.1(m), Plan


Proposed Corrections:1. Revise Figure B.1(m) to include handrail that complies with Sec. 4.14.1.1 (see attached). Alternatively, delete handrail from diagram similar to Fig. B.1(l) and B.1(o). NOTE: It is believed that the diagram as published is intended to depict the option of Sec. 4.14.2, but does not comply with 4.14.1.1 in the process.

2. Change the notation 'Roof manway' to 'Roof hatch'. This standard does not have any provisions for roof manways, only roof hatches.

It is unclear why the Technical Committee has chosen to develop their own requirements in a less comprehensive manner than the AWWA standards and then provide 'explanatory material' in the Annex that contradicts the Technical Committee's base requirements.

I agree with the Technical Committee's response on Public Input #6 to create a Task Group to review Chapter 5 in its entirety to compare and align with AWWA standards. The same effort should be extended to Chapter 6 and the related sections of Annex A and Annex B.

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hatch

Change handrail configuration to meet the requirements of Sec. 4.14.1.1 or delete the handrail depiction as with Figures 5.1(l) and 5.1(o).



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B.1 General.


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Figure_B.1_n_.pdf Proposed corrections to Figure 5.1(n)


1. Bolt channels are not required elements. Revise each occurrence of 'Bolt channel' to include the caveat 'if used'.2. In Section J-J and Section L-L reference is made to a 'caulking detail', yet no caulking detail is provided. Delete these references.3. On the elevation view the Section View notations are backwards and not taken through the location of a vertical joint to match the diagrams of Section J-J, Section B-B and Section L-L. Reverse the section view notations so that they are taken in the proper direction and so that they encompass a vertical joint.4. Section A-A should be identified on the plan view.5. Correct the label indicating 'See Section A-A' at the top of the elevation view to point to the correct portion of the roof structure.6. This diagram does not include the suction nozzle as provided in Figure 5.1(l) and 5.1(m). Utilize the same representation for this nozzle in all three diagrams.7. Do not include items in the diagram that are not required in this standard.

I agree with the Technical Committee's response on Public Input #6 to create a Task Group to review Chapter 5 in its entirety to compare and align with AWWA standards. The same effort should be extended to Chapter 6 and the related sections of Annex A and Annex B including this diagram.

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(if used)

(if used)

(if used)

(if used)

(if used)

L

L

Roof hatch

A A

See Section A-A



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B.1 General.


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NFPA_22_Figure_5.1_o_5.1_p_5.1_q_.pdfProposed corrections to Figure 5.1(o), 5.1(p) and 5.1(q)


Figure 5.1(o)1. Delete Figure 5.1(o), Weld Detail. This diagram adds requirements that are not included in the standard and the weld detail adds confusion because of the notation of 't'. Confusion exists for the following reasons: The figure a dimension of ¼" on a groove weld with a bevel of 30°. With the required 1/16" gap between the penetration and the cutout in the shell, these dimensions require that the shell must be at least 3/8" thick which is not a requirement of the standard. It is this thickness that is referenced as 't' in the weld symbol of the pipe-to-shell weld. Since there is no other definition of 't' provided, it appears that all three instances of 't' must reference the shell thickness and the shell thickness cannot be less than 3/8". Since this is not consistent with the minimum thickness requirements of the standard, the reader is left bewildered as to the intent of providing this level of detail in the diagram in the commentary.

If the Technical Committee believes that it is necessary to provide this level of detail, add the following new requirement to Sec. 5. '5.x.x.x The details of weld configuration, weld size, and reinforcement for shell penetrations shall be in accordance with AWWA D100.' and then add similar requirements to Figure 5.1(p) and 5.1(q).

2. Delete the weld symbol at the flange outside the shell on Figure 5.1(o). This weld symbol is incomplete and improperly located on an incomplete drawing.

3. Revise the note 'See weld detail' to read 'See Note 1'. This change corresponds to #1 above.

4. Add Note 1 as shown: 'For weld size and configuration and reinforcement requirements see Sec. 5.5.8.'

5. Revise figure B.1(o) to eliminate attachment of the anti-vortex plate to either the tank floor or to the top of the support angles. It is generally considered bad practice to connect tank accessories to both the shell and floor or between the tank roof and the floor.


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NOTE: Figure B.1(p) does not provide any form of support from the floor to the anti-vortex plate. Figure B.1(q) shows a support from the floor, but does not require attachment of the support to the floor or the support to the anti-vortex plate.

Figure 5.1(p)1. Add the note 'Anti-vortex plate, minimum 2D x 2D*'. This is required for consistency with Figure 5.1(o). This should be equally applicable to all tanks.

2. Correct the flange drawing on the outside of the shell so that the pipe does not protrude past the flange.

3. Add the footnote as follows: '*Frequently, a 48 in x 48 in. size is used as a standard size that will work in any situation.'

4. Add Note 1 as follows: 'For reinforcement requirements, see Sec. 6.4.1.8'.

Figure 5.1(q)1. Add ', minimum 2D x 2D* to the notation 'Anti-vortex plate'. This is required for consistency with Figure 5.1(o). This should be equally applicable to all tanks.

2. Delete the backing channels from the diagram on the flange at the inside face of the shell. These are not required and add nothing to the understanding of a suction nozzle.

3. Delete the notation '150 x R.F.S.O.' from the flange at the outside of the shell.

4. Add the footnote as follows: '*Frequently, a 48 in x 48 in. size is used as a standard size that will work in any situation.'

5. Add Note 1 as follows: 'For reinforcement requirements, see Sec. 6.4.1.8'.

ADDITIONAL COMMENTARYI agree with the Technical Committee's response on Public Input #6 to create a Task Group to review Chapter 5 in its entirety to compare and align with AWWA standards. The same effort should be extended to Chapter 6 and the related sections of Annex A and Annex B and especially to these three diagrams to resolve why there are differences or why they are three diagrams instead of one to depict the important aspects.

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See Note 1

Note 1: For weld size and configuration and reinforcement requirements see Sec. 5.5.8.

Note 1: For reinforcement requirements see Sec. 6.4.1.8.

Note 1: For reinforcement requirements see Sec. 6.4.1.8.

Flange face must be past end of pipe

Delete.

*Frequently, a 48 in. ¥ 48 in. size is used as a standard size that will work for any situation. *Frequently, a 48 in. ¥ 48 in. size is used as a standard

size that will work for any situation.

, minimum 2D x 2D*

Anti-vortex plate, minimum 2D x 2D*

public comment no. 13-nfpa 22-2016 [ section no. … · public comment no. 24-nfpa 22-2016 [...

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