Biodiesel & Fire Permits

1. Biodiesel&Fire Permits Presented by the Seattle Fire Department for the Department of Ecology Biodiesel Permitting Workshop Seattle, Washington February 9, 2006

2. Today’s Objective • Become familiar with construction and fire codes that may be applicable to biodiesel manufacturing and processing. • Gain awareness of some materials and operations associated with biodiesel manufacturing that require fire permits. • Better understand the typical plan review and permitting process. • Identify possible pitfalls and how to avoid them.

3. Applicable WAState Laws, Rules and Regulations • 2003 International Fire Code (IFC) with Washington State Amendments WAC 51-54 • 2003 International Building Code (IBC) with Washington State Amendments WAC 51-50 • 2003 International Mechanical Code (IMC) with Washington State Amendments WAC 51-52 • 2002 National Electrical Code (NEC) as adopted by RCW 19.28 and WAC 296-46B • 2003 Uniform Plumbing Code (UPC) Appendix A, B, and I with Washington State Amendments WAC 51-56 & WAC 51-57 • 2004 Washington State Energy Code, Chapter 51-11 • 2003 Washington State Ventilation and Indoor Air Quality Code,Chapter 51-13 WAC only

4. Applicable WAState Laws, Rules and Regulations • The State Building Code Council (SBCC) was established in 1974 to advise the Legislature on building code issues and review, develop and adopt the state building codes. • The State Building Code Council (SBCC) makes statewide amendments to the model codes. • Some cities and jurisdictions are authorized to make additional “local” amendments.

5. State and Local Amendments • Download Washington State code amendments at: http://www.sbcc.wa.gov • Contact local fire or building code official to determine if local amendments are in effect. • New codes published and adopted in Washington State every three years… 2006 IFC effective July 2007

6. Fire Code Permits • 2003 IFC Section 105.6 sets forth the type and quantities of hazardous materials and hazardous operations that require permits. • 2003 IFC Section 105.7 identifies systems and equipment that may require separate installation permits (i.e. to install combustible liquid tanks).

7. Materials likely to need a fire permit (see 2003 IFC Section 105.6)

8. Flammable and combustible liquids and other hazardous material storage • In addition to quantities requiring a permit (the “permit threshold”) the Fire Code establishes a separate threshold for each hazard class called the maximum allowable quantity or MAQ. • If quantities exceeding the MAQ are stored or used inside a building then special engineering controls, fire protection systems and construction features will apply.

9. MAQ’s for some materials(2003 IFC Table 2703.1.1) There are some ways to increase these MAQ quantities by adding approved cabinets and sprinklering the building.

10. Tank installations • Tanks must be designed and approved for the intended use. No water heaters or abandoned home heating oil tanks! • Aboveground flammable liquid tanks must be listed to UL 142 (steel aboveground) or UL 2085 (fire protected). • New fire code requirement that all tanks be equipped with automatic overfill protection to shut down filling operations at 90% of tank capacity. • For inside tanks - normal and emergency tank vents required to extend to the outside of the building. • Tank fill openings required to be located outside the building at least 5 feet from building openings.

11. Fire Code Permits& Compliance • 2003 IFC authorizes the fire code official to issue permits but does not mandate it. Permits may be consolidated, so if multiple materials or activities require permits you may still only receive one. It’s up to the jursidiction. • Regardless of whether the jurisdiction issues permits or not compliance with the Fire Code is mandated.

12. Fire Code Permits& Compliance • 2003 IFC Chapter 34 sets forth regulations for flammable and combustible liquid storage and use and tank installations. • 2003 IFC Chapter 27 identifies regulations for hazardous materials in general. • Other relative chapters: compressed gases, LPG, hot work, and hazard class specific (i.e. corrosive materials) chapters.

13. Getting started • Identify hazard classes and quantities of all hazardous materials that will be stored or used. • Compare materials with permit quantities and also with maximum allowable quantities (MAQ) established by the Fire Code. • Materials over permit quantities will need a permit. • Materials inside buildings that exceed the MAQ must be confined to Group H (Hazardous) Occupancy.

14. The Plan Review Process • Plans should show adequate details of process so the plan reviewer can establish and verify hazards such as: • heat of reactions • pressures of reaction • potential for flammable atmosphere in vicinity of electrical equipment • One difficulty for the jurisdiction is that no nationally recognized industry standard is available to compare or review plans to.

15. The Plan Review Process • Another difficulty is lack of technically qualified fire department staff to conduct the plan review and ask appropriate questions. • 2003 IFC 104.7.2 “authorizes the fire code official to require the owner or agent to provide, without charge to the jurisdiction, a technical opinion and report” to determine the acceptability of technologies, processes, products, facilities and uses attending the design, operation or use of a building or premises.

16. The Plan Review Process • Typically the building and fire code official work in conjunction with one another to review plans for buildings that will contain hazardous materials and hazardous operations. However, each jurisdiction should be consulted to determine their needs. • In Seattle – submit plans to Dept. of Planning and Development (DPD). DPD routes plans to other City Departments (land use, mechanical, electrical, fire, etc.) for review and comment.

17. Avoiding pitfalls and delays • Identify applicable codes (i.e. find out if there are any local amendments to the fire and building codes). • Request a “pre-design conference” with the local building and fire official before you submit plans. In this meeting determine: • level of detail necessary on the plans, • required submittal documents (HMIS, HMMP, process plan) • permits and inspections that will required, • potential land use and SEPA issues, • whether a 3rd party technical review be required by fire code official, • whether a written hazard analysis will be required.

18. Avoiding pitfalls and delays • If a third party review is required agree upon who this will be with the jursidiction early in the process. • If certain aspects of the process are proprietary and will not be revealed to the jurisdiction, prepare a hazard analysis of the process that is complete enough to answer the safety concerns of the jurisdiction. • Design and plan for the future. Allow enough flexibility so that you can increase quantities of the hazardous materials used and stored without being out of compliance with the Fire and Building Code within the year.

19. Questions?