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Enron Mail |
Energy Committee Members:
Below is some info about Permitting for Generators. +++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++ Why the permits for portable generators? Well, the California Fire Code (CFC) has definitions on what does and does not have to be permitted. In particular, Section 105f.3.3, specifically states "...any tanks which are used to store, handle or dispense Class II or IIIA Combustible Liquids....over 60 gallons...outside a building..." are subject to permitting. It is no coincidence that day-tanks on most generators are 60 gallons or less. However, there is a difference between a day-tank and a belly-tank. Day tanks are for the occasional cranking. Belly tanks are for operation. Does the belly tank on this diesel generator exceed 60 gallons? If yes, read on. Now that we know we're subject to permitting, we have to follow CFC Article 79, which handles flammable and combustible liquids, and specifically has sections on tanks. You must comply with all pertinent sections of Article 79 (and potentially a few Appendicies), in order to bring these things on your property. True, it's a generator, and it may be portable, and even temporary, but if it exceeds 60 gallons in storage capacity, it requires a permit. The Code is very black-and-white on that one. The Cities of Sunnyvale, Santa Clara, San Jose etc., who all have genarators for their emergency operations centers, ALL have permits for their tanks, and ALL of them have to go through the same exact permitting procedures that we have to (submit plans, pay fees, etc.). No special treatment. The arguement is raised about what if you have a crane, or large truck on your property, with fuel tanks over 60 gallons? Well, those are considered vehicles, and you aren't connecting them to the building's power supply. A portable generator, you tow in, drop and plug into the building. The City will want to verify that it has secondary containment, seismic bracing, proper restraint so it doesn't go rolling around your property, emergency shutoffs, etc. Additionally, you need to check with your utility provider to ensure that they are aware that your buildings are under generator power when you turn them on, and they don't think a grid section is down. Or, worse yet....that you are back-feeding the grid. Trust me, they will want to know. Now, the CFC issues have nothing to do with Air Quality restrictions, and therefore, the "Statewide Portable Generators" certification. Those are differing issues. If I remember correctly, BAAQMD relaxed the time limits on generator operation for a brief while, to allow for local generation during crises. All that is allowing us to do is operate our generators without the significant pollution restrictions. I disagree with the belief that these units should be exempt from Fire Code Review. Personally, I would like to know that the installation, placement, fuelling, and restraint of 1000 gallons of diesel fuel on wheels on my property, has met some sort of outside scrutiny. Also, I know that this is not winter or the rainy season; however, we ARE also in a flood plain here in certain areas of Santa Clara County, and certainly people have seen the news stories of propane and diesel tanks floating down a river. This is why the City of San Jose (and most others) has attempted to mandate underground tanks, in addition to a myraid of other concerns. This is also a CFC Article 79 requirement. There are exceptions for underground tank installations, that we here at Intel take to keep all of our tanks above-ground. If you know of any other member agencies who are harboring generators with tanks in excess of 60 gallons, I suggest that you have them notify their local Fire Department, and hat-in-hand request guidance. They are usually very good about working with you in an emergency, if you ask them what to do rather than tell them what you're doing. If anyone has any questions, please feel free to give me a call. Regards, Todd Todd LaBerge, P.E. Senior Fire Protection Engineer Intel Corporation 408-765-4558 (tele) 408-718-3356 (cell) todd.a.laberge@intel.com
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