Petition: Recognize Corrugated Bolted Steel Water Storage Tanks for Fire Protection Under NFPA 22

 

Sign The Petition

Introduction

We, the undersigned, representing stakeholders within the fire protection, water storage, and broader safety industries, petition the members of relevant Authorities Having Jurisdiction (AHJs) in Harris County, Texas, to recognize and accept corrugated bolted steel water storage tanks as a viable and equivalent option under the NFPA 22 standard for fire protection. We also request the lifting of any blanket bans on this style of tank in Harris County, Texas, which was prohibited on July 18, 2024.

Background

Corrugated bolted steel tanks have been successfully utilized for fire protection and other water storage needs for over two decades with countless AHJ approvals, including in Harris County, Texas prior to the ban. These tanks are prized for their cost-effectiveness, durability, and ease of installation. Despite their widespread use and proven effectiveness, the NFPA 22 standard does not explicitly provide guidelines for corrugated bolted steel tanks, leaving their acceptance to the discretion of local authorities.

The absence of specific NFPA 22 guidelines has resulted in some jurisdictions, like Harris County, Texas, issuing blanket bans on these tanks. These decisions are often based on inaccurate or incomplete information about the tanks’ performance and construction standards. For example, the Harris County Fire Marshal’s Office (HCFMO) recently issued a statement banning corrugated steel tanks for fire protection, citing concerns over wall thickness, structural integrity, and compliance with ASCE 7 standards. These concerns do not apply to well-designed and engineered corrugated tanks, provided that the calculations and drawings adhere to relevant standards and are thoroughly reviewed and tested for compliance by an AHJ.

Justification

We believe that corrugated bolted steel tanks meet or exceed the performance standards set forth in NFPA 22 so long as proper engineering and manufacturing procedures are followed. This can be recognized under the equivalency clause in Chapter 1.4 of the NFPA 22 standard. Here’s why:

  1. Material Integrity: NFPA 22 equivalent corrugated bolted steel tanks utilize steel with a minimum thickness of 20-gauge, with options for 13-gauge or heavier at the base, far surpassing the 1/32” thickness inaccurately cited by some authorities. These specifications are rigorously engineered to withstand the hydrostatic pressures and hoop stress at the tank base, in full compliance with NFPA 22 and relevant AWWA standards.
  2. Structural Compliance: While AWWA D103 does not explicitly cover corrugated steel tanks, it does not exclude them either. NFPA 22 allows for equivalency, provided that tanks meet the general requirements of NFPA 22 Chapter 4. Corrugated bolted steel tanks can meet these requirements through detailed structural calculations and compliance with standards like ASCE 7, where applicable.
  3. Safety and Reliability: By incorporating corrugated bolted steel tanks under the NFPA 22 standard, the industry will ensure consistency in design, engineering, and quality control, ultimately enhancing safety and reliability in fire protection systems.

Request

We urge the AHJs within Harris County, Texas, to recognize corrugated bolted steel tanks as compliant with NFPA 22 under the equivalency clause. Specifically, we request:

  1. Inclusion under NFPA 22 Chapter 1.4: Acknowledgment that corrugated bolted steel tanks meet the necessary equivalent safety and performance criteria when properly engineered and documented.
  2. AHJ Review and Acceptance: Encouragement for AHJs to verify and approve the use of corrugated bolted steel tanks based on their performance and structural calculations. This contrasts preconceived notions or isolated incidents of catastrophic tank failures from nefarious tank manufacturers and suppliers who fail to uphold the current equivalency standards.
  3. Public Comment and Petition Support: Stakeholders are encouraged to submit public input on this tank style for the next edition of NFPA 22 and to sign this petition in support of recognizing corrugated bolted steel tanks for fire protection use.

Conclusion

The inclusion of corrugated bolted steel tanks under NFPA 22 is crucial for advancing fire protection technology, ensuring safety, and providing more flexible and cost-effective solutions for fire protection water storage. We respectfully ask that AHJs within Harris County, Texas, consider our petition and take the necessary steps to recognize the use of these tanks under the current standards.

Thank you for your attention to this important matter.