November 17, 2011 Director, Safety and Regulatory Affairs...

November 17, 2011

Mr. Mike Jennings

Director, Safety and Regulatory Affairs

Leslie’s Poolmart, Inc.

3925 East Broadway Road, Suite 100

Phoenix, AZ 85040

Re: Fire Safety Code Review for Proposed Distribution Center in Dallas, Texas.

HAI Project: 1AAK00020.000

Dear Mike:

As requested, Hughes Associates, Inc. (HAI) has prepared this fire safety review for a

portion of the building located at 5220 S. Westmoreland Road in Dallas, TX. The scope of this

review is fire safety code compliance as it relates to the proposed occupancy of the suite as a

distribution center for Leslie’s Poolmart, Inc. (Leslie’s). The scope of this review only includes

those issues directly related to the storage of products within Leslie’s inventory and does not

include other code review issues, such as structural, mechanical, electrical, plumbing or

environmental issues. HAI has not performed a visual inspection of the proposed tenant space.

Information referenced herein with respect to the existing building systems and features has been

provided by the project architect and the design team.

1 INTRODUCTION

The warehouse building at 5220 S. Westmoreland Road is a total of approximately 345,600

square feet and consists of three suites. Figure 1 provides a site plan showing the three suites.

The suite at the southern end of the building is occupied by Almo as a warehouse and reportedly

contains electronics and electrical equipment. The suite in the center is currently unoccupied and

is expected to remain that way for the immediate future; it is designated as a potential future

expansion space for the tenants in the south or north suites. The space proposed for the Leslie’s

Dallas Distribution Center is the suite at the north end of the building, which is a total of

approximately 151,200 square feet. The demising wall between the Almo warehouse and the

rest of the building is currently constructed floor to roof, and the new demising wall at the south

end of the Leslie’s suite will also be constructed floor to roof.

Mr. Mike Jennings

November 17, 2011

HUGHES ASSOCIATES, INC.

Figure 1 – Site Plan for 5220 S. Westmoreland Road, Dallas, TX

Mr. Mike Jennings

November 17, 2011


The building is currently protected throughout by approved automatic sprinkler systems. The

north suite is currently protected by an ESFR (early suppression fast response) automatic

sprinkler system and has a clear height of approximately 30 feet from the finished floor to the

sprinklers. The ESFR sprinkler system has K 14.0 heads designed to flow at 75 psi. The

building sprinkler system is supervised by the building fire alarm system, which is supervised by

a central station. Information was not available at the time of this report regarding the make,

model, and location of the fire alarm panel in the building, or the name and location of the

central station service company.

2 APPLICABLE CODES AND STANDARDS

The authority having jurisdiction includes the City of Dallas Department of Sustainable

Development and Construction, Building Inspection Division, and the City of Dallas Fire@Rescue

Department. The applicable codes and standards include:

o Dallas Building Code (DBC), which incorporates and amends the 2006 edition of the

International Building Code;

o Dallas Fire Code (DFC), which incorporates and amends the 2006 edition of the

International Fire Code;

o Dallas Mechanical Code (DMC), which incorporates and amends the 2006 edition of

the International Mechanical Code;

o 2008 National Electrical Code (NFPA 70, NEC) with Dallas Amendments;

o 2010 Edition of NFPA 13, Standard for Installation of Sprinkler Systems;

o 2008 Edition of NFPA 30, Flammable and Combustible Liquids Code; and

o 2010 Edition of NFPA 400, Hazardous Materials Code.

Note that the requirements of the former NFPA 430 (Code for the Storage of Liquid and

Solid Oxidizers) have been moved into NFPA 400, primarily Chapter 15.

3 OCCUPANCY CLASSIFICATION

3.1 General

The proposed use of the suite by Leslie’s is for wholesale storage and distribution of a wide

range of pool supplies, including some chemicals. The tenant space will consist of office areas

and the warehouse storage of stock in the remainder of the building. For products classified as

hazardous materials, when the proposed quantities exceed the code maximum allowable

quantities (MAQ), those products are proposed to be stored in code compliant hazardous

materials cut@off storage rooms (Use Group H Rooms). The use of the warehouse is also

Mr. Mike Jennings

November 17, 2011


proposed to include limited repackaging of Dichlor and some non@hazardous products (e.g.

Sodium Carbonate, Sodium Bicarbonate) from large sacks (supersacks) into smaller containers.

Products are expected to be stored both on metal racks (bin shelving, shelf racks and pallet

racks) and some limited bulk piles (floor storage). The storage areas will only be accessible to

employees; they will not be accessible to the public. Based on the storage of combustible

materials and the description of use, the proposed use of the warehouse is consistent with a

Group S@1 Storage occupancy (DBC §311.2). As discussed below, the cutoff storage area for

hazardous materials is classified by the DBC as Group H@3 and Group H@4 High Hazard

occupancy. The suite will also include supporting office areas for staff, and shipping and

receiving areas for products coming in and going out; these areas are classified by DBC §304 as

Group B Business. The layout of the suite is proposed to comply with the requirements for

separated mixed occupancies, in accordance with DBC §508.3.3.

3.2 Hazardous Materials

Some goods proposed to be stored for sale by Leslie’s are classified as hazardous materials

(hazmat) by the DBC. This includes primarily Class 1, 2 and 3 oxidizers; corrosive solids and

liquids; combustible liquids; and limited amounts of flammable IB liquids. The DBC identifies

the use of indoor and outdoor control areas for hazardous material storage within allowable

limits. Control areas are defined by DBC §307.2 as spaces within a building that are enclosed

and bounded by exterior walls, fire walls, fire barriers and roofs, or a combination thereof, where

quantities of hazardous materials not exceeding the maximum allowable quantities (MAQ) per

control area are stored, dispensed, used, or handled.

DBC Tables 307.1(1) and 307.1(2) identify the MAQ’s per control area of hazardous

materials, provided such buildings are maintained in accordance with the DFC. Fire rated

barriers between control areas are required to be rated for 1@hour or more, depending on the

materials stored and occupancy classifications. According to DBC Table 414.2.2, a maximum of

four control areas are permitted in this one@story building. Additionally, in accordance with

DBC Section 414.2.5, the aggregate quantity of nonflammable solid and nonflammable or

noncombustible liquid hazardous materials permitted within a single control area of a Group S

occupancy is permitted to exceed the MAQ specified in DBC Tables 307.1(1) and 307.1(2)

without classifying the building or use as a Group H occupancy, provided that the materials are

displayed and stored in accordance with the DFC and the quantities do not exceed the maximum

allowable quantities specified in DBC Table 414.2.5(1). This code provision is proposed to be

used in the main warehouse for the quantities of Class 2 and Class 3 oxidizers in storage.

The accompanying Hazardous Materials Inventory Statement (HMIS) provides the hazmat

classifications (per the DFC) of the proposed products, which were determined through review of

the manufacturer material safety data sheets, as well as guidance provided in relevant NFPA

standards. Table 3@1 below summarizes the aggregate maximum quantity of each hazmat class

projected to be stored and the applicable code MAQ for that space. Per Table 3@1 and Figure 2,

the suite is proposed to include two control areas, warehouse 1 and warehouse 2, and an H@3/H@4

cutoff storage room with internal sub@divisions to support separation of incompatible substances.

Mr. Mike Jennings

November 17, 2011


Table 3/1: Summary of Maximum Project Quantities and Code Maximum Allowable Quantities

Hazard Classification

Warehouse #1 (Control Area #1)

Warehouse #2 (Control Area #2)

Areas 1, 2, and 3 (H�3/H�4 Occupancy)

Area 4 (H�4 Occupancy)

Code Limit Projected Max Code Limit Projected Max Code Limit Projected Max Code Limit Projected Max

Levels 2 and 3 Aerosol 24,000 lbs 560 lbs 24,000 lbs N/A N/A N/A N/A N/A

Class 1B Flammable Liquids 240 gals 20 gals 240 gal N/A 15,000 gals 175 gals N/A N/A

Class II Combustible Liquids 240 gals 100 gals 240 gal N/A 24,000 gals 2,894 gals N/A N/A

Class IIIA Combustible Liquids 660 gals 50 gals 660 gal N/A 48,000 gals N/A N/A N/A

Class IIIB Combustible Liquids Not Limited 14,983 gals 1,307 lbs

Not limited N/A Not Limited N/A Not Limited N/A

Class 1 Oxidizer Solids Not Limited 31,500 lbs Not limited 1,554,985 lbs Not Limited N/A Not Limited N/A

Class 1 Oxidizer Liquids Not Limited 2,735 gals Not Limited N/A Not Limited N/A Not Limited N/A

Class 2 Oxidizer Solids 4,500 lbs 4,500 lbs 4,500 lbs N/A 1,000,000 lbs 82,560 lbs N/A N/A

Class 3 Oxidizer Solids 2,300 lbs 2,300 lbs 2,300 lbs N/A 1,000,000 lbs 568,611 lbs N/A N/A

Class 1 Water Reactive Solids Not Limited 16,000 lbs Not limited 708,041 Not Limited N/A Not Limited N/A

Class 1 Unstable Reactive Not Limited N/A Not Limited N/A Not Limited 4,641 lbs Not Limited N/A

Toxic Solids 1,000 lbs 30 lbs 2,000 lbs N/A Not Limited 5,003 lbs Not Limited N/A

Corrosive Solids 10,000 lbs 10,000 lbs 19,500 lbs N/A Not Limited N/A Not Limited 767,434 lbs

Corrosive Liquids 1,000 gals 950 gals 1,950 gal N/A Not Limited 2,626 gal Not Limited N/A

Primary Chemical Products in this Location

Adhesives; some paints; kits, except those containing Cal6Hypo; some algaecides; limited quantities of oxidizers, flammable & combustible liqs

Trichlor tablets and granules; Dichlor granules

Cal6Hypo Tablets & granules, and kits containing Cal6Hypo; Bromine Tablets; Class 1B, II and IIIA liquids; Corrosive liquids

Fresh and Clear

Mr. Mike Jennings

November 17, 2011


Figure 2: Proposed Floor Plan for Leslie’s Pool Supplies Dallas Distribution Center

Mr. Mike Jennings

November 17, 2011


3.3 Summary of Occupancy Classifications

The proposed use of the warehouse by Leslie’s is classified as a mixed use occupancy with

specific areas classified as described below and shown in Figure 2.

Table 3/2: Summary of Proposed Occupancy Classifications

Space(s) Use Occupancy Classification

Office Areas Offices, Shipping/Receiving Group B Business

Warehouse 1 Storage of non@combustible and combustible

commodities, and hazardous materials within the

code maximum allowable quantities

Group S@1 Moderate Hazard

Storage

Warehouse 2 Storage of Class 1 oxidizers in a fully sprinkler

protected facility

Group S@1 Moderate Hazard

Storage

Area 1 Closed storage of Class 3 oxidizers with a

corrosive classification

Group H@3/H@4

Area 2 Closed storage of Class 2 oxidizers with a

corrosive classification

Group H@3/H@4

Area 3 Closed storage of flammable and combustible

liquids, and corrosive liquids

Group H@3/H@4

Area 4 Closed storage of corrosive solids Group H@4

4 CONSTRUCTION REQUIREMENTS

4.1 Building Height and Area

The proposed Leslie’s tenant space is required to comply with the height and area limitations

of DBC Chapter 5 for the construction type. The building consists of concrete tilt@up walls and

concrete floors with exposed steel structural members inside, consistent with Type IIB

construction (DBC Table 601). The building height at the peak is 35 ft (up to 30’@0” clear

height), less than the maximum of 55 feet permitted in DBC Table 503 for Type IIB

construction.

Based on complete sprinkler protection, being surrounded by more than 60@ft of yard or

public way on all sides, and its use for Group B, S and limited Group H occupancies, the single

story building qualifies for unlimited area construction in accordance with DBC §507.2. DBC

§507.7 permits the aggregate floor area of Group H occupancies on the building perimeter to be

up to 10% of the building area (i.e. 34,500 square feet) provided the area limitations of DBC

Table 503, modified by the open area allowances of DBC §506.2, are also met. The total Group

H@3 occupancy permissible in a Type II@B construction with 60 feet plus clear around half of the

perimeter is 21,000 sq ft; the Group H@3 area proposed is approximately 16,200 sq. ft. The total

Group H@4 occupancy permissible is 26,250 sq ft; the Group H@4 area proposed is approximately

18,900 sq ft. There are reportedly no Group H occupancies in the building currently.

Mr. Mike Jennings

November 17, 2011


4.2 Provisions for Storage of Hazardous Materials

The proposed construction is to provide a cutoff storage area with half of its perimeter as

exterior walls for enclosure of the Group H@3/H@4 occupancy, separated from the Warehouse 1

and Warehouse 2 storage areas by 2@hour fire barrier walls. Within the cutoff storage areas there

will be minimum 1@hour fire rated sub@divisions to accommodate the various types of materials

and in particular to ensure separation of incompatible materials. The room for storage of Class 3

oxidizers (i.e. Area 1) will be separated on all interior sides by 2@hour fire rated construction.

The proposed construction also includes a separated room (Warehouse #2) for storage of

Class 1 oxidizers that is constructed as a separate control area (i.e. 1@hour fire rated

construction). Together with the cutoff storage area, this proposed construction complies with

all applicable DBC and DFC construction requirements, which are listed below. Figure 3 depicts

the proposed fire barrier separations.

1. Control areas on the ground floor must be separated from other areas by minimum 1@

hour fire rated construction (DBC Table 414.2.2). The office areas and the

shipping/receiving areas are considered part of control area #1, which includes

Warehouse #1.

2. Cutoff storage areas for Class 2 and Class 3 oxidizers must be separated from the rest

of the building by 2@hour fire rated construction (DFC Tables 4004.1.7(2) and

4004.1.7(3)).

3. The barrier between adjacent Group H@3 and H@4 rooms is permitted to be an unrated

wall (DBC Table 508.3.3).

4. A minimum of 25% of the perimeter of Group H@3 occupancies larger than 1,000 sq.

ft. must be exterior walls (DBC §415.3).

5. The floors of the Group H@3 occupancy must be liquid tight and non@combustible

(DBC §415.5.1 and 415.7.2, and DFC §2704.2 and 2704.12).

5 REQUIREMENTS FOR STORAGE OF MATERIALS

The proposed use of the tenant space by Leslie’s includes storage of materials up to the

maximum allowable storage heights. The fire protection requirements applicable to the proposed

arrangements are addressed in section 6 of this report. The other applicable requirements are

listed below; the current design includes compliance with these requirements. Figure 4 below

depicts the storage locations for the products that drive the prescribed storage arrangements and

required sprinkler protection regimes.

Mr. Mike Jennings

November 17, 2011


Figure 3: Fire Barrier Separations Between Hazardous Materials Storage Areas

2@hr fire barrier wall

1@hr fire barrier wall

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November 17, 2011


Legend

Figure 4 – Proposed Storage Locations for Products with Special Protection Requirements

Mr. Mike Jennings

November 17, 2011


5.1 High Piled Storage

High piled combustible storage is defined in DFC §2302.1 as “Storage of combustible

materials in closely packed piles or combustible materials on pallets, in racks or on shelves

where the top of storage is greater than 12 feet in height. When required by the fire code official,

high@piled combustible storage also includes certain high@hazard commodities, such as rubber

tires, Group A plastics, flammable liquids, idle pallets and similar commodities, where the top of

storage is greater than 6 feet.” The DFC includes an amendment that any Group S occupancy

exceeding 12,000 square feet that has a clear height that permits storage above 12 feet shall be

considered to be high piled storage. The following proposed storage spaces meet the definition

for high piled storage: Warehouse 1, Warehouse 2, Area 3 and Area 4. Per DFC Table 2306.2

and other sections as referenced, the following requirements apply to these four areas:

1. Smoke and heat removal is required. DFC §2306.7 Exception does not require smoke

and heat removal in fully sprinkler protected buildings. The building does not have

smoke and heat vents, but is fully sprinkler protected and is therefore compliant.

2. Automatic sprinkler protection is required (see section 6 of this report for sprinkler

and aisle width requirements).

3. Automatic smoke detection is not required.

4. Draft curtains are not required.

5. Flue spaces in rack systems must comply with the spacing requirements of DFC

Table 2308.3.

6. Steel building columns shall be protected by either 1@hour fire insulation or special

sprinkler protection as described by NFPA 13 (DFC §2308.4). Per NFPA 13

§16.1.4.1 columns in Warehouse 1, Warehouse 2 and Area 4 will be protected by the

ESFR sprinkler system, and in Area 3 by in@rack sprinklers.

7. Exterior doors permitting fire department access are required every 100 lineal feet of

exterior walls. The building is constructed in this manner.

5.2 General Requirements for Hazardous Materials Storage

The following requirements apply to all six storage areas.

1. Incompatible materials in storage must be separated when the stored materials are in

containers having a capacity of more than 5 pounds or 0.5 gallons. (DFC §2703.9.8).

Separation can be accomplished by:

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November 17, 2011


a. Segregating incompatible materials in storage by a distance of not less than 20

feet (oxidizers and flammable liquids should be separated by a minimum of 25

feet),

b. Isolating incompatible materials in storage by a noncombustible partition

extending not less than 18 inches above and to the sides of the stored material.

c. Storing liquid and solid materials in hazardous material storage cabinets.

d. Storing compressed gases in gas cabinets or exhausted enclosures in

accordance with DFC §2703.8.5 and 2703.8.6. Materials that are

incompatible shall not be stored within the same cabinet or exhausted

enclosure.

e. NOTE: Following the guidance in NFPA 400, solid oxidizers should not be

stored beneath liquids, especially incompatible liquids.

2. Appropriate spill clean@up kits should be located in the warehouse for the different

types of chemicals.

3. NFPA 704 signage is required at the entrances to the warehouse and the interior

storage rooms, and on the building exterior (DFC §2703.5).

4. Persons responsible for the operation of areas in which hazardous materials are

stored, dispensed, handled, or used shall be familiar with the chemical nature of the

materials and the appropriate mitigating actions necessary in the event of fire, leak, or

spill. (DFC §2703.9.1)

5. Smoking is prohibited inside the warehouse and the other storage rooms. No smoking

signs shall be placed in each of these locations. (DFC §2703.7.1)

6. Open flames and high@temperature devices shall not be used in a manner that creates

a hazardous condition. (DFC 2703.7.2)

7. The storage areas shall be secured against unauthorized entry and safeguarded in a

manner approved by the fire code official. This includes approved safeguards to assist

in the prevention of unauthorized entry into the building or the unauthorized removal

of hazardous chemicals.(DFC §2703.9.2)

8. Portable fire extinguishers are required, and shall be selected and located in

accordance with NFPA 10 (DFC §906.1).

a. Following the guidance in NFPA 400, portable fire extinguishers containing

ammonium compounds (i.e. most dry chemical extinguishers) or Halon should

not be used on fires that may involve oxidizers and it is recommended that

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November 17, 2011


they not be provided in areas where oxidizers are stored. Also CO2

extinguishers are ineffective against fires involving oxidizers.

b. Water based fire extinguishers (straight stream and/or water mist) with

minimum 2A rating are the preferred option in the areas that contain

oxidizers. Water mist extinguishers can also be considered as a viable option

for the rest of the suite in lieu of dry chemical extinguishers.

9. Material safety data sheets for each chemical must be kept up to date and available

on@site. (DFC §2703.4).

5.3 Warehouse #1 and #2

In addition to the general requirements listed in section 5.2, the following apply to

Warehouse #1 and #2:

1. Hazardous materials quantities will comply with the MAQ for Group S occupancies

in accordance with DFC Tables 2703.1.1(1) and 2703.11.1. These are summarized

above in Table 3@1.

2. Warehouse #2 will be separated from Warehouse #1 by minimum 1@hour fire rated

construction, including 45@minutes fire doors at openings between the two.

3. The minimum aisle width will be 4 feet wide (DFC §2306.9.1.1 and 2703.11.3.9).

4. The maximum storage height for Class 1 oxidizers will be 20 ft (DFC Table

4004.1.7(1).

5. The maximum storage height for Class 2 and Class 3 oxidizers will be 8 ft (DFC

§2703.11.3).

6. The maximum storage height for expanded plastic products will be 25 ft, based on the

NFPA 13 ESFR sprinkler system protection criteria for this commodity.

7. The maximum storage height for all other products in Warehouse #1 and Warehouse

#2 will be 27 feet, based on the NFPA 13 requirement for minimum 3 feet clearance

below ESFR sprinkler heads.

5.4 Cutoff Storage Area (Group H Occupancy)

1. The cutoff storage area will be separated from Warehouse #1 and Warehouse #2 by 2@

hour fire resistance rated construction, including minimum 90@minute fire resistance

rated doors (DFC §4004.1.7 and DBC Table 715.4).

Mr. Mike Jennings

November 17, 2011


2. Mechanical exhaust ventilation complying with the Dallas Mechanical Code (DMC)

will be provided at a rate of at least 1 cfm/ft2 (DFC §2704.3).

a. The exhaust ventilation must run continuously unless approved otherwise by

the fire code official. A manual shutoff switch is required outside the rooms,

adjacent to the warehouse side access door or another location approved by

the code official, and provided with a sign stating “VENTILATION SYSTEM

EMERGENCY SHUTOFF.”

b. The exhaust ventilation cannot be recirculated to the rest of the building,

unless it is treated to remove any hazardous contaminants (e.g. corrosive

vapors) in the air stream.

c. The anticipated vapors are expected to be heavier than air and therefore the

exhaust must be taken as close to the floor as practicable and preferably

within 12 inches of the floor. The exhaust and inlet air openings will be

positioned to provide air movement across all portions of the floor.

d. Exhaust outlets and ducts must terminate outside the building no less than 10

feet from the property line, 3 feet from exterior walls and the roof, 10 feet

from operable openings into this or adjacent buildings and 10 feet above grade

(DMC §501.2.1). Locate the exhaust outlets remote from any ventilation

inlets.

3. A manual emergency alarm system will be provided in accordance with DFC

§2704.9. The following requirements apply to the system:

a. The alarm initiating device shall be located outside of each interior exit access

door (i.e. not located outside the building) of each of the H@3/H@4 rooms.

b. Activation of the emergency alarm must initiate a local alarm at the building

to alert occupants. This alarm notification must be distinguishable from the

notification given for a fire alarm.

4. All fire detection, emergency alarm and sprinkler systems will be supervised by an

approved central, proprietary or remote station service (DFC §2704.10). The existing

fire alarm control panel will be evaluated to confirm there is adequate capacity to add

the smoke detection and emergency manual alarm systems.

5. A liquid@tight floor will be provided (DFC §4004.1.5).

6. Spill control and secondary containment are required for Areas 1, 2 and 3 since they

store Class 3 oxidizers, Class 2 oxidizers, flammable and combustible liquids and

corrosive liquids (DFC Table 2704.2.2 and DFC §3404.3.7.3). The code permits

containment by either draining the liquid to an approved storage location or by using

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November 17, 2011


liquid tight barriers to contain the liquid in the area of origin. The current design

proposes to contain the liquid in the H@3 occupancy (i.e. within the area occupied by

Areas 1, 2 and 3) by providing liquid tight floors and liquid tight barriers along the

outer perimeter of the H@3 occupancy (i.e. the exterior walls and the boundaries with

Warehouse 1 and Area 4). Sprinkler water will be permitted to flow between Areas

1, 2 and 3 (i.e. beneath doors and through small (3@inch diameter or less) semicircular

drains. The secondary containment is required to include 20 minutes of sprinkler

system water flow. Based on the required sprinkler system protection in these areas,

the required curb height around the H@3 occupancy is 6@inches. This curb height will

contain the water volume from any of the sprinkler system protection schemes

discussed in this report, including use of the existing ESFR system plus in@rack

sprinklers. A 20% overage on actual water flow was assumed above the specified

water flow levels. As shown in Figure 3, as a result of the containment curb there are

ramps proposed for fork truck and personnel entry and exit from the affected areas.

7. Emergency or standby power will be provided for the following systems in the cutoff

storage area: emergency alarm, mechanical ventilation and smoke detection (DFC

§2704.7). The backup power for the emergency alarm and fire detection systems can

be provided through the fire alarm system provided the fire alarm system power

backup (e.g. battery) is shown to have adequate capacity.

8. Area #1 (Class 3 Oxidizers) additional requirements are:

a. The automatic sprinkler system must be provided in accordance with the rack

storage criteria in NFPA 400 Table 15.3.2.4.12.3(B).

b. The maximum storage height is listed by DFC Table 4004.1.7(3) as 10 ft.

i. Using the protection scheme mandated in NFPA 400 for two levels of

storage as depicted in NFPA 400 Figure 15.3.2.4.12.4(A), it is

estimated that the top of storage will be approximately 10 ft@11 inches

above finished floor (AFF). Considering that the storage arrangement

matches what is prescribed in NFPA 400 (including that the shelf for

the second level of storage is 6 ft AFF), and that the actual aggregate

height of product being stored is less than 10 ft (i.e. the 11 inches

overage is due to the size of the rack’s structural beam and the

sprinkler head clearances), HAI concludes that the proposed

arrangement meets the code intent for the protection criteria. See

Figures 5 and 6 below for the NFPA 400 scheme and the Leslie’s

proposed arrangement, respectively

ii. The proposed storage height is less than 12 feet and is therefore not

high piled combustible storage.

Mr. Mike Jennings

November 17, 2011


c. The aisle width between racks will be at least 8 ft wide (NFPA 400 Table

15.3.2.4.12.3(B)).

d. A minimum 4 ft clearance must be provided between Class 3 oxidizers and

adjacent walls (DFC 4004.1.7(3).

e. A supervised smoke detection system must be provided in Area 1, with a local

alarm (i.e. fire alarm) in the warehouse upon activation (DFC §4004.1.6). The

detectors will be installed in accordance with NFPA 72 and the

manufacturer’s recommendations.

Figure 5: Excerpt from NFPA 400 – Storage Arrangement and In Rack Sprinkler

Protection for Class 3 Oxidizers

Mr. Mike Jennings

November 17, 2011


Figure 6 – Proposed Storage Arrangement of Class 3 Oxidizers in Area 1

(Includes One Pallet Load of Different Container Sizes on Two Rack Levels)

9. Area #2 (Class 2 Oxidizers) additional requirements are:

a. The automatic sprinkler system must be provided in accordance with the 12@ft

high storage rack storage criteria in NFPA 400 Table 15.3.2.3.2.10(B).

b. The maximum storage height is listed by DFC Table 4004.1.7(2) as 12 ft.

i. The proposed storage configuration will be less than 12 ft AFF, and

therefore is not classified as high piled combustible storage.

c. The aisle width between racks will be at least 8 ft wide (NFPA 400

§15.3.2.3.2.5).

Mr. Mike Jennings

November 17, 2011


d. A minimum 2 ft clearance must be provided between Class 2 oxidizers and

adjacent walls (DFC Table 4004.1.7(2).

e. A supervised smoke detection system must be provided in Area 2, with a local

alarm (i.e. fire alarm) in the warehouse upon activation (DFC §4004.1.6). The

detectors will be installed in accordance with NFPA 72 and the

manufacturer’s recommendations.

10. Area 3 (Corrosive Liquids and Flammable and Combustible Liquids) additional

requirements:

a. Maximum storage height for the flammable and combustible liquids is 25 ft

(DFC Table 3404.3.6.3(3).

b. The minimum aisle width between racks is based on the sprinkler system and

must be at least 7.5 ft (DFC Table 3404.3.6.3(5) note b). The main aisle(s) of

the room must be at least 8 ft wide (DFC §3404.3.7.2.2).

c. The maximum storage height for corrosive liquids is based on the sprinkler

system protection provided in the room and will be at least 27 ft (see section

6.1 below). Minimum aisle width for the corrosive liquids is 4 ft.

d. At least one portable fire extinguisher with a minimum rating of 20@B must be

provided outside the room on the Warehouse #1 side less than 10 ft from the

entrance door (DFC §3404.3.7.5.2).

11. Area 4 (Corrosive Solids) additional requirements:

a. Minimum aisle width between racks must be 4 ft wide.

6 FIRE PROTECTION REQUIREMENTS

6.1 Commodity Classification

6.1.1 General

The products stocked by Leslie’s include chemicals, combustible products and non@

combustible products. The chemical products are listed in the HMIS. The non@chemical

products are categorized as follows:

o Filters and filter accessories;

o Pumps and motors;

o Heaters and coolers;

Mr. Mike Jennings

November 17, 2011


o Pool cleaning equipment and accessories;

o Pipes, fittings and other plumbing supplies (primarily PVC);

o Lighting and lighting controls;

o Pool covers;

o Pool liners and steps;

o Recreational products, including floats, inflatables, pool games and lounges;

o Gates, alarms and other security equipment; and

o Rescue tubes, buoys and other safety equipment

Based on a review of the product component materials and following the guidance provided

in NFPA 13, §5.6.3, the products not classified as hazardous materials are primarily Class I

through Class III commodities, with some Class IV and some Group A Plastics. The

classification and appropriate sprinkler system protection for the products with plastic content

are discussed further below.

6.1.2 Products with Plastic Content

The products with plastic content that are stocked by Leslie’s are summarized in Table 6@1,

along with the commodity classification and sprinkler system protection guidance provided in

NFPA 13, §5.6.3 (and the accompanying appendix section).

Table 6/1: Commodity Classification for Products with Plastic Content

Products NFPA 13 Classification Notes

Small fittings and replacement parts, such as gaskets and nozzles

Free#flowing Group A plastic materials, protected as Group IV commodities

Stocked in original cardboard boxes or in open bins.

Pumps with plastic components

Group IV commodity – plastic content is less than 15% by weight or less than

25% by volume

Stocked in original cardboard boxes

Plastic cleaning equipment (e.g. vacuum hoses)

Unexpanded Group A plastic

Stocked both exposed and in cardboard boxes

Plastic pails 5 gallons or less filled with non#combustible liquids, and

stored in cardboard cartons Group I commodity Pool chemicals

Mr. Mike Jennings

November 17, 2011


Products NFPA 13 Classification Notes

Plastic bottles 1 gallon or less with non#combustible powders, stored in

cartons Group IV commodity Pool chemicals

Plastic bottles more than 1 gallon size with powders/solids, stored in

cartons


Pool chemicals

Plastic bottles and buckets with powders/solids, any size,

uncartoned


Pool chemicals

Plastic recreational products Group A plastic (both

unexpanded and expanded)

Both cartoned and uncartoned

Solar blankets Unexpanded Group A

plastic Both cartoned and uncartoned

Plastic pool steps Unexpanded Group A

plastic Stocked exposed

Plastic pool liners Unexpanded Group A

plastic Stocked in cardboard boxes

6.2 Automatic Sprinkler System

The warehouse is currently protected throughout by an ESFR automatic sprinkler system.

There are no known concerns with the fire protection water supply or the building sprinkler

system.

6.2.1 Current Provisions and Water Supply

According to the sprinkler contractor as@built shop drawings dated 12/30/2008, the system

design includes K14.0 ESFR pendents at 75 psi and 250 gpm outside hose demand. The drawing

notes that the inside hose valves were excluded by direction of the fire code official. A fire

pump is provided with a rated capacity of 2,000 gpm at 90 psi, and pressure relief set at 175 psi.

The water flow test results of the city supply to the pump on 7/25/2008 are quoted as:

Static: 76 psi

Residual: 70 psi, while flowing 1324 gpm

Action Item #1: It is recommended that a new flow test be conducted, if none has

been done in the past 12 months, to confirm that the water supply is substantially

the same as the design basis.

Mr. Mike Jennings

November 17, 2011


6.2.2 Protection Criteria

Based on the proposed storage arrangements, the applicable protection criteria for each space

are summarized in Table 6@2.

Table 6/2: Summary of Sprinkler System Protection Criteria

Area Primary Hazard Protection Requirement Actions Needed

Area #1 Class 3 Oxidizers Per NFPA 400, Table 15.3.2.4.12.3(B) any ceiling protection of OH2 or better is

acceptable, plus multiple lines of in6rack sprinklers at both storage elevations, plus

3/86in plywood barriers at the top, back and sides of each bay

Add quick response K=8.0 in6rack sprinklers as shown in

Figure 5 above. Changes to the ESFR system are only needed in regards to secondary containment, but

otherwise can remain.

Area #2 Class 2 Oxidizers Per NFPA 400, Table 15.3.2.3.2.10(B) – 0.20 gpm/ft2 over 3,750 ft2 at the ceiling plus one

line of in6rack sprinklers above the lower level of storage (i.e. 2 levels of storage expected)

Add one line of quick response K = 8.0 in6rack

sprinklers spaced 8 to 10 ft apart and flowing six heads at

25 psi each. Also, see discussion below regarding

ESFR sprinklers.

Area #3 Class 1B Liquids Per DFC Table 3404.3.6.3(5) Option 2, provide 0.55 gpm/ft2 over 2,000 ft2 at the ceiling, plus one line of shielded in6rack

sprinklers above each level of storage in the longitudinal flue space and located no more

than 8 ft63 inches apart

Add in6rack sprinklers – ordinary temperature, quick

response with 0.53 inch orifice and 14 psi operating

pressure.

Area #4 Corrosive solids in plastic pails up to 27 ft

Per NFPA 13, Table A.5.6.3 this commodity is bounded by unexpanded Group A Plastics.

See protection requirements below.

None.

Warehouse #1 Expanded Group A Plastics up to 25 ft

Per NFPA 13 Table 17.2.3.1, K=14.0 operating at 50 psi is the minimum protection

None

Warehouse #1 Unexpanded Group A Plastics up to 27 ft


None

Warehouse #1 Class IV Commodities up to 27 ft


None

Warehouse #1 Class IIIB Liquids up to 27 ft

Per NFPA 30, Table 16.5.2.5 Scheme A, the ceiling level protection is based on the other commodities in the rack/storage area; plus

need K=8.0 quick response in6rack sprinklers on the rack face and in the longitudinal flue, below horizontal barriers located no more

than 126ft apart vertically.

Need to add in6rack sprinklers to these racks

Warehouse #1 Class I, II and IIIA Liquids Per NFPA 30 §12.8 either: 1. Limit storage heights of the liquids to 5 ft

(Class I and II) and 10 ft (Class IIIA) and use protection appropriate for 20 ft high storage of Class IV commodities; or

2. For storage of the liquids up to 27 ft high, per NFPA 30 Table 16.5.2.7,

For either option, the existing ceiling sprinklers meet the

criteria. For option 2 (liquids stored up to 27 ft high) the potential in6rack scheme is shown in NFPA 30 Figures

16.6.2.1(a) – (c).

Mr. Mike Jennings

November 17, 2011


Area Primary Hazard Protection Requirement Actions Needed

provide ceiling sprinklers to protect the surrounding commodities and in6rack sprinklers per Design Scheme B

Warehouse #1 Class 2 and 3 Oxidizers up to 8 ft in pile storage

Per NFPA 400, Table 15.3.2.3.2.10(B), ceiling level protection of 0.20 gpm/ft2 over 3,750 ft2

is required for the Class 2 oxidizers Per NFPA 400 Table 15.3.2.4.12.1(B), ceiling level protection of 0.65 gpm/ft2 over 5,000 ft2

is required for the Class 3 oxidizers

The existing ESFR system is adequate. The actual

delivered density of the existing ESFR is

approximately 1.3 gpm/ft2 over the design area

(approximately 1,000 sq ft based on the 12 heads

calculated). The proposed storage of Class 2 and 3

oxidizers is up to six pallet loads, covering no more than 80 sq ft. The oxidizers will be separated from incompatible chemicals and combustible

products.

Warehouse #2 Class 1 Oxidizers in plastic pails up to 20 ft

Per NFPA 400 §15.3.2.2.3, this commodity is protected as a Class III commodity. See

protection for Class IV commodities above.

None

6.2.3 Summary of Changes Required to Existing Sprinkler System

1. The existing ceiling level protection provided in Warehouse #1, Warehouse #2, Area

#1 and Area #4 are appropriate for the proposed use.

2. Warehouse #1 requires addition of in@rack sprinklers to the racks designated for Class

IIIB liquids storage.

3. Area #1 requires addition of in@rack sprinklers per Figure 5.

4. Area #2 requires addition of in@rack sprinklers. The protection criteria for the ceiling

level sprinklers are not specified in typical ESFR sprinkler system terms, however

based on the actual amount of water required to be delivered it is proposed that the

existing ESFR system is adequate. The specified protection criteria are 0.20 gpm/ft2

over 3,750 ft2 plus the 500 gpm hose stream. Therefore, a gross estimate of how

much water is to be delivered (excluding in@rack sprinklers) is 1,250 gpm. The

existing K=14.0 ESFR system operating at 75 psi was calculated based on 12 heads

flowing and a hose stream allowance of 250 gpm. Therefore, a gross estimate of how

much water is to be delivered is 1,705 gpm.

5. Area #3 requires addition of in@rack sprinklers. The scenario for the protection

required from the ceiling level sprinklers is very similar to that for Area #2 as

described above and it is proposed that the existing ESFR system be retained as@is.

Mr. Mike Jennings

November 17, 2011


Action Item #2: Hydraulic calculations should be performed for potential

sprinkler system alterations to confirm the adequacy of the water supply and the

delivery of the specified water flow and density. This will also allow quantitative

evaluation of the question of the use of ESFR sprinklers in Areas 2 and 3.

6.3 Manual Fire Protection

In accordance with DFC §905.3 and NFPA 400, a standpipe system is not required to be

provided. As noted in section 6.2.1 above, the building is not currently provided with inside

hose stations. Therefore, manual fire protection will be provided by way of fire extinguishers.

See section 5.2.8 above for guidance on selection of fire extinguishers, especially for oxidizer

fires.

6.4 Fire Department Access

The building is provided with ample fire department vehicle access around the entire

perimeter and meets the criteria listed in DFC §503. Additionally access is provided via exterior

doors into the building every 100 lineal ft, in accordance with DFC §505 and 2306.6.1.

7 MEANS OF EGRESS

The following means of egress requirements are applicable, and are met by the current

proposed design:

1. At least two remote means of egress are required from each occupied space (DBC

§1019.1). The means of egress (including aisles) and exit doors must be maintained

clear, obvious and unobstructed.

2. The means of egress, including the exit discharge, shall be illuminated at all times the

building space served by the means of egress is occupied. An emergency electrical

system shall be provided for the means of egress illumination system, in accordance

with DBC §1006.

3. Internally or externally illuminated exit signs shall be distributed throughout the

facility, to meet the exit signage requirements of DBC §1011.

Action Item #3: The existing exit sign arrangement should be reviewed based on

the proposed storage arrangement in each space, in particular Warehouse #1.

4. The maximum travel distance is 300 ft for office areas; 250 ft for Warehouse #1 and

Warehouse #2; 175 ft for Area #4; and 150 ft for Areas #1, 2 and 3 (DBC §1016.1).

5. The maximum permissible common path of travel is 100 ft for Warehouse #1,

Warehouse #2 and Area #4; and 25 ft for Areas #1, 2 and 3 (DBC §1014.3).

Mr. Mike Jennings

November 17, 2011


6. The maximum permissible dead@end is 20 ft (DBC §1017.3).

7. Egress through an intervening room or space is permissible in a Group H or Group S

occupancy when the intervening space is the same or lesser hazard occupancy group

(DBC 1014.2, Exception). Therefore, it is permissible to egress from any of the

rooms within the cutoff storage area though Warehouse #1 or Warehouse #2, and it is

permissible to egress from any of the H@3 spaces through another H@3 space.

8 SUMMARY AND CONCLUSIONS

HAI has reviewed the proposed storage and use of the north suite at 5220 S. Westmoreland

Road in Dallas, TX as the new Leslie’s Pool Supplies Dallas Distribution Center. The proposed

design is compliant with the applicable code requirements. The following action items have

been identified and will be addressed as the design progresses:

1. It is recommended that a new flow test be conducted, if none has been done in the

past 12 months, to confirm that the water supply is substantially the same as the

design basis.

2. Hydraulic calculations should be performed for potential sprinkler system alterations

to confirm the adequacy of the water supply and the delivery of the specified water

flow and density. This will also allow quantitative evaluation of the question of the

use of ESFR sprinklers in Areas 2 and 3.

3. The existing exit sign arrangement should be reviewed based on the proposed storage

arrangement in each space, in particular Warehouse #1.

Please contact us with any questions or comments.

Yours truly, Reviewed by:

Alwin A. Kelly Steven E. Unger, P.E.

Senior Fire Protection Consultant Senior Fire Protection Engineer

Texas Professional Engineer License #86463

Texas Firm Registration #3944

11111111/17/2011/17/2011/17/2011/17/2011

November 17, 2011 Director, Safety and Regulatory Affairs...

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