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Munitions Factory, H-2, requirements

ewenme

Sawhorse
Joined
Oct 27, 2009
Messages
306
Location
Troy, ID
A neighboring jurisdiction has asked for assistance from us [City] in the form of time from the Fire Marshal and myself to help him review proposals for a munitions factory. The structures: 7,000 operations building; two other buildings of indeterminate size as of yet for: smokeless powder, 500 pounds per magazine, two magazines per building; and then a storage building for finished product ready to ship [cartridges of a calibar unnamed]. The proposer claims Type 1.3C explosive on one page and then calls it 1.4 on the next. He cites codes which he claims alleviate the requirements for fire sprinklers.

So far, the only thing I can agree with is that if he has the separation distance he won't need barricades. He wants to use Type V-A construction. But in my reading he needs a 4-hour separation between magazines. I don't think Type V-A construction will comply with that.

Has anyone dealt with any wild requests like this? These people don't want to be bothered with life-safety issues. They are being asked to move from their "M" facility in another state. Here, they will be classified as H-2 at a minimum, and maybe H-1.

I'd like to hear from others who have dealt with similar situations.

Thanks in advance.:popcorn
 
I have worked as the fire marshal for a munitions factory.

First Question> is the property, buildings etc. owned or operated by the federal government?

Second Question> are the munitions for any branch or subset of the Department of Defense?

IF NOT the next steps will get very involved due to how munitions are manufactured and all of the pre-cursor materials involved. Small arms ammunition has some allowances that do not apply to the pre-cursor materials. Some H structures used for munitions fall into special categories and would not require sprinklers due to the interaction of water with the chemicals.
 
In Virginia it would be an F/S-1 but sprinklers and wood cabinets required.

From the 2009 Virginia Construction Code

Note that R-5 is IRC buildings.

CHAPTER 3

USE AND OCCUPANCY CLASSIFICATION

Change exception 13 of Section 307.1 of the IBC to read:

13. The storage of black powder, smokeless propellant and small arms primers in Groups M, R-3 and R-5 and special

industrial explosive devices in Groups B, F, M and S, provided such storage conforms to the quantity limits and

requirements prescribed in the International Fire Code, as amended in Section 307.9.

Add Section 307.9 to the IBC to read:

307.9 Amendments. The following changes shall be made to the International Fire Code for the use of Exception 13 in

Section 307.1:

1. Change Section 314.1 of the IFC to read as follows:

314.1 General. Indoor displays constructed within any building or structure shall comply with Sections 314.2

through 314.5.

2. Add new Section 314.5 to the IFC to read as follows:

314.5 Smokeless powder and small arms primers. Vendors shall not store, display or sell smokeless powder

or small arms primers during trade shows inside exhibition halls except as follows:

1. The amount of smokeless powder each vender may store is limited to the storage arrangements and

storage amounts established in Section 3306.5.2.1.

2. Smokeless powder shall remain in the manufacturer’s original sealed container and the container

shall remain sealed while inside the building. The repackaging of smokeless powder shall not be

performed inside the building. Damaged containers shall not be repackaged inside the building and

shall be immediately removed from the building in such manner to avoid spilling any powder.

3. There shall be at least 50 feet separation between vendors and 20 feet from any exit.

4. Small arms primers shall be displayed and stored in the manufacturer’s original packaging and in

accordance with the requirements of Section 3306.5.2.3.

3. Change Exception 4 and add Exceptions 10 and 11 to Section 3301.1 of the IFC as follows:

4. The possession, storage and use of not more than 15 pounds (6.75 kg) of commercially manufactured

sporting black powder, 20 pounds (9 kg) of smokeless powder and any amount of small arms primers for

hand loading of small arms ammunition for personal consumption.

10. The display of small arms primers in Group M when in the original manufacturer’s packaging.

11. The possession, storage and use of not more than 50 pounds (23 kg) of commercially manufactured

sporting black powder, 100 pounds (45 kg) of smokeless powder, and small arms primers for hand

loading of small arms ammunition for personal consumption in Group R-3 or R-5, or 200 pounds (91 kg)

of smokeless powder when stored in the manufacturer’s original containers in detached Group U

structures at least 10 feet (3048 mm) from inhabited buildings and are accessory to Group R-3 or R-5.

4. Change the definition of Smokeless Propellants in Section 3302.1 of the IFC as follows:

SMOKELESS PROPELLANTS. Solid propellants, commonly referred to as smokeless powders, or any

propellants classified by DOTn as smokeless propellants in accordance with NA3178 (Smokeless Powder for

Small Arms), used in small arms ammunition, firearms, cannons, rockets, propellant-actuated devices and

similar articles.

5. Change Section 3306.4 of the IFC to read as follows:

3306.4 Storage in residences. Propellants for personal use in quantities not exceeding 50 pounds (23 kg) of

black powder or 100 pounds (45 kg) of smokeless powder shall be stored in original containers in occupancies

limited to Group R-3 and R-5 or 200 pounds (91 kg) of smokeless powder when stored in the manufacturer’s

original containers in detached Group U structures at least 10 feet (3048 mm) from inhabited buildings and

are accessory to Group R-3 or R-5. In other than Group R-3 or R-5, smokeless powder in quantities exceeding

20 pounds (9 kg) but not exceeding 50 pounds (23 kg) shall be kept in a wooden box or cabinet having walls

of at least one inch (25 mm) nominal thickness or equivalent.

6. Delete Sections 3306.4.1 and 3306.4.2 of the IFC.

7. Change Section 3306.5.1.1 of the IFC to read as follows:

3306.5.1.1 Smokeless propellant. No more than 100 pounds (45 kg) of smokeless propellants in containers of

eight pounds (3.6 kg) or less capacity shall be displayed in Group M occupancies.

8. Delete Section 3306.5.1.3 of the IFC.

9. Change Section 3306.5.2.1 of the IFC as follows:

3306.5.2.1 Smokeless propellant. Commercial stocks of smokeless propellants shall be stored as follows:

1. Quantities exceeding 20 pounds (9 kg), but not exceeding 100 pounds (45 kg) shall be stored in

portable wooden boxes having walls of at least one inch (25 mm) nominal thickness or equivalent.

2. Quantities exceeding 100 pounds (45 kg), but not exceeding 800 pounds (363 kg), shall be stored in

storage cabinets having walls at least one inch (25 mm) nominal thickness or equivalent. Not more

than 400 pounds (182 kg) shall be stored in any one cabinet, and cabinets shall be separated by a

distance of at least 25 feet (7620 mm) or by a fire partition having a fire-resistance rating of at least

one hour.

3. Storage of quantities exceeding 800 pounds (363 kg), but not exceeding 5,000 pounds (2270 kg) in a

building shall comply with all of the following:

3.1. The storage is inaccessible to unauthorized personnel.

3.2. Smokeless propellant shall be stored in nonportable storage cabinets having wood walls at least

one inch (25 mm) nominal thickness or equivalent and having shelves with no more than 3 feet

(914 mm) of vertical separation between shelves.

3.3. No more than 400 pounds (182 kg) is stored in any one cabinet.

3.4. Cabinets shall be located against walls with at least 40 feet (12 192 mm) between cabinets. The

minimum required separation between cabinets may be reduced to 20 feet (6096 mm) provided

that barricades twice the height of the cabinets are attached to the wall, midway between each

cabinet. The barricades must extend a minimum of 10 feet (3048 mm) outward, be firmly

attached to the wall, and be constructed of steel not less than 0.25 inch thick (6.4 mm), 2-inch

(51 mm) nominal thickness wood, brick, or concrete block.

3.5. Smokeless propellant shall be separated from materials classified as combustible liquids,

flammable liquids, flammable solids, or oxidizing materials by a distance of 25 feet (7620 mm)

or by a fire partition having a fire-resistance rating of 1 hour.

3.6. The building shall be equipped throughout with an automatic sprinkler system installed in

accordance with Section 903.3.1.1.

4. Smokeless propellants not stored according to Item 1, 2, or 3 above shall be stored in a Type 2 or 4 magazine

in accordance with Section 3304 and NFPA 495.
 
V-A construction is a classification which allows any code approved material to be used.

There's no reason that a four hour separation cannot be provided within a building of that type.
 
I forgot to mention that they want to store 1,000,000 primers, also. Type V-A construction is also limited to 1 story and 7,000 sq. ft. This factory, because of the amount of explosives, etc. will definitely be an H-1 or H-2, not an F or S-1. They will be manufacturing bullets [cartridges] for small arms, but have not indicated the calibar. I do understand they could get a 4-hour wall with Type V-A construction, but at what cost to them? How many layers of drywall does it take to stop an explosion? They are proposing this use for a parcel of 600 acres, but have not indicated the distances from the buildings to highways, houses, etc. They have to get Conditional Use Permit for this application. They are proposing Type 2 or Type 4 magazines for storage of the 1.3C propellant/explosive. The Fire Marshal from the jurisdiction which they are vacating had issues with the 'we don't need fire sprinklers' attitude. Frankly, so do I.
 
Would suggest highly to the ahj

To require a technical report. Sounds like this needs it
 
I'm with cda. If there was ever a case for technical assistance, this would probably be it. From the 2009 IFC:

104.7.2 Technical assistance. To determine the acceptability of technologies, processes, products, facilities, materials and uses attending the design, operation or use of a building or premises subject to inspection by the fire code official, the fire code official is authorized to require the owner or agent to provide, without charge to the jurisdiction, a technical opinion and report. The opinion and report shall be prepared by a qualified engineer, specialist, laboratory or fire safety specialty organization acceptable to the fire code official and shall analyze the fire safety properties of the design, operation or use of the building or premises and the facilities and appurtenances situated thereon, to recommend necessary changes. The fire code official is authorized to require design submittals to be prepared by, and bear the stamp of, a registered design professional.
 
^Absolutely. You simply cannot approve this, regardless of how competent you are, without a third party, professional analysis.
 
Smokeless propellants will not explode unless confined.

Stored in the configurations shown in the VA regulations they are about the same fire hazard as your living room with stuffed furniture and a Christmas tree.

I served on the committee that wrote the Virginia regulations below--it was a compremise between some fire marshals that wanted to stick with the IFC regs and interests that wanted powder display and storage unregulated as a 2nd Ammendment right and had a bill in the legislature to that effect. Fortunately the VA legislature tends to bounce code issues back to the administrative process by passing bills that require a "study". Typically that is directive to come up with something that satisfies the various stakeholders.

The issue came up when our fire marshal was called to a local gunshow by concerned nearby vendors when a powder seller was smoking over spilled powder and then tried to enforce the fire code limits on powder quantities.

At the table there were fire marshals, building officials, state officials, powder manufacturers, NRA, cannon shooters, reenactors, handloaders, gun show promoters, sporting goods store owners, etc. The manufacturer's were able to provide right much material on tests done with smokeless propellent fires. The burns of pallet loads of smokeless powder were slower than a Christmas tree fire or a living room stuffed furniture group.

There were some interesting discussions at the table. The wood cabinets will slow the propellent fire down enough to let the sprinklers get ahead of it.

The cannon guys can burn through alot of powder fast.

I definately concur on the need for sprinklers.
 
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If you have not answered my first comments then you do not have the information necessary to make a decision. Secondly, if you do not know the maximum caliber then you can not use a small arms definition.

Sheet rock is considered to be an acceptable material for a frangable opening when working with explosives.

The manufacture of ammunition is somewhat covered by Chapter 33 of the IFC. AND I do mean somewhat.

The handling of propellants in the manufacturing process is much more involved then using a reloader, or storing some smokeless powder in a gun shop.

Propellants even classified as a 1.3C have a critical mass. That is the point when you move from deflagration to detonation. A material can be confined by its own mass.

Do you know what a card test is? IF not then someone with the specialized knowledge needs to conduct the analysis.
 
ewenme said:
I forgot to mention that they want to store 1,000,000 primers, also. Type V-A construction is also limited to 1 story and 7,000 sq. ft. This factory, because of the amount of explosives, etc. will definitely be an H-1 or H-2, not an F or S-1. They will be manufacturing bullets [cartridges] for small arms, but have not indicated the calibar. I do understand they could get a 4-hour wall with Type V-A construction, but at what cost to them? How many layers of drywall does it take to stop an explosion? They are proposing this use for a parcel of 600 acres, but have not indicated the distances from the buildings to highways, houses, etc. They have to get Conditional Use Permit for this application. They are proposing Type 2 or Type 4 magazines for storage of the 1.3C propellant/explosive. The Fire Marshal from the jurisdiction which they are vacating had issues with the 'we don't need fire sprinklers' attitude. Frankly, so do I.
Again, type V construction can be made out of anything allowed by code - a building which uses poured concrete walls, heavy timber, or titanium may be proposed as type V so long as it meets the height and area limitations for the occupancy.
 
I've emailed this thread to the AHJ and hopefully he'll get some good information here. Our own Fire Marshal suggested that no less than a report from a Fire Protection Engineer would be required. I think that will be the beginning. The fact that another jurisdiction 'asked them to relocate' should be a huge indicator of caution required. Thank you all for your comments. Until they get a Conditional Use Permit for this use in the Ag-Forest Zone, I think it's all rhetorical. For the Conditional Use Permit, I don't think the County will ask for too many details. They want to know the use, not the risks. Their Building Department will cover the risks and structural aspects.
 
You can use the CUP as a means to require things not spelled out in the code such as an FPE with x amount of years of experience designing such facilities in lieu of an FPE with little experience with this type of facility.
 
Trust me mtlogcabin, the Zoning Commission in the County won't do anything such like. They did, however, stop a farming/sustainable agriculture 'school' from starting. The group came back with a 'toned down' proposal to only use 28 of the 500 acres for the project. The Munitions factory is proposing its use on 600 acares. I could see the zoning commission cutting down the actual area of use to some more difinitive number like two acres or five maybe. The other conditions will depend upon who protests and opposes the project. The County will be requiring design by a Fire Protection Engineer. I doubt they'll care how much experience he has. The Fire Marshal will also be in contact with other FMs who do have experience. What a fun project!
 
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