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SCHIRMER ENGINEERING CORPORATION
350 INDIANA STREET, STE 500 A GOLDEN, COLORADO 80401 A PHONE(303)279-8900 A FAX(303)279-8905
TIRE MOUNTAIN, INC.
HUDSON, COLORADO
FIRE SAFETY EVALUATION
& FIRE CONTROL PLAN
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SEC Project No. 2403005-000
PREPARED FOR
J.A. Jerry Jamison, President
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Fire Protection Engineering ♦ Code Consulting A Loss Control ♦ Security Cr — —
2003-2659
TABLE OF CONTENTS
Introduction 1
Existing Facility 3
Current Code Requirements 7
Proposed Expansion 8
Below Grade Strategy of Storing Tires 8
Special Tire and Earth Moving Equipment is Available
On-Site 9
Limiting Fire to One Storage Cell 10
Adequate Local Supply of Earth & Fire Fighting Water . 10
Warning Indicators For Future Tire Pile Fires 11
Full Compliance with Findings of 1988 FP Report 12
Fire Control Plan 13
Environmental Hazard Containment 15
Safety of Operations 16
Conclusion 18
Recommendations 18
References 20
Appendix 21
Introduction
Schirmer Engineering Corporation (SEC) was retained to assist Tire Mountain
with an evaluation of the fire protection issues related to a proposed expansion of
the 120-acre outdoor storage facility in Hudson, Colorado. Our scope of work
involved reviewing current code requirements, validating the configuration of the
existing facility, conducting a physical survey of the facility and associated fire
protection features, developing a basic fire control plan and providing
recommendations as deemed necessary.
Tire Mountain is located eight miles northwest of Hudson, Colorado in a rural,
relatively unpopulated area. The primary business of Tire Mountain is to buy,
store and sell used tires. The existing facility consists of 45 tire storage areas
spread out over 80 acres. An office/maintenance building and several storage
lots are also located on the property. The proposed expansion area consists of
the remaining 40 acres, which is between the two existing, developed parcels.
Once this proposed expansion is complete, the site will be completely comprised,
except for office/maintenance building and general storage lots, of tire storage
pits (cells). As a result of the proposed expansion, the State of Colorado has
required an updated evaluation and fire control plan.
The 1988 High Country Engineering report sets precedence for the current
configuration and fire control plan. This report addressed three primary issues.
Report issues and recommendations are provided below. Secondary issues
include fire fighting procedures and fire prevention. All of these
recommendations were implemented after the 1988 report and are currently
being followed.
• The spacing of the cells used for tire storage with respect to adjoining
storage cells and the minimum required distance between cells to prevent
ignition of adjoining cells assuming a fire.
Recommendation — divide storage cells in half with a 50' wide earthen
barrier— recommended cells were to be 250'long x 102' wide. (cells were
originally proposed to be 500'in length and 102'feet wide)
• The need for separation/fire breaks within the individual cells to minimize
the likelihood of total involvement within a single cell and the spacing of
these fire breaks.
Recommendation — divide storage cells in half with a 50' wide earthen
barrier— recommended cells were to be 250'long x 102' wide. (cells were
originally proposed to be 500'in length and 102'feet wide)
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Tire Mountain April 28, 2003
Hudson, Colorado SEC Project No. 2403005-000
■ The proposed distance between the storage cells as they related to the
requirements for fire department operations and access.
Recommendation — 50' wide, unobstructed and able to support 50,000
pounds
• Fire fighting procedures.
Recommendation — bury the fire with dirt, maintain proper heavy
equipment locally, provide fire extinguishers and train employees and
ensure phone service is maintained for notification.
■ Facility Fire Prevention.
Recommendation — Control combustible storage, no vehicular storage in
tire storage areas, monitoring of site and designate a facility emergency
coordinator.
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Tire Mountain April 28, 2003
Hudson, Colorado SEC Project No. 2403005-000
Existing Facility
The Tire Mountain facility encompasses a total of 120 acres and is located
northwest of Hudson, Colorado. Access to the facility is via paved road (Weld
County Road #41). The local terrain within the facility is relatively flat with minor
elevation changes. The entire area is relatively void of trees and vegetation. In
addition, there are two gas wells located in the undeveloped area.
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Existing Ti• re Storage Cells
Proposed Expansion Area — Parcel "C"
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Tire Mountain April 28, 2003
Hudson, Colorado SEC Project No. 2403005-000
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Gas Well Head - 1 of 2 in Proposed Expansion Area
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Crude Oil (left) and Water Tank (right,at grade)
Two gas wells are located in the proposed expansion area. The wells are
accessed by an unimproved dirt road. These wells transport a mixture of natural
gas, oil and water to separation equipment and holding tanks on the east side of
the property adjacent to Weld County Road (WCR) #41. The transport piping
(-2") is normally maintained at -200 psi and is located —5 feet below current
grade. In the holding tank location on the east side of the property; the crude oil
is stored in an atmospheric tank (-10,000 gallon), the excess water is stored in
an atmospheric tank (-2000 gallon) at grade next to the crude oil tank and the
natural gas in routed directly back in an underground gas line along WCR #41.
4
Tire Mountain April 28, 2003
Hudson, Colorado SEC Project No. 2403005-000
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Office and Maintenance Facility
An approximate 15 acre section of the facility in the northeast corner is dedicated
to office area, equipment maintenance and storage, leased general storage,
leased vehicle storage and parking. The office area serves as the base of
operation for the facility and is manned by one full-time on-site employee who
manages the operation. The owner of the facility also assists the on-site
managers with operations at Tire Mountain.
Each existing tire storage area (cells) is 250 feet in length, 102 feet in width and
15 feet below surrounding grade. Tires are stacked 4-5 feet above grade in all
cells. A 50-foot physical separation is maintained between all cells, which
provides the fire exposure protection as well as heavy equipment and vehicular
access to each cell. The general dimensions of the existing cells were
determined by the 1988 Fire Protection Analysis performed by High Country
Engineering. The 1988 study was able to show that the radiant heat would not
be expected to ignite adjacent cells if a 50 foot separation (fire lane) was
maintained.
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Tire Mountain April 28, 2003
Hudson, Colorado SEC Project No. 2403005-000
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Existing, Partially Filled Cell — 102' wide x 250' long
Operations at Tire Mountain consist of transport and handling of all sizes and
types of tires. Tires are brought to site by various sizes of commercial trucks.
The tires are then off-loaded into designated areas near or in storage cells.
Front-end loaders then move/push the tires into the cells as best possible.
Finally, specialized excavators with hydraulic thumbs spread the tires out into the
cells until the approved configuration is attained.
Typically Tire Off-loading Operation — Large Straight Truck
Driving Away (on right) After Tire Drop-Off (on left)
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Tire Mountain April 28, 2003
• Hudson, Colorado SEC Project No. 2403005-000
Current Code Requirements
Although there are no dedicated codes related to outdoor tire storage, several
nationally recognized codes do provide guidance regarding outdoor storage of
scrap tires. National Fire Protection Association (NFPA) 230, Fire Protection of
Storage, 1999 and NFPA 231D, Storage of Rubber Tires, 1998, provide similar
applicable guidance in their appendices. In addition, there is good information on
tire fires available from the U.S. Fire Administration and numerous other sources.
These codes and guidelines provide guidance on:
• Fire experience
• Fire department access
• Site security
• Pre-incident planning
• Water supplies
• Pile geometry and spacing
• Fire fighting tactics and strategy
NFPA 231D and 230 recommend that cells be limited to 50 feet wide and 250
feet long and provide a table to set separation distances between piles. This
standard assumes that tires are stored above ground. The 1997 Uniform Fire
Code (UFC) requires at least a 40 foot separation between tire piles and no
storage within 10 feet of any property line. Any tire storage within 20 feet of a
property line shall be less than 6.feet in height. The UFC also restricts the area
of each tire pile to 5,000 square feet, <50,000 cubic feet and less than 10 feet in
height.
In the case of Tire Mountain, 75% of the tires are stored below grade with no tire
pile exceeding 4-5 feet above surrounding grade anywhere on site. The 1988,
High Country Engineering report, was able to show through engineering
calculations that cells could be wider (102') with little to no risk that a fire would
spread to an adjacent cell.
The proposed cells for Parcel "C" would be 102' wide x 305' long to increase
storage efficiency in the 660-foot wide section. Calculations performed for these
slightly longer cells indicate only a slightly higher radiant heat potential on any
adjacent cell, which is still well below the expected energy necessary to ignite
adjacent cells.
Additional discussion of the mitigating factors are provided in the next section —
Proposed Expansion.
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Tire Mountain April 28, 2003
Hudson, Colorado SEC Project No. 2403005-000
Proposed Expansion
Tire Mountain management has proposed to develop Parcel "C", which
encompasses approximately 40 acres. The expansion area is proposed to be
set-up similar to the existing facility. The cells will be the same width, but are
proposed to be slightly longer in order to maximize efficiency of the storage
arrangement. The additional length of each cell will be 55 feet. Therefore,
proposed cells will be 102 feet in width and 305 feet in distance. Each cell will be
approximately 15 feet in depth. This below ground configuration is desirable
since it minimizes the exposure risk of adjacent cells in a fire scenario (-75% of
tires, are below grade).
Since the current configuration is based on engineering analysis and does meet
applicable regulatory codes, we proposed using an equivalency approach based
on fire protection engineering calculations and other factors as discussed below.
In summary, we believe that this slightly increased cell length poses little to no
added fire risk to the facility. The following mitigating factors are provided for
consideration:
Below grade strategy of storing tires - although the code (NFPA 231D/230)
allows above ground storage of tires, Tire Mountain has decided to follow a more
conservative strategy of storing 75% of tires below grade.
■ This minimizes their exposure during a fire since there is less combustible
surface area exposed to adjacent cells. 75% of the tires are stored below
grade and, therefore, have no direct line-of-sight exposure to an adjacent
cell. Even if a cell was fully involved in a fire, the previous fire protection
(1988 High Country Engineering) evaluation indicated that ignition would
not be probable based on engineering calculations at a separation
distance of 50 feet.
■ Minimizes their exposure to lighting strikes by keeping the height of the
cells down and allows easier fire control and suppression operations.
• Maximizes visibility across site.
• Naturally contains any fire byproducts and fire fighting water.
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Tire Mountain April 28, 2003
Hudson, Colorado SEC Project No. 2403005-000
Special tire and earth moving equipment is available on site — Tire Mountain is a
full-time tire storage and management facility and has five full-time employees.
All employees and the owner are trained to operate all equipment. Most of the
heavy equipment on site has been specially modified for tire handling in
accordance with industry standards. A list of equipment on-site is provided
below. Additional equipment, as listed, is available from Platteville, which is
approximately 10 miles away from the site. Also, portable fire extinguishers are
kept on all equipment and telephone service is maintained at the site for prompt
reporting of any fires or emergency situations.
• 4 Yard 745 Fiat End Loader (on-site)
• 3 Yard John Deere 644 End Loader (on-site)
• 1 1/2 Yard Komatsu Hydraulic Excavator (on-site)
• 2 '/2 Yard Drott Excavator with Bucket (on-site)
• 8 Yard Terex Loader (local delivery, —1hour)
• 11 Yard John Deere Elevating Scraper
• D-7 Caterpillar Dozer (local delivery, --1 hour)
• D-8 Caterpillar Dozer (local delivery, —1 hour)
• 18 Yard Caterpillar Scraper (local delivery, -1 hour)
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Komatsu Hydraulic Excavator w/hydraulic thumb
9
Tire Mountain April 28, 2003
Hudson, Colorado SEC Project No. 2403005-000
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Komatsu Hydraulic Excavator— Track Modifications
Designed To Resist Tires Getting Caught.
Limiting Fire to One Storage Cell — According the 1988 High Country Engineering
report, the existing cells would produce no more than 7.22 kW/m2 on adjacent
storage cells. This calculation assumes that the facility maintains a clear 50-foot
fire lane between all cells.
The 1988 High Country Engineering report calculations were re-performed using
the larger proposed cell (102' x 305'). Results indicated that the increased
radiant energy that could be impinged on an adjacent cell could be as high as 8.7
kW/m2. The 1988 High Country Engineering report used 12.5 kW/m2 as a
benchmark, since this is the radiant heat required to ignite wood after prolonged
exposure. The radiant energy required to ignite whole tire is less than that for
wood based on ignition temperatures after prolonged exposure. Therefore, the
8.7 kW/m2 is still well below the expected radiant energy required to ignite tires
in an adjacent cell.
Adequate local supply of earth and fire fighting water — Fire fighting soil is
available from most all of the 50 foot fire lanes between each cell and other
designated areas on-site. Two agricultural wells provide fire fighting water and
are located on Weld County Road (WCR) #26 (0.8 miles away) and #24 (1.75
miles away). An on-site 2,200-gallon, underground water holding tank is also
available behind the office/maintenance building.
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Tire Mountain April 28, 2003
Hudson, Colorado SEC Project No. 2403005-000
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Agricultural Well on WCR #26
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2,200 Gallon Holding Tank On-Site
Warning Indicators for Future Tire Pile Fires — The US. Fire Administration has
identified warning indicators associated with tire fires. Only one of the warning
indicators identified by the U.S. Fire Administration is present (in bold),
minimizing the possibility of a fire at Tire Mountain.
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Tire Mountain April 28, 2003
Hudson, Colorado SEC Project No. 2403005-000
TABLE 1. WARNING INDICATORS FOR FUTURE TIRE PILE FIRES
• The tire operation changes from fire recycling to scrap-tire storage.
• The operation began as non-code-compliant.
• The state tire-fee-disposal program is not invoiced, and therefore not audited to
ensure proper tire disposal and ethical operations.
• The business owner resists compliance with code and fire safety practices.
• Business ownership changes.
• The business owner files for bankruptcy.
• The property owner and/or government pursue court action against the tire operation.
Full Compliance with Findings of 1988 Fire Protection Report—Tire Mountain
management implemented all recommended findings. PGFPD staff has
conducted detailed research on tire fires and related fire fighting strategy. In
addition, PGFPD has developed a comprehensive pre-plan for Tire Mountain.
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Tire Mountain April 28, 2003
• Hudson, Colorado SEC Project No. 2403005-000
Fire Control Plan
The Platteville/Gilcrest Fire Protection District (PGFPD) provides primary fire
protection to the Tire Mountain facility. PGFPD maintain two stations and has
available three full-time fire fighters and 60 volunteer, state certified fire fighters.
PGFPD was involved in fighting and suppressing the 1987 fire that consumed
over 2 million tires at Tire Mountain.
Per discussion with PGFPD, their initial response to a fire at Tire Mountain would
most likely involve three Class A pumpers (750 gpm) and two Water Tenders
(3,000 & 3,500 gallons). In addition, partly due to the 1987 fire, PGFPD has
conducted considerable time and effort into researching tire fires and detailing a
pre-plan for the current configuration at Tire Mountain.
Tire Mountain management/operators are trained to promptly report any fire prior
to initiating fire fighting/management operations. Normal telephone service is
maintained at the site. Cellular service is available in this area as well and most
employees carry cells phone in their equipment or on their person.
The primary objectives for fighting tire fires at Tire Mountain are prioritized:
Rescue/Evacuation
Exposure Protection
Confinement
Extinguishment
Overhaul
Rescue/Evacuation
A tire fire at Tire Mountain is not expected to involve life-threatening rescue
challenges. Some evacuation may be required, but the surrounding area is
mostly void of exposures and residences. The speed and direction of the wind
will influence the extent of evacuation, and these may change during the days
and weeks of fire operations. PGFPD officials will determine the extent of the
evacuation.
Exposures
The area around Tire Mountain is current rural and relatively void of exposures
and/or residences. Depending on wind direction, smoke from a fire may affect
visibility on the nearby main roadway (WCR #41)
During the initial stages of a fire, time should be spent separating unburned tire
exposures and/or berming up the earth around the fire area. Water should be
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Tire Mountain April 28, 2003
Hudson, Colorado SEC Project No. 2403005-000
used to keep unburned tires from burning rather than to extinguish the burning
tires. Also, calculations have shown that a single storage cell can be completely
consumed and not ignite nearby cells if proper separation distances are
maintained (50').
Containment
An earthen berm should then be built around the burning tire pile. Berms should
be at least one half the height of the tire pile, provided that the angle of repose of
the pile is not such that material from the top can tumble out of the confining
berm. With the berm complete, the tire fire should be considered contained and
extinguishment would become the main focus.
Extinguishment
There are several strategic considerations and tactical options with tire fire
extinguishment. PGFPD officials on-scene will have to decide the best strategy
given all variable and factors at that time. Although other options exist,
recommended options are as follows:
Burying the burning tires. Research and experience indicates that the most
effective means of managing a major tire fire may be by smothering the burning
material with dirt or fill. In addition, this strategy is in keeping with the 1988 High
Country Engineering report and PGFPD pre-planning. Though smothered, the
fire may continue to smolder for weeks or months and may break out into open
flaming periodically. Any flare-ups caused by settling and erosion should be
refilled with dirt.
Letting the fire burn. Although not recommended, this is an option for local and
state officials. Allowing the fire to burn minimizes the impact on air pollution
because the free-burning tire fire is in the equilibrium and pyrolysis phase and
will consume most of the fuel. Free burning, therefore, reduces toxic and
carcinogenic combustion emissions such as benzo (a) pyrene and benzene, as
well as toluene, chrysene, zinc oxide, titanium dioxide, carbon monoxide, sulfur
dioxide, and hydrogen sulfide.
Suppression by Water. Use of water should only be in support of the burying and
cooling operation. First, burning material should be pulled into small manageable
piles. Then the fire could be doused with hand-lines and a front-end loader could
be used to complete overhaul by moving the material to be submerged
(dumpster) or buried until cool. After the product is sufficiently cooled, the water
can be drained and the dumpster was trucked to the landfill.
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Tire Mountain April 28, 2003
Hudson, Colorado SEC Project No. 2403005-000
Overhaul. To ensure extinguishment, the burned tire product should be buried in
dirt or submerged until cooled below 200 F. Burned tires should be submerged in
construction dumpsters filled with water or in a three to four foot deep water
pond. Extinguished tire product should be submerged in the pond until cool, then
loaded into transport trucks with a front-end loader. Tires must be completely
extinguished before they can be transported to another site or landfill. If not
extinguished, the tire remains may re-ignite at another location.
Environmental Hazard Containment
Since the tires are stored in below grade cells, any run-off is expected to be
mostly contained in the cells. The use of water should be minimized since it may
cause overflow of containment ponds and/or increase the chances of
contaminating the soil or ground water below the cell (cells have no liners).
Water should only be used in conjunction with digging out the piles with,
extinguishing smaller piles and protecting unburned tires.
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Tire Mountain April 28, 2003
•
Hudson, Colorado SEC Project No. 2403005-000
Safety of Operations
PGFPD should assume the role of safety coordination for all the agencies
operating on the fire. This is notwithstanding the fact that all contract personnel,
as well as those operating under the control of other public agencies, should be
monitored by their respective employers. Safety responsibilities should be
handled per OSHA regulations, specifically 1910-120, paragraph Q.4,
"Hazardous Waste Operations and Emergency Response," and with EPA safety
regulations. NFPA 1500 standards also would apply. A designated PGFPD
safety officer should oversee the firefighting, burned product overhaul and
removal. The safety effort should be an around-the-clock operation and may
require shifts. However, to ensure accountability, shifts assigned for a fire may be
covered with 12-hour shifts on and 12-hour shifts off. Assistant safety officers
may be needed to oversee personnel rehabilitation and to provide documentation
of all personnel participating. They also would document injuries and subsequent
medical treatments that occur at the incident.
Fire ground security is necessary because day-to-day operations will involve
working with personnel who may not know one another. Security and safety may
be complicated if curiosity seekers and well-intentioned volunteers attempt to
enter the fire ground. Security should start with emphasis on requiring
identification of all personnel cleared to work at these fires. Also important is
personnel accountability, including accountability for non-fire-department
personnel such as heavy equipment operators and environmental waste
contractors.
All personnel operating in hazardous areas should have appropriate protective
equipment including SCBA, if indicated. Some non-fire personnel may need to
have personal protective fire equipment provided. The PGFPD incident
commander should assure that anyone with access to the site, including
contractors, are made aware of the applicable safety requirements. At a
minimum, the following steps should be taken:
1. Site briefing - All personnel entering the scene should be advised of the
conditions, inherent dangers, and potential risks. PGFPD safety procedures and
personnel accountability rules should be covered at the briefing.
2. Communications - It should be verified that equipment operators have or are
provided communications capabilities that are fully compatible with PGFPD and
other assisting agencies communications equipment.
3. Personal protection — Personal protective ensemble, including appropriate
respiratory equipment, should be ensured for all fire ground personnel. Those not
familiar with the use of respiratory equipment may need to be trained in how to
wear and use this equipment properly.
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Tire Mountain April 28, 2003
• Hudson, Colorado SEC Project No. 2403005-000
4. Supervision and monitoring — PGFPD should maintain close supervision of
contractor personnel during operations, and provide on-going environmental
monitoring.
Additional safety considerations include the following:
The heavy equipment operators are at greatest risk because they will be working
nearest to the fire. Those especially at risk include bulldozer operators moving
unburned tire product during the propagation phase of rapid-fire spread, and
operators who will be subject to fire flare-up when the burning tires are pulled
from the pile. A PGFPD Rapid Intervention Team (RIT) of fire personnel should
always be ready to move in with charged attack lines to protect or rescue heavy
equipment operators.
Heavy equipment should not be driven over burned piles. The center of these
piles can be likened to volcano lava, and is very unstable.
Flare-ups of fire can occur by re-ignition, in run-off oil, and by air reaching the
center of the pile when pulling up burning material. PGFPD suppression crews
with adequate hose lines must be available to extinguish small.
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Tire Mountain April 28, 2003
• Hudson, Colorado SEC Project No. 2403005-000
Conclusion
The proposed 40 acres expansion at Tire Mountain is considered an acceptable
arrangement, assuming that all the recommendations in this report and the 1988
report are followed. In addition, follow-up inspections should be conducted by
PGFPD to ensure that all recommendations are properly incorporated. Any
variance in the recommendations in this report should be discussed and agreed
to by PGFPD, State of Colorado representatives and Schirmer Engineering
Corporation.
Recommendations
1. Allow the expansion of the cell length in Parcel "C" to 305 feet in length as
shown on the attached drawings.
2. Maintain 50-foot fire lanes between all cells. Fire lanes shall be free of
tires, debris and vegetation at all times.
3. Maintain a 200-foot distance between cells and two gas wells and
associated storage tanks.
4. Ensure that proper pre-planning has been completed. Specifically, create
a scaled map that shows the site configuration, fire fighting soil location(s),
agricultural water well locations, buildings, utility shut-off for buildings, on-
site water holding tank location, gas well locations and underground piping
and other related emergency features. The map should also have all
contact information for the site, local authorities, owner,
employees/operators and resource listing (i.e., heavy equipment leasing,
fill dirt, gravel, food service, sanitation, nearby building that may be used
as a base of operations in a fire scenario, environmental contacts with
local university). This map and resource listing should be distributed to
state and local authorities with several copies kept on-site.
5. Identify the exact location of the underground gas line in Parcel "C". This
location should be coordinated with the construction of all new storage
cells in the parcel. Also, the area above the underground piping should be
signed to ensure no digging in the area. Also, provide concurrence from a
State of Colorado licensed civil engineer that heavy equipment will not
adversely affect the underground gas line (i.e, pipe may require sleeving,
etc.).
6. Ensure the following fire prevention items (i.e., fire extinguishers, level of
water holding tanks, fire extinguisher training of employees, etc.) are
formalized into an on-site, documented program (3 ring binder with
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Tire Mountain April 28, 2003
Hudson, Colorado SEC Project No. 2403005-000
records/documentation) that can be checked when State or local
authorities visit the facility.
7. The Platteville/Gilcrest Fire Protection District should review this report
provide general concurrence regarding the fire control plan and
recommendations.
8. Provide no smoking signage around the storage cells.
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Tire Mountain April 28, 2003
Hudson, Colorado SEC Project No. 2403005-000
References
1. Uniform Fire Code, 1997 Edition Produced by the ICBO (International
Conference of Building Officials)
2. National Fire Protection Association (NFPA) 230, Fire Protection of Storage,
Appendix G "Guidelines for the Outdoor Storage of Scrap Tires", 1999 Edition
3. National Fire Protection Association (NFPA) 231 D, Storage of Rubber Tires,
Appendix C "Guidelines for the Outdoor Storage of Scrap Tires", 1999 Edition
4. National Fire Protection Association (NFPA) 780, Standard for Lightning
Protection, 1999 Edition
5. Factory Mutual (FM) Guideline 8-3, "Rubber Tire Storage"
6. "Fire Protection Evaluation for Scrap Tire Landfill at Tire Mountain" Glen
Hoynoski, P.E. December 5, 1988
7. State of Colorado Department of Public Health and Environment, 6 CCR
1007-2, "Requirements for Scrap Tire Disposal"
8. United States Fire Administration, "Scrap and Shredded Tires, Report 093,
Stanley L. Poole, Jr., 1998.
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Tire Mountain April 28, 2003
Hudson, Colorado SEC Project No. 2403005-000
APPENDIX
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Parcel Identl lfret ten No. 121 000021
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