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Aug 2412 02:11 p 763-241-1266 p.4 <br /> Page 4 <br /> Both IFC and NFPA Code Standards were formulated by the experience and existence of the state <br /> of the industry and the technology of the equipment utilizing the solvents. <br /> The 100 year experience within the industry shows us that a drycleaning machine has in its process <br /> tanks(use)65 and 1000 gallons of liquid depending on the machines dry weight capacity. <br /> Additionally,the machine incorporates filters, spinning cycles,heating cycles by high pressure <br /> steam,and distillation units. Naturally,with this type of apparatus utilizing a Class IIIA liquid in <br /> its process,a keen focus on safety is paramount. <br /> The Columbia/ILSA company does indeed build machines as just mentioned; however,the TL HCS <br /> IPURA systems;development allows for the elimination of large volume process tanks,high <br /> pressure steam requirement, distillation requirement and high RPM spinning requirement. <br /> The TL HCS IPURA system holds less solvent than a typical standard automobile's fuel tank. This <br /> trivial amount can act as a method to;further reduced the level of control in the area. Never the <br /> less,IPURA still conforms with the current standards in IFC and NFPA. <br /> It should be noted that prior to the formation of IFC 2000,the 1997 Uniform Fire Code,Acticle 36, <br /> drycleaning allowed for exempted amounts set forth in Article 79 for quantities below 334 gallons <br /> in unsprinided control areas. <br /> We are uncertain as to why the exempted amount was later removed when UFC was meld in to IFC, <br /> nor has the IFC Committee substantiated its position in this particular change. <br /> In a recent Federal EPA final ruling affecting the drycleaning industry—U.S.Environmental <br /> Protection Agency,40 CFR Part 63 EPA-HQ-OAR-2005-0155,published date 7/14106, the <br /> department recognized the fire hazard association with Hydrocarbon solvent and cyclic siloxanes, <br /> and the technology of the equipment. (See attached EPA Page 91). <br /> With this submittal package we ask for a review of the equipment,and the application for permit to <br /> construct,with the requirement of automatic sprinklers to be set aside based on this information <br /> enclosed. <br /> If you have any questions or require more information please let us know directly. <br /> We respect the AJH's final decision and we thank you for the opportunity to present this <br /> documentation package. <br /> Respectfully, <br /> ILSA MACHINES CORP. <br /> Stephen Langiulli <br /> President <br /> And NFPA 32 Committeeperson <br />