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Mr. Jamie Johnson <br />Page Two <br />May 6, 1976 <br />when airflow across the burner drops below 50% of the rated CFM. This is <br />more than adequate to supply the required combustion air to the unit and <br />maintain a high rate of dilution of the products o` combustion downstream. <br />All air from the unit will be eventually exhausted to the outside in a safe <br />manner because of the natural exfiltration resulting from pressure differential <br />in the building. Without this exfiltration the static pressure buildup within the <br />building would result in loss of airflow through the unit and initiate a shutdown <br />due to the pressure differential switch. <br />Our interpretation of Section 1904(e) allows an electrical interlock on <br />the fan motor of the exhaust system to prevent the direct -fired unit from <br />operating when the exhaust system is off. <br />Item 3 <br />In reviewing the definition of "central heating plant" in the Uniform <br />Mechanical Code Section 405 and in the Uniform Building Code Section 404, <br />it appears to include make-up air heaters by lack of definition. It is my con- <br />tention, however, that it was not the intent of these definitions and Section <br />1108 of the U. B.C. or Section 704 of the U. M. C. to require one -hour <br />enclosure of make-up air heaters, especially where there is already installed <br />a separate "central heating plant" intended to heat the entire volume of the <br />building for comfort reasons. We would like to discuss the applicability of <br />this section with the Department, if the Department so agrees to allow a <br />temporary and conditional approval pending outcome of our discussions. <br />We are investigating the safety and practical aspects of downrating the <br />unit if code interpretations are not in support of our contention. If the agreed <br />interpretation of the intent of the code does not support our contention that the <br />applicability of Section 1108, requiring a one -hour fire -rated occupancy <br />separation, does not apply to direct -fired units then we will be prepared to <br />either 1) request a variance, 2) relocate the unit, or 3) de -rate the unit to <br />less than 400, 000 Btu per hour. <br />We would like to clarify the intent of the code along this line, not be- <br />cause of this single installation, but because of possible future installations <br />that will be made under the revision in the 1976 code, which removes occu- <br />pancy restrictions from direct -fired make-up air heaters. Your considera- <br />tion of this request would be very much appreciated and would assist us in <br />future planning and activities on such units. <br />If you can and do agree to permit a temporary gas turn -on and operation <br />of the unit pending our interpretative discussions, please advioe me and I will <br />