Just browsing documentation can have me hitting that number of tabs easy. I tend to open stuff in new tabs so I can flip back and forth. Also if I'm searching for error messages I like to open in new tabs so I don't have to continuously go back and forth. I won't kill a tab until I know I'm done with it, I have a tab sleep extension to save resources for long idle tabs. Tab groups are a nice feature that I would love in Firefox to help clean things up, I tend to use new windows and virtual desktops to compartmentalise tasks.