Public Input No. 1-NFPA [ Global Input ] Additional Proposed Changes. Statement of Problem and Substantiation for Public Input

Transcription

1 of 39 7/15/2015 8:29 AM Public Input No. 1-NFPA [ Global Input ] NOTE: The following Public Input appeared as Rejected but held (Hold) in Public Comment No. 56PS-12 of the A2013 Second Draft Report (ROC) for NFPA 56 and per the Regs. at Additional Proposed Changes File Name 56PS-12.pdf Description Approved 56PS-12 Recommendation: Revise text to read as follows: A Inert Gas. Users should note that radioactive gases such as radon are not inert in the context of NFPA 56. Inert gases do not react readily with other materials under normal temperatures and pressures. For example, nitrogen combines with some of the more active metals such as lithium and magnesium to form nitrides, and at high temperatures it will also combine with hydrogen, oxygen, and other elements. The gases neon, krypton, and xenon are considered rare due to their scarcity. Although these gases are commonly referred to as inert gases, the formation of compounds is possible. For example, xenon combines with fluorine to form various fluorides and with oxygen to form oxides; the compounds formed are crystalline solids. [55, 2010] Substantiation: Radon is inert under the definition provided. However, it is radioactive and is therefore not considered inert for the purposes of NFPA 56. Submitter Full Name: TC on GPS-AAA Organization: TC on Gas Process Safety Submittal Date: Thu Feb 20 13:32:02 EST 2014 Resolution: FR-11-NFPA Statement: Updated the reference to most current edition. This included language that radon is an inert but should not be use.

2 of 39 7/15/2015 8:29 AM Public Input No. 10-NFPA [ Global Input ] Type your content here... As a member of the Gas Processors Association and an Operator/Designer of natural gas gathering/processing facilities, I would like to offer my support to the NFPA 56 Committee Task Force Report Assessment of Oil & Gas Industry issues including gathering lines as published by John Puskar. Specifically the exemption of gathering lines operated in compliance with PHMSA 49 cfr 191/192 (DOT 191/192) to NFPA 56 requirements. Additionally, I would like to recommend NFPA evaluate and accept the equivalency of PSM requirements found in 29 cfr as being compliant with NFPA 56 requirements. Scott A. Neil, PE Vice President Engineering and Tech Services Corporate Engineering/Chief Corporate Office SANeil@DCPMidstream.com Office: Mobile: See recommendation Submitter Full Name: Scott Neil Organization: DCP Midsteam LLC Submittal Date: Fri Oct 24 19:18:43 EDT 2014 Resolution: These are non-actionable items.

3 of 39 7/15/2015 8:29 AM Public Input No. 11-NFPA [ Global Input ] As a member of the Gas Processors Associa on and an Operator/Designer of natural gas gathering/processing facili es, I would like to offer my support to the NFPA 56 Commi ee Task Force Report, Assessment of Oil & Gas Industry Issues Including Gathering Lines, published by John Puskar. Specifically the exemp on of gathering lines operated in compliance with PHMSA 49 CFR 191/192 (DOT 191/192) to NFPA 56 requirements. Addi onally, I would like to recommend NFPA evaluate and accept the equivalency of PSM requirements found in 29 CFR Equivalency of PSM requirements found in 29 CFR Submitter Full Name: Justin Brady Organization: Chesapeake Energy Affilliation: GPA Submittal Date: Tue Dec 09 11:12:12 EST 2014 Resolution: These are non-actionable items.

4 of 39 7/15/2015 8:29 AM Public Input No. 2-NFPA [ Global Input ] NOTE: The following Public Input appeared as Rejected but held (Hold) in Public Comment No. 56PS-14 of the A2013 Second Draft Report (ROC) for NFPA 56 and per the Regs. at Additional Proposed Changes File Name 56PS-14.pdf Description Approved 56PS-14 Recommendation: Revise text to read as follows: A.6.1 Pipe cleaning methods and requirements change with the intent of the piping system. The most common cleaning methods for industrial natural gas piping systems, where it is required, is discharging or blowing the piping system down with compressed air. This blowing process is carefully managed and controlled. In other cases, possibly pharmaceutical and or food processing, liquid solvents may be used where the process requirements make this necessary. Substantiation: The committee added clarification on the possible use of solvents in applications particularly sensitive to the presence of impurities. Submitter Full Name: TC on GPS-AAA Organization: TC on Gas Process Safety Submittal Date: Thu Feb 20 13:34:33 EST 2014 Resolution: This content reflected paragraph

5 of 39 7/15/2015 8:29 AM Public Input No. 25-NFPA [ Global Input ] Type your content here... As a member of the Gas Processors Association and an Operator/Designer of natural gas gathering/processing facilities, I would like to offer my support to the NFPA 56 Committee Task Force Report, Assessment of Oil & Gas Industry Issues Including Gathering Lines, published by John Puskar. Specifically the exemption of gathering lines operated in compliance with PHMSA 49 CFR 191/192 (DOT 191/192) to NFPA 56 requirements. Additionally, I would like to recommend NFPA evaluate and accept the equivalency of PSM requirements found in 29 CFR As a member of the Gas Processors Association and an Operator/Designer of natural gas gathering/processing facilities, I would like to offer my support to the NFPA 56 Committee Task Force Report, Assessment of Oil & Gas Industry Issues Including Gathering Lines, published by John Puskar. Specifically the exemption of gathering lines operated in compliance with PHMSA 49 CFR 191/192 (DOT 191/192) to NFPA 56 requirements. Additionally, I would like to recommend NFPA evaluate and accept the equivalency of PSM requirements found in 29 CFR Submitter Full Name: Bruce Proctor Organization: Superior Pipeline Company Affilliation: supporting Gas Processors Association Submittal Date: Mon Jan 05 17:27:51 EST 2015 Resolution: These are non-actionable items.

6 of 39 7/15/2015 8:29 AM Public Input No. 12-NFPA [ Section No ] Nonapplication of Standard. This standard shall not apply to the following items: (10 * ) Systems regulated by U.S. Department of Transportation (DOT) 49 CFR 191/192 and technically equivalent gathering lines. (1) * Piping systems covered by NFPA 2, Hydrogen Technologies Code (2) * Piping systems covered by NFPA 51, Standard for the Design and Installation of Oxygen Fuel Gas Systems for Welding, Cutting, and Allied Processes (3) * Piping systems covered by NFPA 51A, Standard for Acetylene Cylinder Charging Plants (4) Fuel-dispensing facilities covered by NFPA 52, Vehicular Gaseous Fuel Systems Code. (5) * Piping systems covered by NFPA 54, National Fuel Gas Code (6) * Piping systems covered by NFPA 55, Compressed Gases and Cryogenic Fluids Code (7) * Piping systems covered by NFPA 58, Liquefied Petroleum Gas Code (8) * LP-Gas (including refrigerated storage) at utility gas plants (seenfpa 59, Utility LP-Gas Plant Code ) (9) * LNG facilities covered by NFPA 59A, Standard for the Production, Storage, and Handling of Liquefied Natural Gas (LNG) (10)* Vehicle fuel dispensers (11) Commissioning and maintenance of equipment (12) Vent lines from pressure relief valves or devices unless such vent lines are also used for purging of flammable gas piping systems (13) * Systems regulated by U.S. Department of Transportation (DOT) 49 CFR This is the result of a task force lead by John Puskar and Scott Neil. A complete report from the task force has been submitted to the committee chair regarding this submission. Submitter Full Name: John Puskar Organization: Prescient Technical Services LLC Submittal Date: Thu Jan 01 18:40:35 EST 2015 Resolution: FR-20-NFPA Statement: Clarify that gathering lines and upstream piping are not in the scope of this document.

7 of 39 7/15/2015 8:29 AM Public Input No. 13-NFPA [ Section No ] Nonapplication of Standard. This standard shall not apply to the following items: (1) (2) * * Piping systems covered by NFPA 2, Hydrogen Technologies Code Piping systems covered by NFPA 51, Standard for the Design and Installation of Oxygen Fuel Gas Systems for Welding, Cutting, and Allied Processes (3) * Piping systems covered by NFPA 51A, Standard for Acetylene Cylinder Charging Plants (4) Fuel-dispensing facilities covered by NFPA 52, Vehicular Gaseous Fuel Systems Code. (5) (6) (7) (8) * * * * Piping systems covered by NFPA 54, National Fuel Gas Code Piping systems covered by NFPA 55, Compressed Gases and Cryogenic Fluids Code Piping systems covered by NFPA 58, Liquefied Petroleum Gas Code LP-Gas (including refrigerated storage) at utility gas plants (see NFPA 59, Utility LP-Gas Plant Code ) (9) * LNG facilities covered by NFPA 59A, Standard for the Production, Storage, and Handling of Liquefied Natural Gas (LNG) (10)* Vehicle fuel dispensers (11) Commissioning and maintenance of equipment (12) Vent lines from pressure relief valves or devices unless such vent lines are also used for purging of flammable gas piping systems (13) (10 * ) Systems regulated by U.S. Department of Transportation (DOT) 49 CFR (1) 191/192 and technically equivalent gathering lines, distribution, and or transmission lines. This modification would include deleting sections and Sections and discuss the possibility of a plant being owned by a serving gas utility. It s not clear what a plant is. I believe it was meant to indicate electrical generating plant. However, there is no definition for plant. In my opinion, this is an exemption. First of all, exemptions should not be addressed in the body of the document. Section Non-application of standard is the place for this. This entire matter is very parallel to the entire discussion regarding the midstream gas processing industry and the task for work related to it. In fact it s the same issue. In effect the midstream task force work says many gathering lines are technically equivalent to DOT regulated lines and therefore the DOT practices related to purging and safe piping processes should apply. This is the same issue with segments of distribution piping and transmission piping that consist of largely underground sections that might be somewhat long and have few isolation valves. In these cases DOT practices address creating a plan for doing this kind of work. If NFPA 56 does not fit well for these kinds of systems and DOT does then why not require it instead of abdicating to some unknown set of practices that some gas utilities have or do not have? It makes no sense. Hence, this submission slightly changes the original task force for midstream piping systems and by doing so eliminates the need to exempt gas utilities, (7.1.2 and 8.2.1) later in the document.

8 of 39 7/15/2015 8:29 AM Submitter Full Name: John Puskar Organization: PuskarCo Submittal Date: Thu Jan 01 18:43:51 EST 2015 Resolution: FR-20-NFPA Statement: Clarify that gathering lines and upstream piping are not in the scope of this document.

9 of 39 7/15/2015 8:29 AM Public Input No. 17-NFPA [ Section No. 2.2 ] 2.2 NFPA Publications. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA NFPA 2, Hydrogen Technologies Code, 2011 edition. NFPA 30, Flammable and Combustible Liquids Code, 2012 edition. NFPA 31, Standard for the Installation of Oil-Burning Equipment, 2011 edition. NFPA 51, Standard for the Design and Installation of Oxygen Fuel Gas Systems for Welding, Cutting, and Allied Processes, 2013 edition. NFPA 51A, Standard for Acetylene Cylinder Charging Plants, 2012 edition. NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, 2014 edition. NFPA 52, Vehicular Gaseous Fuel Systems Code, 2013 edition. NFPA 54, National Fuel Gas Code, 2012 edition. NFPA 55, Compressed Gases and Cryogenic Fluids Code, 2013 edition. NFPA 58, Liquefied Petroleum Gas Code, 2014 edition. NFPA 59, Utility LP-Gas Plant Code, 2012 edition. NFPA 59A, Standard for the Production, Storage, and Handling of Liquefied Natural Gas (LNG), 2013 edition. NFPA 69, Standard on Explosion Prevention Systems, 2008 edition. NFPA 70, National Electrical Code, 2014 edition. NFPA 2112 NFPA 2113 NFPA 2112 and 2113 were added as part of previous public comments for chapter 4, these are related to flame resistant clothing. Submitter Full Name: John Puskar Organization: PuskarCo Submittal Date: Thu Jan 01 19:27:57 EST 2015 Resolution: FR-5-NFPA FR-4-NFPA Statement: NFPA 2113 was added due to its inclusion in FR-4.

10 0 of 39 7/15/2015 8:29 AM Public Input No. 4-NFPA [ Section No ] ASME Publications. American Society of Mechanical Engineers ASME International, Three Park Avenue, New York, NY ASME B31.1, Power Piping, ASME B31.3, Process Piping, ASME B31.12, Hydrogen Piping and Pipelines, Referenced current editions. Related Public Inputs for This Document Related Input Public Input No. 5-NFPA [Chapter D] Relationship Submitter Full Name: Aaron Adamczyk Organization: [ Not Specified ] Submittal Date: Mon Jun 16 17:19:55 EDT 2014 Resolution: FR-1-NFPA Statement: Referenced current editions.

11 1 of 39 7/15/2015 8:29 AM Public Input No. 18-NFPA [ Section No. 2.4 ] 2.4 References for Extracts in Mandatory Sections. NFPA 54, National Fuel Gas Code, 2012 edition. NFPA 55, Compressed Gases and Cryogenic Fluids Code, 2013 edition. API RP 99 (2014), Flash Fire Risk Assessment for the Upstream Oil and Gas Industry The definition for flash fire was extracted from API RP 99. If it's easier this may also be in NFPA 2113, I did not have a chance to look. Submitter Full Name: John Puskar Organization: PuskarCo Submittal Date: Thu Jan 01 19:29:44 EST 2015 Resolution: As a result of resolving PI-19, this references is not needed.

12 2 of 39 7/15/2015 8:29 AM Public Input No. 15-NFPA [ New Section after 3.2 ] isolation Isolations of piping systems shall be such that a complete and positive zero energy state is achieved. This zero energy state shall be verified and document making sure that closed valves are leak free. Acceptable methods of verifying complete and positive isolation include double block and bleed with a monitored bleed vent, disconnection and capping, or the installation of blinds between flanges. Isolation is used in the document but it is not clear what is meant. In some cases practioners can be lead to believe this simply means closing a valve. This can be very dangerous. We should be more clear and explicit regarding the extent of isolation intended and validation of the isolation. Submitter Full Name: John Puskar Organization: PuskarCo Submittal Date: Thu Jan 01 19:19:24 EST 2015 Resolution: CI-7-NFPA Statement: The committee has formed a task group to look at the inclusion of isolation in the document.

13 3 of 39 7/15/2015 8:29 AM Public Input No. 19-NFPA [ New Section after 3.3 ] Flash Fire Flash Fire : A fire that spreads rapidly by means of a brief flame front through a diffuse fuel such as gas or the vapors of an ignitable liquid, without the production of a damaging pressure. {API RP 99, section 2.1.6, 2014} The concept of flash fire is an important one for this topic. I have also used the term in one of the public comments added related to nfpa 2112 and 2113 Submitter Full Name: John Puskar Organization: PuskarCo Submittal Date: Thu Jan 01 19:31:48 EST 2015 Resolution: USed definition from 921, see FR-#.

14 4 of 39 7/15/2015 8:29 AM Public Input No. 6-NFPA [ New Section after ] (7) Protection and Rescue of Personnel (a) Training requirements for personnel involved in the work efforts (b) Personal protective equipment including possible need for flame resistant clothing (FRC) and flash fire protection as per NFPA 2112 and NFPA (c) Rescue equipment including self contained breathing apparatus and breathing air escape packs (d) Standby rescue personnel (e) Primary and secondary muster areas (f) Assignment of personnel for alerting and accounting of personnel duties The document previously did not address matters related to protection personnel or their possible rescue. The document also did not address the term flash fire, or flame resistant clothing. This section raises the awareness level of users to all of these issues. Submitter Full Name: John Puskar Organization: Prescient Technical Services LLC. Submittal Date: Mon Oct 20 22:43:33 EDT 2014 Resolution: FR-4-NFPA Statement: Made editorial revisions for clarity. While the current text highlights control of static electricity at the discharge point, the inclusion of non-conductive components within a temporary piping system used for venting and purging can induce static charges that may not be accounted for if the focus is limited to the discharge point. Although primarily directed at non-conductive liquids, NFPA 77 provides the essential basis for control of this hazard and, while it is generically referenced in the annex for Section 4.4.1(4)(a), drawing the user to the specifics of Section 10.3 in NFPA 77 will promote a proper review of this detail. API RP 2003 provides a full discussion of protections for static electricity and can be of assistance in evaluating the risks from static electricity. Reorganized and updated to raise the awareness level of users to these issues.

15 5 of 39 7/15/2015 8:29 AM Public Input No. 16-NFPA [ Section No ]

16 6 of 39 7/15/2015 8:29 AM *

17 7 of 39 7/15/2015 8:29 AM The written procedure for each cleaning and purging activity shall address, as a minimum, the following items: replace item (m) below with the following: Evaluate engineering controls that allow excess gas from depressuriation to be consumed in a controlled manner instead of vented, (i.e. flaring or controlled combustion in process equipment to as low a pressure as safely possible). (1) Scope of work and site-specific purge procedure development (2) Cleaning and purging method (3) Piping and instrument diagrams (PIDs) (4) Chemical and physical properties of flammable gas, cleaning media, purge media, and discharge gas (5) Determination of purge end point introducing flammable gas, inert gas, or air (6) Assessment and control of purge inlet and discharge locations (7) * Mitigation or capture strategies (8) Temporary piping system design (9) Personal protective equipment (PPE) (10) Training and qualifications (11) Management review and approval (12) Restoration of service (13) Target design, launcher/receiver venting review for pigging operations (14) Regulatory permits (15) Evaluation of engineering controls to limit potential unintended ignition of gases (controlled oxidation, flaring ) (a) that allow excess gases to be consumed in some safe manner that limits the amount of gas to be vented from depressurization processes, (i.e. flaring or controlled oxidation in equipment). (b) Written stand-down instructions to stop activity in a controlled manner (c) * Precautions for gases that have toxic, highly toxic, unstable reactive, corrosive, or other deleterious properties beyond flammability (16)* Environmental conditions and work locations (17) Establishment and clear identification of exclusion zones where flammable gas air mixtures are likely to exist (18) Limited access for personnel not directly involved with purge operations (19) Assessment of potential for gas migration (building openings, adjacent structures) (20) Prohibition of hot work within exclusion zones (21) Lockout/tagout (22) Impact of environmental conditions (wind speed and direction, temperature, barometric pressure) on purge operations (23) Vehicular and air traffic, if applicable (24) Topography (25) Noise control/monitoring (26) Communication plans (27) Pre-job briefings

18 8 of 39 7/15/2015 8:29 AM (28) Work permits (29) Roles and responsibilities (30) Emergency response plan (31) Facility alarm, alert and warning systems (32) General facility notification prior to start of purge operations (33) General facility notification at the conclusion of purge operations (34) Notification of regulatory authorities as required (local emergency responders, utility operators, community officials, environmental authorities, etc.) (35) Control of ignition sources (36) * Bonding and grounding considerations (37) No smoking or spark-producing work within exclusion zones (38) Elimination of hot work within exclusion zone (39) Static electricity ignition sources at discharge point (40) Pre-purge piping system assessment (41) Assessment of piping system for trapped liquids, pyrophoric solids, and other flammable or combustible deposits within the piping system (42) Ensuring that the piping system is properly isolated (43) Limiting site conditions that impact the safety of the activity (44)* Purge monitoring and instrumentation (45) (46) (47) (48) (49) (50) Ensuring that monitoring instruments are appropriate for gas being purged Training Calibration Monitoring frequency and reporting Appropriate selection of sample point(s) General atmosphere checks in vicinity of purge gas release The way item (m) is currently stated is confusing, the intent is not clear. Submitter Full Name: John Puskar Organization: PuskarCo Submittal Date: Thu Jan 01 19:22:00 EST 2015

19 9 of 39 7/15/2015 8:29 AM Resolution: FR-4-NFPA Statement: Made editorial revisions for clarity. While the current text highlights control of static electricity at the discharge point, the inclusion of non-conductive components within a temporary piping system used for venting and purging can induce static charges that may not be accounted for if the focus is limited to the discharge point. Although primarily directed at non-conductive liquids, NFPA 77 provides the essential basis for control of this hazard and, while it is generically referenced in the annex for Section 4.4.1(4)(a), drawing the user to the specifics of Section 10.3 in NFPA 77 will promote a proper review of this detail. API RP 2003 provides a full discussion of protections for static electricity and can be of assistance in evaluating the risks from static electricity. Reorganized and updated to raise the awareness level of users to these issues.

20 0 of 39 7/15/2015 8:29 AM Public Input No. 23-NFPA [ Section No ]

21 1 of 39 7/15/2015 8:29 AM *

22 2 of 39 7/15/2015 8:29 AM The written procedure for each cleaning and purging activity shall address, as a minimum, the following items: (1) Scope of work and site-specific purge procedure development (2) Cleaning and purging method (3) Piping and instrument diagrams (PIDs) (4) Chemical and physical properties of flammable gas, cleaning media, purge media, and discharge gas (5) Determination of purge end point introducing flammable gas, inert gas, or air (6) Assessment and control of purge inlet and discharge locations (7) * Mitigation or capture strategies (8) Temporary piping system design (9) Personal protective equipment (PPE) (10) Training and qualifications (11) Management review and approval (12) Restoration of service (13) Target design, launcher/receiver venting review for pigging operations (14) Regulatory permits (15) Evaluation of engineering controls to limit potential unintended ignition of gases (controlled oxidation, flaring ) (16) Written stand-down instructions to stop activity in a controlled manner (17) * Precautions for gases that have toxic, highly toxic, unstable reactive, corrosive, or other deleterious properties beyond flammability (18)* Environmental conditions and work locations (19) Establishment and clear identification of exclusion zones where flammable gas air mixtures are likely to exist (20) Limited access for personnel not directly involved with purge operations (21) Assessment of potential for gas migration (building openings, adjacent structures) (22) Prohibition of hot work within exclusion zones (23) Lockout/tagout (24) Impact of environmental conditions (wind speed and direction, temperature, barometric pressure) on purge operations (25) Vehicular and air traffic, if applicable (26) Topography (27) Noise control/monitoring (28) Communication plans (29) Pre-job briefings (30) Work permits (31) Roles and responsibilities (32) Emergency response plan (33) Facility alarm, alert and warning systems (34) General facility notification prior to start of purge operations

23 3 of 39 7/15/2015 8:29 AM (35) General facility notification at the conclusion of purge operations (36) Notification of regulatory authorities as required (local emergency responders, utility operators, community officials, environmental authorities, etc.) (37) Control of ignition sources (38) * Bonding and grounding considerations (39) No smoking or spark-producing work within exclusion zones (40) Elimination of hot work within exclusion zone (41) Static electricity ignition sources at discharge point (42) Non-conductive piping, hose or fittings in temporary piping assemblies (43) Pre-purge piping system assessment (44) Assessment of piping system for trapped liquids, pyrophoric solids, and other flammable or combustible deposits within the piping system (45) Ensuring that the piping system is properly isolated (46) Limiting site conditions that impact the safety of the activity (47)* Purge monitoring and instrumentation (48) (49) (50) (51) (52) (53) Ensuring that monitoring instruments are appropriate for gas being purged Training Calibration Monitoring frequency and reporting Appropriate selection of sample point(s) General atmosphere checks in vicinity of purge gas release While the current text highlights control of static electricity at the discharge point, the inclusion of non-conductive components within a temporary piping system used for venting and purging can induce static charges that may not be accounted for if the focus is limited to the discharge point. Proper bonding of the conductive portions of the assembly on both sides of the non-conductive portions is essential to proper control of static electricity and treatment of only the discharge point may not be sufficient for complete control of the hazard. Although primarily directed at non-conductive liquids, NFPA 77 provides the essential basis for control of this hazard and, while it is generically referenced in the annex for Section 4.4.1(4)(a), drawing the user to the specifics of Section 10.3 in NFPA 77 will promote a proper review of this detail. API RP 2003 provides a full discussion of protections for static electricity and can be of assistance in evaluating the risks from static electricity. For the purposes of NFPA 56, substitution of the term fluid for liquid in the extracted text assists the user in making the connection to the subject of gas purging as discussed in NFPA 56. Additionally, the term hose is appended to state hose[s] in recognition that multiple flexible sections may be used to route temporary vent piping. Related Public Inputs for This Document Related Input Public Input No. 24-NFPA [New Section after A.4.4.1(4)(a)] Relationship Annex material associated with this proposal

24 4 of 39 7/15/2015 8:29 AM Submitter Full Name: Lawrence Danner Organization: GE Power & Water Submittal Date: Mon Jan 05 07:07:15 EST 2015 Resolution: FR-4-NFPA Statement: Made editorial revisions for clarity. While the current text highlights control of static electricity at the discharge point, the inclusion of non-conductive components within a temporary piping system used for venting and purging can induce static charges that may not be accounted for if the focus is limited to the discharge point. Although primarily directed at non-conductive liquids, NFPA 77 provides the essential basis for control of this hazard and, while it is generically referenced in the annex for Section 4.4.1(4)(a), drawing the user to the specifics of Section 10.3 in NFPA 77 will promote a proper review of this detail. API RP 2003 provides a full discussion of protections for static electricity and can be of assistance in evaluating the risks from static electricity. Reorganized and updated to raise the awareness level of users to these issues.

25 5 of 39 7/15/2015 8:29 AM Public Input No. 7-NFPA [ Section No ]

26 6 of 39 7/15/2015 8:29 AM 4.4.1*

27 7 of 39 7/15/2015 8:29 AM The written procedure for each cleaning and purging activity shall address, as a minimum, the following items: (1) Scope of work and site-specific purge procedure development (2) Cleaning and purging method (3) Piping and instrument diagrams (PIDs) (4) Chemical and physical properties of flammable gas, cleaning media, purge media, and discharge gas (5) Determination of purge end point introducing flammable gas, inert gas, or air (6) Assessment and control of purge inlet and discharge locations (7) * Mitigation or capture strategies (8) Temporary piping system design (9) Personal protective equipment (PPE) (10) Training and qualifications (a) Management review and approval (b) Restoration of service (c) Target design, launcher/receiver venting review for pigging operations (d) Regulatory permits (e) Evaluation of engineering controls to limit potential unintended ignition of gases (controlled oxidation, flaring ) (f) Written stand-down instructions to stop activity in a controlled manner (g) * Precautions for gases that have toxic, highly toxic, unstable reactive, corrosive, or other deleterious properties beyond flammability (h) (i) (j) (k) (l) Locations of nearby residences, schools, churches, roads, medical facilities, and parks Evacuation routes and road block locations On-site and or classroom table top drills of emergency drills Qualifications of personnel Hazards (11)* Environmental conditions and work locations (12) Establishment and clear identification of exclusion zones where flammable gas air mixtures are likely to exist (13) Limited access for personnel not directly involved with purge operations (14) Assessment of potential for gas migration (building openings, adjacent structures) (15) Prohibition of hot work within exclusion zones (16) Lockout/tagout (17) Impact of environmental conditions (wind speed and direction, temperature, barometric pressure) on purge operations (18) Vehicular and air traffic, if applicable (19) Topography (20) Noise control/monitoring (21) Communication plans (22) Pre-job briefings

28 8 of 39 7/15/2015 8:29 AM (23) Work permits (24) Roles and responsibilities (25) Emergency response plan (26) Facility alarm, alert and warning systems (27) General facility notification prior to start of purge operations (28) General facility notification at the conclusion of purge operations (29) Notification of regulatory authorities as required (local emergency responders, utility operators, community officials, environmental authorities, etc.) (30) Emergency phone list including: emergency services, ambulances, hospitals, air rescue (helicopter services), local emergency planning committee, state response center, national response center, state and local law enforcement, fire departments, operators and contractors, gas supplier including distribution emergency personnel, emergency leak repair and valve service contractors. (31) Control of ignition sources (32) * Bonding and grounding considerations (33) No smoking or spark-producing work within exclusion zones (34) Elimination of hot work within exclusion zone (35) Static electricity ignition sources at discharge point (36) Pre-purge piping system assessment (37) Assessment of piping system for trapped liquids, pyrophoric solids, and other flammable or combustible deposits within the piping system (38) Ensuring that the piping system is properly isolated (39) Limiting site conditions that impact the safety of the activity (40)* Purge monitoring and instrumentation (41) (42) (43) (44) (45) (46) Ensuring that monitoring instruments are appropriate for gas being purged Training Calibration Monitoring frequency and reporting Appropriate selection of sample point(s) General atmosphere checks in vicinity of purge gas release Enhancement of considerations for preparing a more complete and effective work plan. Removed personnel protective equipment and training from section 1), added them to section 7, protection and rescue of personnel. Added mitigation or capture strategies Added sections n) through r) Added section 3 i) Submitter Full Name: John Puskar

29 9 of 39 7/15/2015 8:29 AM Organization: prescient Technical Services LLC. Submittal Date: Mon Oct 20 22:48:39 EDT 2014 Resolution: FR-4-NFPA Statement: Made editorial revisions for clarity. While the current text highlights control of static electricity at the discharge point, the inclusion of non-conductive components within a temporary piping system used for venting and purging can induce static charges that may not be accounted for if the focus is limited to the discharge point. Although primarily directed at non-conductive liquids, NFPA 77 provides the essential basis for control of this hazard and, while it is generically referenced in the annex for Section 4.4.1(4)(a), drawing the user to the specifics of Section 10.3 in NFPA 77 will promote a proper review of this detail. API RP 2003 provides a full discussion of protections for static electricity and can be of assistance in evaluating the risks from static electricity. Reorganized and updated to raise the awareness level of users to these issues.

30 0 of 39 7/15/2015 8:29 AM Public Input No. 8-NFPA [ Section No. 5.1 [Excluding any Sub-Sections] ] Persons whose duties fall within the scope of this standard shall be provided with training that is consistent with the scope of their job activities and assigned tasks for the cleaning or purging work to be performed. Evidence of knowledge transfer shall be included as part of the training program. Explicitly stating what the training is to be about. Nothing currently speaks to the need to validate knowledge transfer. Submitter Full Name: John Puskar Organization: Prescient Technical Services LLC Submittal Date: Mon Oct 20 23:07:13 EDT 2014 Resolution: FR-12-NFPA Statement: Language added to help insure knowledge transfer is effective.

31 1 of 39 7/15/2015 8:29 AM Public Input No. 9-NFPA [ Section No ] Training records including dates of training, name of instructor (s), content or curriculum covered, and evidence of knowledge transfer shall be maintained for a period not less than 5 years from the date of completion of the activity. We ask for training records to be maintained but we never explain what we mean by this. It is hoped this clears that up. Submitter Full Name: John Puskar Organization: Prescient Technical Services LLC Submittal Date: Mon Oct 20 23:08:53 EDT 2014 Resolution: FR-13-NFPA Statement: Clarification to what records must be maintained.

32 2 of 39 7/15/2015 8:29 AM Public Input No. 20-NFPA [ Section No ] It is proposed that these be deleted, in favor of submission #13's concept and language * If the plant is owned or operated by the serving natural gas supplier, natural gas piping between the point of delivery or source valve and the plant shall be permitted to be purged into service in accordance with the serving natural gas supplier s written procedures The natural gas supplier s written procedures shall include a safety validation in accordance with Section The natural gas supplier s written procedures and process shall be coordinated with the plant operational personnel. Sections and discuss the possibility of a plant being owned by a serving gas utility. It s not clear what a plant is. I believe it was meant to indicate electrical generating plant. However, there is no definition for plant. In my opinion, this is an exemption. First of all, exemptions should not be addressed in the body of the document. Section Non-application of standard is the place for this. This entire matter is very parallel to the entire discussion regarding the midstream gas processing industry and the task for work related to it. In fact it s the same issue. In effect the midstream task force work says many gathering lines are technically equivalent to DOT regulated lines and therefore the DOT practices related to purging and safe piping processes should apply. This is the same issue with segments of distribution piping and transmission piping that consist of largely underground sections that might be somewhat long and have few isolation valves. In these cases DOT practices address creating a plan for doing this kind of work. If NFPA 56 does not fit well for these kinds of systems and DOT does then why not require it instead of abdicating to some unknown set of practices that some gas utilities have or do not have? It makes no sense. Hence, this submission slightly changes the original task force for midstream piping systems and by doing so eliminates the need to exempt gas utilities, (7.1.2 and 8.2.1) later in the document. RELATED TO SUBMISSION #13 Submitter Full Name: John Puskar Organization: PuskarCo Submittal Date: Thu Jan 01 19:35:27 EST 2015 Resolution: FR-21-NFPA Statement: Clarify that this is applicable explicitly to electrical generating plant.

33 Public Input No. 21-NFPA [ Section No ] IT IS PROPOSED THAT THIS SECTION BE DELETED IN ACCORDANCE WITH PUBLIC COMMENT # * If owned or operated by the serving natural gas supplier, natural gas piping between the point of delivery or source valve and the plant shall be permitted to be purged out of service in accordance with the serving natural gas supplier s written procedures The natural gas supplier s written procedures shall include a safety validation in accordance with Section The natural gas supplier s written procedures and process shall be coordinated with the plant operational personnel. Sections and discuss the possibility of a plant being owned by a serving gas utility. It s not clear what a plant is. I believe it was meant to indicate electrical generating plant. However, there is no definition for plant. In my opinion, this is an exemption. First of all, exemptions should not be addressed in the body of the document. Section Non-application of standard is the place for this. This entire matter is very parallel to the entire discussion regarding the midstream gas processing industry and the task for work related to it. In fact it s the same issue. In effect the midstream task force work says many gathering lines are technically equivalent to DOT regulated lines and therefore the DOT practices related to purging and safe piping processes should apply. This is the same issue with segments of distribution piping and transmission piping that consist of largely underground sections that might be somewhat long and have few isolation valves. In these cases DOT practices address creating a plan for doing this kind of work. If NFPA 56 does not fit well for these kinds of systems and DOT does then why not require it instead of abdicating to some unknown set of practices that some gas utilities have or do not have? It makes no sense. Hence, this submission slightly changes the original task force for midstream piping systems and by doing so eliminates the need to exempt gas utilities, (7.1.2 and 8.2.1) later in the document. RELATED TO COMMENT 13 Submitter Full Name: John Puskar Organization: PuskarCo Submittal Date: Thu Jan 01 19:37:26 EST 2015 Resolution: FR-22-NFPA Statement: Clarify this is explicitly applicable to electric generating plants. 3 of 39 7/15/2015 8:29 AM

34 4 of 39 7/15/2015 8:29 AM Public Input No. 14-NFPA [ New Section after A.1.1.2(6) ] For Public Comment #12 Section exemption (10): US DOT 49 cfr 191/192 contains guidance on carefully planning flammable gas piping activities including purging gathering line systems into and out of service. Much of this guidance addresses techniques for relatively long underground runs where there may not be isolation valves. This standard, NFPA 56, also provides guidance for purging piping systems into and out of service. Many of the techniques and processes within this standard, including the requirements for detailed planning and the use of nitrogen or other inert gases for purging can enhance the safety of gathering line installation and servicing activities. For Public comment #13 Section exemption (10): US DOT 49 cfr 191/192 contains guidance on carefully planning flammable gas piping activities including purging gathering line systems into and out of service. Much of this guidance addresses techniques for relatively long underground runs where there may not be isolation valves. These kinds of runs are technically equivalent to some distribution and transmission line segments. This standard, NFPA 56, also provides guidance for purging piping systems into and out of service. Many of the techniques and processes within this standard, including the requirements for detailed planning and the use of nitrogen or other inert gases for purging can enhance the safety of gathering, distribution and transmission line segment installation and servicing activities. These annex sections help to explain the non application of standard submissions made. I provided two annex sections here, one for public comment #12 and one for #13. They are very similar and I thought these might be discussed at the same time. Submitter Full Name: John Puskar Organization: PuskarCo Submittal Date: Thu Jan 01 18:51:00 EST 2015 Resolution: FR-20-NFPA Statement: Clarify that gathering lines and upstream piping are not in the scope of this document.

35 5 of 39 7/15/2015 8:29 AM Public Input No. 24-NFPA [ New Section after A.4.4.1(4)(a) ] TITLE OF NEW CONTENT Type your content here... A.4.4.1(4)(e) Temporary piping may be comprised of an assembly of solid piping, flexible hose and flexible tubing. It is preferable to use only conductive components in the temporary piping system; however, the use of non-conductive components may be necessitated by the constraints of the installation or process. Specific guidance on grounding and bonding of non-conductive components is provided in NFPA 77 Section 10.3, included here for the convenience of the user: 10.3* Flexible Hose and Tubing. Flexible hose and flexible tubing are available in metal, lined metal, nonconductive plastic, reinforced rubber and plastic, and composite-ply types Where nonconductive hose or tubing must be used because of process conditions, the hazards of static electric charge generation should be thoroughly investigated As a minimum, all conductive couplings (e.g., end fittings) and components should be bonded and grounded If hose[s] are used immediately downstream of filters in nonconductive liquid [fluid] service, they should be of metal or other conductive material. Semiconductive liners might be necessary to prevent charge accumulation and pinhole damage to the hose Conductive hose[s] should be electrically continuous, and the continuity should be periodically checked Hose[s] with more than one internal spiral should not be used because it is not possible to determine if one of the spirals has lost its continuity. A.10.3 For all-metal conductive hose, the resistance to ground from any point normally should be 10 ohms or less. For conductive hose that contain a continuous bonding element, such as wire or braid, the resistance to ground from any metal connector normally should be 1000 ohms per meter or less, with the same exception being applicable. Resistance to ground through semiconductive hose with a currentlimiting design that eliminates a low-resistance bonding element and resistance to ground through insulating flanges should be between 103 ohms/m and 105 ohms/m. In either case, the total resistance to ground from a metal hose connector should not exceed 106 ohms. While a resistance to ground of less than 106 ohms will prevent accumulation of static electric charge in most cases, if periodic testing reveals a significant increase in the as-installed resistance, that increase could be the result of corrosion or other damage, which could lead to sudden loss of continuity. The hose, insulating flange, or both should be inspected to determine the need for replacement. Where conductive hose has double spirals, one for bonding and the other for mechanical strength, continuity between the end connectors confirms the continuity of only one spiral. A fire was reported during draining of toluene from a tank vehicle through such a hose. It was found that the inner spiral not only was broken but was not designed to be bonded to the end connectors. For handling nonconductive liquids, one option is to use a hose with a semiconductive or conductive liner, so that a broken inner spiral cannot become isolated from ground and form a spark gap. Ideally, the inner spiral should be separately bonded to the end connectors. It is especially important to ensure continuity with end connectors (or nozzles) where a hose is used in an ignitable atmosphere. In general, it is safer to use a properly designed fixed fill system, such as a dip pipe arrangement, for filling tank vehicles, rather than to use a hose. Where used in flammable atmospheres, such as inside tanks, utility hose should be conductive or semiconductive. In particular, all metal connectors and nozzles should be grounded. Ungrounded hose connectors on nonconductive hose can become charged by a variety of means, such as by the insertion of a nitrogen hose into a tank containing charged liquid or mist, by rubbing, or by streaming currents generated by the flow of steam condensate. While clean and dry gases do not generate charge, a nonconductive hose will become highly charged by the flow of steam. Additional background information on control of static electricity for fluid systems can be found in API Recommended Practice 2003.

36 6 of 39 7/15/2015 8:29 AM See Justification for Public Input No. 23-NFPA Related Public Inputs for This Document Related Input Public Input No. 23-NFPA [Section No ] Relationship Submitter Full Name: Lawrence Danner Organization: GE Power & Water Submittal Date: Mon Jan 05 07:09:24 EST 2015 Resolution: FR-4-NFPA Statement: Made editorial revisions for clarity. While the current text highlights control of static electricity at the discharge point, the inclusion of non-conductive components within a temporary piping system used for venting and purging can induce static charges that may not be accounted for if the focus is limited to the discharge point. Although primarily directed at non-conductive liquids, NFPA 77 provides the essential basis for control of this hazard and, while it is generically referenced in the annex for Section 4.4.1(4)(a), drawing the user to the specifics of Section 10.3 in NFPA 77 will promote a proper review of this detail. API RP 2003 provides a full discussion of protections for static electricity and can be of assistance in evaluating the risks from static electricity. Reorganized and updated to raise the awareness level of users to these issues.

37 7 of 39 7/15/2015 8:29 AM Public Input No. 5-NFPA [ Chapter D ] Annex D Informational References D.1 Referenced Publications. The documents or portions thereof listed in this annex are referenced within the informational sections of this standard and are not part of the requirements of this document unless also listed in Chapter 2 for other reasons. D.1.1 NFPA Publications. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA NFPA 1, Fire Code, 2012 edition NFPA 2, Hydrogen Technologies Code, 2011 edition NFPA 30, Flammable and Combustible Liquids Code, 2012 edition NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages, 2012 edition NFPA 37, Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines, 2010 edition NFPA 45, Standard on Fire Protection for Laboratories Using Chemicals, 2011 edition NFPA 51, Standard for the Design and Installation of Oxygen Fuel Gas Systems for Welding, Cutting, and Allied Processes, 2013 edition. NFPA 51A, Standard for Acetylene Cylinder Charging Plants, 2012 edition NFPA 52, Vehicular Gaseous Fuel Systems Code, 2013 edition NFPA 54, National Fuel Gas Code, 2012 edition NFPA 55, Compressed Gases and Cryogenic Fluids Code, 2010 edition NFPA 55, Compressed Gases and Cryogenic Fluids Code, 2013 edition.nfpa 58, Liquefied Petroleum Gas Code, 2014 edition NFPA 59, Utility LP-Gas Plant Code, 2012 edition NFPA 59A, Standard for the Production, Storage, and Handling of Liquefied Natural Gas (LNG), 2013 edition NFPA 69, Standard on Explosion Prevention Systems, 2008 edition NFPA 70, National Electrical Code, 2014 edition NFPA 77, Recommended Practice on Static Electricity, 2014 edition. NFPA 85, Boiler and Combustion Systems Hazards Code, 2011 edition NFPA 86, Standard for Ovens and Furnaces, 2011 edition NFPA 87, Recommended Practice for Fluid Heaters, 2011 edition NFPA 99, Health Care Facilities Code, 2012 edition NFPA 400, Hazardous Materials Code, 2013 edition NFPA 801, Standard for Fire Protection for Facilities Handling Radioactive Materials, 2014 edition. D.1.2 Other Publications. D AGA Publications. American Gas Association, 400 N. Capitol Street, N W, Washington, DC AGA XK0101, Purging Principles and Practices, 2001.

38 8 of 39 7/15/2015 8:29 AM D AIChE Publications. American Institute of Chemical Engineers, Center for Chemical Process Safety, Three Park Avenue, New York, NY Crowl, D. A., Understanding Explosions, Guidelines for Hazard Evaluation Procedures, 2nd 3rd edition, D ASME Publications. American Society of Mechanical Engineers, Three ASME International, Two Park Avenue, New York, NY ASME B31.1, Power Piping, ASME B31.3, Process Piping, D ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA ASTM E 2079, Standard Test Method for Limiting Oxygen (Oxidant) Concentration for Gases and Vapors, 2007, reapproved D U.S. Government Publications. U.S. Government Printing Office, Washington, DC Kuchta, J. M., Investigation of Fire and Explosion Accidents in the Chemical, Mining, and Fuel-Related Industries A Manual, in U.S. Bureau of Mines Bulletin 680, U.S. Department of the Interior, Title 49, Code of Federal Regulations, Parts , Hazardous Material Regulations. Title 49, Code of Federal Regulations, Parts , Pipeline Safety Regulations. U.S. Department of Labor, Occupational Safety and Health Administration (OSHA), Safety and Health Topics, Competent Persons, D Other Publications. Britton, L. G., Using Heats of Oxidation to Evaluate Flammability Hazards, Process Safety Progress, 20(1), (March 2002): Coward, J. F., and G. W. Jones, Limits of Flammability of Gases and Vapors, Bulletin 503, U.S. Bureau of Mines, Pittsburgh, PA, Jones, G. W., et al., Research on the Flammability Characteristics of Aircraft Fuels, Wright Air Development Center, Wright-Patterson AFB, OH, Technical Report 52-35, Supplement I, Kuchta, J. M., et al., Effect of Pressure and Temperature on Flammability Limits of Chlorinated Combustibles in Oxygen-Nitrogen and Nitrogen Tetroxide-Nitrogen Atmospheres, Journal of Chemical and Engineering Data, Vol. 13, No. 3, July 1968 (American Chemical Society, Washington, DC), p Zabetakis, M. G., Flammability Characteristics of Combustible Gases and Vapors, Bulletin 627, U.S. Bureau of Mines, Pittsburgh, PA, Zabetakis, M. G., and B. H. Rosen, Considerations Involved in Handling Kerosine, Proceedings, API, Vol. 37, Sec. III, 1957, p D.2 Informational References. D.2.1 ASSE Publications. American Society of Safety Engineers, 1800 E. Oakton Street, Des Plaines, IL ASSE/ISO Risk Management, Risk Management Package, (Includes the following 3 standards) ANSI/ASSE Z690.1, Vocabulary for Risk Management, ANSI/ASSE Z690.2, Risk Management Principles and Guidelines, ANSI/ASSE Z690.3, Risk Assessment Techniques, D.2.2 Other Publications. (Reserved)