TECHNICAL COMMITTEE ON HANDLING AND CONVEYING OF DUSTS, VAPORS, AND GASES NFPA 655 CMD-HAP F , AM 4 PM ET AGENDA

Transcription

1 TECHNICAL COMMITTEE ON HANDLING AND CONVEYING OF DUSTS, VAPORS, AND GASES NFPA 655 CMD-HAP F2016 First Draft Web/Teleconference Meeting February 23, AM 4 PM ET AGENDA 1.0 Meeting is called to order at 10 AM ET 2.0 Welcome and Self-Introduction of Committee Members and Guests 3.0 Chair and Staff Liaison Remarks 4.0 Approve minutes from last meeting of TC (first draft for 654) 5.0 Review of F2016 Revision Cycle and new NFPA process (staff liaison presentation on new process and procedures, will include membership review and review of schedule) 6.0 Committee Correspondence 7.0 Review of public input to NFPA Review of correlating notes for other dust documents 9.0 Old Business 10.0 New Business and determination of next meeting date and location 11.0 Adjournment Meeting will adjourn at 4 PM ET

2 TECHNICAL COMMITTEE ON HANDLING AND CONVEYING OF DUSTS, VAPORS, AND GASES Minutes of Meeting NFPA 654 First Draft Meeting Atlanta, GA July 30 August 1, 2014 Member Attending Mark Runyon chair Yes Principal Brice Chastain Yes Principal John Cholin Yes Principal Burke Desautels No Principal Tony DiLucido No Principal Vahid Ebadat No Principal Henry Febo Yes Principal Larry Floyd Yes Principal Walter Frank Yes Principal Stephen Greeson Yes Principal Mark Holcomb Yes Principal Jerry Jennett No Principal David Kirby Yes Principal James Koch Yes by phone Principal Bruce McLelland Yes Principal Jack Osborn Yes Principal Richard Pehrson No Principal Jason Reason Yes by phone Principal Ali Reza Yes Principal James Roberts No Principal Samuel Rodgers Yes- by phone Principal Thomas Scherpa Yes Principal Bill Stevenson Yes Principal Jeffrey Sutton Yes Principal Robert Taylor Yes Principal Tony Thomas Yes Principal Erdem Ural Yes by phone Principal Harold Weber No Principal Glenn Baldwin Yes by phone Alternate

3 Amy Brown Yes Alternate David Clayton No Alternate James Dahn No Alternate Randal Davis Yes Alternate Randall Dunlap Yes Alternate Robert Gravell No Alternate William Hilton No Alternate Jason Krbec No Alternate Philip Parson Yes Alternate Robert Shafto No Alternate Jerome Taveau No Alternate Matthew Chibbaro No Alternate Harry Verakis No Alternate William Hamilton No Alternate Jay Juvenal Yes Guest Niels Petersen Yes Guest Susan Bershad Yes NFPA staff Guy Colonna Yes NFPA staff 1.0 The meeting was called to order at 8 am by Mark Runyon, chair. The attendees, guests, and those attending via the web conference made self-introductions. 2.0 Guy Colonna, NFPA staff, introduced the new staff liaison, Susan Bershad, and gave a presentation on the new process, the schedule for the A2016 cycle, and the committee membership. There are currently 28 voting members on the technical committee. 3.0 The committee reviewed and approved the minutes from the July 23, 2014 Second Draft Meeting for NFPA The committee reviewed and acted on the public input received for NFPA 654. The committee reviewed and acted on 109 of the 112 public input received on the document. The last three public input will be discussed in a web meeting scheduled for Friday, August 15, 2014 from 10 AM to 3 PM ET. 5.0 The meeting adjourned at 5 PM on July 30 and 31, and at 1 PM on August 1, The committee discussed the timing and location of the Second Draft Meeting. A decision was made to hold the Second Draft Meeting after the NFPA annual meeting next June in Chicago. If there are any NITMAMs received on NFPA 652, they will be heard at the June, 2015 annual meeting, which will be held in Chicago June 22 to the 25, The committee decided to hold the Second Draft Meeting July 7, 8, and 9, 2015 in Seattle, WA.

4 TECHNICAL COMMITTEE ON HANDLING AND CONVEYING OF DUSTS, VAPORS, AND GASES Minutes of Meeting NFPA 654 First Draft Meeting - Continuation Web Meeting August 15, 2014, 10 AM 1 PM ET Member Attending Mark Runyon chair Yes Principal Brice Chastain Yes Principal John Cholin Yes Principal Burke Desautels Yes Principal Tony DiLucido Yes Principal Vahid Ebadat No Principal Henry Febo Yes Principal Larry Floyd No Principal Walter Frank No Principal Stephen Greeson Yes Principal Mark Holcomb No Principal Jerry Jennett No Principal David Kirby No Principal James Koch No Principal Bruce McLelland No Principal Jack Osborn No Principal Richard Pehrson Yes Principal Jason Reason Yes Principal Ali Reza No Principal James Roberts No Principal Samuel Rodgers Yes Principal Thomas Scherpa No Principal Bill Stevenson Yes Principal Jeffrey Sutton No Principal Robert Taylor No Principal Tony Thomas Yes Principal Erdem Ural Yes Principal Harold Weber No Principal Glenn Baldwin Yes Alternate

5 Amy Brown No Alternate David Clayton Yes Alternate James Dahn No Alternate Randal Davis No Alternate Randall Dunlap No Alternate Robert Gravell No Alternate William Hilton No Alternate Jason Krbec No Alternate Philip Parson Yes Alternate Robert Shafto No Alternate Jerome Taveau No Alternate Matthew Chibbaro No Alternate Harry Verakis No Alternate William Hamilton No Alternate Niels Pedersen Yes Guest Susan Bershad Yes NFPA Tony Supine Yes Guest Mike Walters Yes Guest Guy Colonna Yes NFPA 1.0 The meeting was called to order at 10 am by Mark Runyon, chair. Staff did a roll call and noted attendance. 2.0 Prior to consideration of the remaining three public input from the Atlanta meeting, Niels Pedersen made a presentation providing background information for the three public input, which he submitted to the technical committee. This presentation is a rather large file, and the link to it was forwarded to the committee via subsequent to the meeting. 3.0 The committee considered the three remaining public input for 654, all of which were for annex material. These were PI-43, 44, and Camfil made a presentation on its position on PI-42. PI-42 was considered at the meeting in Atlanta. The committee response to PI -42 is FR-44. The committee did not vote to reconsider its response to PI-42 and invites Camfil and any other interested parties to submit public comment on the material. A copy of this presentation was transmitted to the committee via after the meeting. 5.0 The committee reviewed the membership and scope of task groups going forward. These are as listed below. If there are any committee members that would like to join one of the task groups, please let the chair or the staff know. Note that the task group leaders are designated in bold: Task group to develop public comment on FR-44. o Bill Stevenson, Erdem Ural Task group to review PI 101 compare housekeeping requirements to 652. o Tom Scherpa, Sam Rodgers, Bill Stevenson, Erdem Ural

6 Task group to develop annex material for material in 10.2 o Tony Thomas and John Cholin, Sam Rodgers. Scope of task group work Develop annex material to explain the material in 10.2 and to develop public comment on the first revisions in 10.2 that are consistent with the annex material. This will be presented to the TC at the second draft. Task group to develop public comment for FR-37 reach out to the 69 TC for participation o Erdem Ural, Sam Rodgers, Bill Stevenson, John Cholin, and Henry Febo. Task group to develop public comment to annex material on abort gates (committee input response to PI- 43, 44, and 45. o Bill Stevenson, Erdem Ural, Tony Thomas, Niels Pedersen, and John Cholin 6.0 The meeting was adjourned at 1 PM ET. The next meeting of the committee will be the second draft meeting currently scheduled for July 7, 8, and 9, 2015 in Seattle, WA.

7 Address List No Phone Handling and Conveying of Dusts, Vapors, and Gases Combustible Dusts Mark L. Runyon Chair Marsh Risk Consulting 111 SW Columbia, Suite 500 Portland, OR I 1/10/2008 CMD-HAP Brice Chastain Principal Georgia-Pacific LLC 133 Peachtree Street NE, 9th Floor Atlanta, GA Alternate: William C. Hilton 02/04/2015 Susan Bershad CMD-HAP U 10/28/2008 CMD-HAP John M. Cholin Principal J. M. Cholin Consultants Inc. 101 Roosevelt Drive Oakland, NJ SE 1/1/1992 CMD-HAP Ashok Ghose Dastidar Principal Fauske & Associates, LLC 16W070 83rd Street Burr Ridge, IL SE 10/28/2014 CMD-HAP Burke Desautels Principal Fenwal/IEP Technologies 400 Main Street Ashland, MA Alternate: Randal R. Davis M 03/07/2013 CMD-HAP Tony DiLucido Principal Zurich Risk Engineering Services 720 Ash Avenue Collingdale, PA Alternate: Robert D. Shafto I 8/5/2009 CMD-HAP Vahid Ebadat Principal Chilworth Technology Inc. 113 Campus Drive Princeton, NJ Alternate: C. James Dahn SE 7/1/1996 CMD-HAP Henry L. Febo, Jr. Principal FM Global Engineering Standards 1151 Boston-Providence Turnpike PO Box 9102 Norwood, MA Alternate: Amy Brown I 4/1/1996 CMD-HAP Larry D. Floyd Principal BASF 1379 Ciba Road McIntosh, AL U 8/5/2009 CMD-HAP Walter L. Frank Principal Frank Risk Solutions, Inc Shallcross Avenue Wilmington, DE SE 7/1/1994 CMD-HAP Stephen T. Greeson Principal HSB Professional Loss Control 3410 Navasota Circle San Antonio, TX I 8/5/2009 CMD-HAP Mark L. Holcomb Principal Kimberly-Clark Corporation 2001 Marathon Avenue Neenah, WI U 7/23/2008 CMD-HAP Jerry J. Jennett Principal Georgia Gulf Sulfur Corporation PO Box 1165 Valdosta, GA Alternate: Randall Dunlap U 1/15/1999 CMD-HAP David C. Kirby Principal Baker Engineering & Risk Consultants, Inc Clearview Heights Charleston, WV Alternate: Philip J. Parsons SE 1/1/1983 CMD-HAP 1

8 Address List No Phone Handling and Conveying of Dusts, Vapors, and Gases 02/04/2015 Susan Bershad CMD-HAP James F. Koch Principal The Dow Chemical Company 1400 Building Midland, MI American Chemistry Council Alternate: Glenn W. Baldwin U 10/28/2008 CMD-HAP Bruce McLelland Principal Fike Corporation 704 SW 10th Street Blue Springs, MO Alternate: Jérôme R. Taveau M 3/2/2010 CMD-HAP Jack E. Osborn Principal Airdusco, Inc Mendenhall Road South Memphis, TN M 1/10/2008 CMD-HAP Richard Pehrson Principal Pehrson Fire PC 7455 France Avenue South, Suite 271 Edina, MN International Fire Marshals Association E 3/1/2011 CMD-HAP Jason P. Reason Principal Lewellyn Technology 321 North 18th Avenue Beech Grove, IN SE 3/2/2010 CMD-HAP Ali Reza Principal Exponent, Inc McConnell Avenue Los Angeles, CA Alternate: David B. Clayton SE 03/05/2012 CMD-HAP James L. Roberts Principal Fluor Enterprises, Inc. 100 Fluor Daniel Drive Greenville, SC SE 1/1/1989 CMD-HAP Samuel A. Rodgers Principal Honeywell, Inc Woods Edge Road Colonial Heights, VA U 7/20/2000 CMD-HAP Thomas C. Scherpa Principal The DuPont Company, Inc. 71 Valley Road Sullivan, NH Alternate: Robert L. Gravell U 3/21/2006 CMD-HAP Bill Stevenson Principal CV Technology, Inc Mercantile Court Jupiter, FL Alternate: Jason Krbec M 1/15/1999 CMD-HAP Jeffery W. Sutton Principal Global Risk Consultants Corporation 350 Highway 7, Suite 220 Excelsior, MN SE 3/4/2008 CMD-HAP Robert D. Taylor Principal PRB Coal Users Group 4377 Sandra Kay Lane Newburgh, IN U 8/9/2011 CMD-HAP Tony L. Thomas Principal Flamex, Inc Federal Drive Greensboro, NC M 10/27/2009 CMD-HAP Erdem A. Ural Principal Loss Prevention Science & Technologies, Inc. 2 Canton Street, Suite A2 Stoughton, MA SE 7/23/2008 CMD-HAP 2

9 Address List No Phone Handling and Conveying of Dusts, Vapors, and Gases Combustible Dusts Michael Walters Principal Camfil Farr Air Pollution Control 3501 South Airport Road Jonesboro, AR M 10/27/2009 CMD-HAP Harold H. Weber, Jr. Principal The Sulphur Institute th Street, NW, Suite 520 Washington, DC /04/2015 Susan Bershad CMD-HAP U 1/1/1986 CMD-HAP Glenn W. Baldwin Alternate The Dow Chemical Company PO Box 8361 South Charleston, WV American Chemistry Council Principal: James F. Koch U 03/07/2013 CMD-HAP VL to Document: 655 Amy Brown Alternate FM Global 1151 Boston-Providence Turnpike PO Box 9102 Norwood, MA Principal: Henry L. Febo, Jr. I 03/03/2014 CMD-HAP David B. Clayton Alternate Exponent, Inc McConnell Avenue Los Angeles, CA Principal: Ali Reza SE 10/29/2012 CMD-HAP C. James Dahn Alternate Safety Consulting Engineers Inc Hammond Drive Schaumburg, IL Principal: Vahid Ebadat SE 1/1/1989 CMD-HAP Randal R. Davis Alternate IEP Technologies South Street Marlborough, MA Principal: Burke Desautels M 10/29/2012 CMD-HAP Randall Dunlap Alternate Georgia Gulf Sulfur Corporation PO Box 67 Bainbridge, GA Principal: Jerry J. Jennett U 3/2/2010 CMD-HAP Robert L. Gravell Alternate The DuPont Company, Inc. Chambers Works Site Explosion Hazards Laboratory Mail Spot WWTP O Deepwater, NJ Principal: Thomas C. Scherpa U 3/4/2009 CMD-HAP William C. Hilton Alternate Georgia-Pacific 133 Peachtree Street, NE Atlanta, GA Principal: Brice Chastain U 7/23/2008 CMD-HAP Jason Krbec Alternate CV Technology, Inc Mercantile Court Jupiter, FL Principal: Bill Stevenson M 3/1/2011 CMD-HAP Philip J. Parsons Alternate Baker Engineering & Risk Consultants, Inc West Lynnwood Avenue San Antonio, TX Principal: David C. Kirby SE 8/9/2011 CMD-HAP 3

10 Address List No Phone Handling and Conveying of Dusts, Vapors, and Gases 02/04/2015 Susan Bershad CMD-HAP Robert D. Shafto Alternate Zurich Insurance 1093 Tall Pines Trail Highland, MI Principal: Tony DiLucido I 8/5/2009 CMD-HAP Jérôme R. Taveau Alternate Fike Corporation 704 SW 10th Street Blue Springs, MO Principal: Bruce McLelland M 03/07/2013 CMD-HAP Matthew I. Chibbaro Nonvoting Member US Department of Labor Occupational Safety & Health Administration 200 Constitution Ave. NW, Room N3609 Washington, DC Alternate: William R. Hamilton E 3/4/2009 CMD-HAP William R. Hamilton Alt. to Nonvoting Member US Department of Labor Occupational Safety & Health Administration 200 Constitution Ave. NW, Room N3609 Washington, DC Principal: Matthew I. Chibbaro E 3/4/2009 CMD-HAP Susan Bershad Staff Liaison National Fire Protection Association 1 Batterymarch Park Quincy, MA /16/2014 CMD-HAP 4

11 2016 FALL REVISION CYCLE *Public Input Dates may vary according to standards and schedules for Revision Cycles may change. Please check the NFPA Website for the most up to date information on Public Input Closing Dates and schedules at # (i.e. and click on the Next Edition tab. Process Stage Process Step Dates for TC Dates for TC with CC Public Input Closing Date* 1/5/15 1/5/15 Final Date for TC First Draft Meeting 6/15/15 3/16/15 Public Input Posting of First Draft and TC Ballot 8/3/15 4/27/15 Stage Final date for Receipt of TC First Draft ballot 8/24/15 5/18/15 (First Draft) Final date for Receipt of TC First Draft ballot recirc 8/31/15 5/25/15 Posting of First Draft for CC Meeting 6/1/15 Final date for CC First Draft Meeting 7/13/15 Posting of First Draft and CC Ballot 8/3/15 Final date for Receipt of CC First Draft ballot 8/24/15 Final date for Receipt of CC First Draft ballot recirc 8/31/15 Post First Draft Report for Public Comment 9/7/15 9/7/15 Public Comment closing date 11/16/15 11/16/15 Final Date to Publish Notice of Consent Standards (Standards that 11/30/15 11/30/15 received no Comments) Appeal Closing Date for Consent Standards (Standards that received 12/14/15 12/14/15 no Comments) Final date for TC Second Draft Meeting 5/2/16 1/25/16 Comment Posting of Second Draft and TC Ballot 6/13/16 3/7/16 Stage Final date for Receipt of TC Second Draft ballot 7/5/16 3/28/16 (Second Final date for receipt of TC Second Draft ballot recirc 7/11/16 4/4/16 Draft) Posting of Second Draft for CC Meeting 4/11/16 Final date for CC Second Draft Meeting 5/23/16 Posting of Second Draft for CC Ballot 6/13/16 Final date for Receipt of CC Second Draft ballot 7/5/16 Final date for Receipt of CC Second Draft ballot recirc 7/11/16 Post Second Draft Report for NITMAM Review 7/18/16 7/18/16 Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 8/22/16 8/22/16 Preparation Posting of Certified Amending Motions (CAMs) and Consent 10/17/16 10/17/16 Standards (& Issuance) Appeal Closing Date for Consent Standards 11/1/16 11/1/16 SC Issuance Date for Consent Standards 11/11/16 11/11/16 Tech Session Association Meeting for Standards with CAMs 6/4 7/17 6/4 7/17 Appeals and Appeal Closing Date for Standards with CAMs 6/27/17 6/27/17 Issuance SC Issuance Date for Standards with CAMs 8/10/17 8/10/17 Approved October 30, 2012 Revised

12 National Fire Protection Association Report Public Input No. 3-NFPA [ Chapter 2 ] Chapter 2 Referenced Publications 2.1 General. The documents or portions thereof listed in this chapter are referenced within this standard and shall be considered part of the requirements of this document. 2.2 NFPA Publications. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA NFPA 17, Standard for Dry Chemical Extinguishing Systems, 2009 edition NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work,2009 edition NFPA 68, Standard on Explosion Protection by Deflagration Venting, 2007 edition NFPA 69, Standard on Explosion Prevention Systems, 2008 edition NFPA 70, National Electrical Code, 2011 edition NFPA 72, National Fire Alarm and Signaling Code, 2010 edition NFPA 80, Standard for Fire Doors and Other Opening Protectives, 2010 edition NFPA 101, Life Safety Code, 2012 edition NFPA 220, Standard on Types of Building Construction, 2012 edition NFPA 221, Standard for High Challenge Fire Walls, Fire Walls, and Fire Barrier Walls, 2012 edition NFPA 496, Standard for Purged and Pressurized Enclosures for Electrical Equipment, 2008 edition NFPA 600, Standard on Industrial Fire Brigades, 2010 edition NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids, 2006 edition NFPA 780, Standard for the Installation of Lightning Protection Systems, 2011 edition NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire, 2012 edition Other Publications ISA Publications. The Instrumentation, Systems, and Automation Society, 67 Alexander Drive, Research Triangle Park, NC ANSI/ISA , Functional Safety: Safety Instrumental Systems for the Process Industry Sector, 2004 edition U.S. Government Publications. U.S. Government Printing Office, Washington, DC Title 29, Code of Federal Regulations, (b) Other Publications. Merriam-Webster's Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, References for Extracts in Mandatory Sections. NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids, 2006 edition NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire, 2012 edition Statement of Problem and Substantiation for Public Input of 11 2/4/2015 1:08 PM

13 National Fire Protection Association Report of /4/2015 1:08 PM Referenced current editions. Related Public Inputs for This Document Related Input Public Input No. 4-NFPA [Chapter C] Relationship Submitter Information Verification Submitter Full Name: Aaron Adamczyk Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Fri Jun 20 00:30:29 EDT 2014

14 National Fire Protection Association Report of /4/2015 1:08 PM Public Input No. 9-NFPA [ Section No ] * Where lightning protection is provided, it shall be installed in accordance with NFPA 780, Standard for the Installation of Lightning Protection Systems. Statement of Problem and Substantiation for Public Input The proposed annex text provides the user of the standard with information on the source of risk assessment procedures which may be used to determine when lightning protection should be provided. Submitter Information Verification Submitter Full Name: Mark Morgan Organization: East Coast Lightning Equipment Affilliation: On behalf of NFPA 780 References Task Group Street Address: City: State: Zip: Submittal Date: Tue Dec 30 17:24:56 EST 2014

15 National Fire Protection Association Report Public Input No. 6-NFPA [ Section No. 5.5 ] 5.5 Fire Fighting Protection for covered liquid sulfur storage tanks, pits, and trenches shall be by one of the following means: (1) Inert gas system in accordance with NFPA 69, Standard on Explosion Prevention Systems (2) * Steam extinguishing system capable of delivering a minimum of 2.5 lb/min (1.13 kg/min) of steam per 100 ft 3 (2.83 m 3 ) of volume Rapid (3.)* Rapid sealing of the enclosure to exclude air. For sulfur tanks and sulfur pits the use of a steam rate of 1.0 lb/min (0.45 kg/min) of steam per 100 ft 3 (2.83 m 3 ) of total tank or pit volume is expected to develop a positive pressure in the enclosure thereby sealing the sulfur tank or sulfur pit preventing air ingress and extinguishing the fire Snuffing Steam and Sealing Steam Precautions The vent systems on enclosed sulfur tanks and sulfur pits must be designed to allow the required snuffing steam rate or sealing steam rate to vent without over pressuring the enclosure. The vent systems must also be designed for proper operation during normal operation Water Extinguishing Precautions Liquid sulfur stored in open containers shall be permitted to be extinguished with a fine water spray Use of high-pressure hose streams shall be avoided The quantity of water used shall be kept to a minimum Dry Chemical Extinguishers. Where sulfur is being heated by a combustible heat transfer fluid, dry chemical extinguishers complying with NFPA 17, Standard for Dry Chemical Extinguishing Systems, shall be provided. Statement of Problem and Substantiation for Public Input The NFPA 655 snuffing steam rate is so large that it creates issues with overpressureing sulfur tanks and sulfur pits. We have written a paper called M olten Sulfur Fire Sealing Steam Requirements to address the problemsfound, present our analysis of the issues and propose a sealing steam rate that we want NFPA 655 to consider Submitter Information Verification Submitter Full Name: ALAN MOSHER Organization: Black & Veatch Street Address: City: State: Zip: Submittal Date: Fri Dec 19 18:07:32 EST 2014 of 11 2/4/2015 1:08 PM

16 National Fire Protection Association Report of /4/2015 1:08 PM Public Input No. 5-NFPA [ Section No ] Dry Chemical Portable Fire Extinguishers. Where sulfur is being heated by a combustible heat transfer fluid, dry chemical extinguishers complying with NFPA 17, Standard for Dry Chemical Extinguishing Systems, water mist extinguishers rated 2-A:C, shall be provided. Statement of Problem and Substantiation for Public Input Dry chemical extinguishers can disrupt a sulfur pile and cause the dust to become airborne, which can explode on contact with an ignition source such as a spark or flame. Water mist extinguishers deliver a fine spray which ensures that sulfur dust clouds are not created. Water mist is also the most satisfactory extinguishing agent for bulk stores. Submitter Information Verification Submitter Full Name: Jennifer Boyle Organization: Mark Conroy, Brooks Equipment Affilliation: Fire Equipment Manufacturers Association (FEMA) Street Address: City: State: Zip: Submittal Date: Wed Dec 10 10:05:04 EST 2014

17 National Fire Protection Association Report of /4/2015 1:08 PM Public Input No. 10-NFPA [ New Section after A ] A NFPA 780, Annex L.6 and IEC provide methods for assessments to determine the need for lightning protection. Statement of Problem and Substantiation for Public Input The proposed annex text provides the user of the standard with information on the source of risk assessment procedures which may be used to determine when lightning protection should be provided Submitter Information Verification Submitter Full Name: Mark Morgan Organization: East Coast Lightning Equipment Affilliation: On behalf of NFPA 780 References Task Group Street Address: City: State: Zip: Submittal Date: Tue Dec 30 17:26:36 EST 2014

18 National Fire Protection Association Report of /4/2015 1:08 PM Public Input No. 7-NFPA [ Section No. A.5.5.1(2) ] A.5.5.1(2) The steam should preferably be introduced near the surface of the molten sulfur. See NFPA 86, Standard for Ovens and Furnaces, Section F.3. A.5.5.1(3) For enclosed sulfur tanks or sulfur pits with air sweep systems, the sealing steam should be fed into the enclosure very near the air inlets. As the sealing steam vents backwards through the air inlets the sealing steam will quickly stop air ingress to the fire. Sealing steam should be fed into the sulfur tank or sulfur pit for a minimum of 15 minutes or until the temperature has returned to near normal. For further information and good engineering practice regarding sealing steam see Molten Sulfur Fire Sealing Steam Requirements. Statement of Problem and Substantiation for Public Input This is additional information for 6-NFPA System is not letting me link the input forms together. Submitter Information Verification Submitter Full Name: ALAN MOSHER Organization: Black & Veatch Street Address: City: State: Zip: Submittal Date: Fri Dec 19 18:23:43 EST 2014

19 National Fire Protection Association Report of /4/2015 1:08 PM Public Input No. 4-NFPA [ Chapter C ] Annex C Informational References C.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. C.1.1 NFPA Publications. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA NFPA 68, Standard on Explosion Protection by Deflagration Venting, 2007 edition. NFPA 69, Standard on Explosion Prevention Systems, 2008 edition. NFPA 77, Recommended Practice on Static Electricity, 2007 edition. NFPA 86, Standard for Ovens and Furnaces, 2011 edition. NFPA 499, Recommended Practice for the Classification of Combustible Dusts and of Hazardous (Classified) Locations for Electrical Installations in Chemical Process Areas, 2008 edition. NFPA 5000, Building Construction and Safety Code, 2012 edition. C.1.2 Other Publications. C AIChE Publications. American Institute of Chemical Engineers, Three Park Avenue, 120 Wall Street, Floor 23, New York, NY Guidelines for Safe Automation of Chemical Processes, C ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA ASTM D 257, Standard Test Methods for DC Resistance or Conductance of Insulating Materials, ASTM E 1515, Standard Test Method for Minimum Explosible Concentration of Combustible Dusts, ASTM E 2019, Standard Test Method for Minimum Ignition Energy of a Dust Cloud in Air, 2007, reapproved 2013.

20 National Fire Protection Association Report of /4/2015 1:08 PM C Other Publications. Britton, L., Avoiding Static Ignition Hazards in Chemical Operations, CCPS, New York, NY, 1999, pp Ebadat, V., and Mulligan, J. C., Testing the Suitability of FIBCs for Use in Flammable Atmospheres, Process Safety Progress, Vol. 15, No. 3, Eckhoff, R. K., Dust Explosions in the Process Industries, Oxford, UK: Butterworth-Heinemann Ltd., 3rd edition, Hawley's Condensed Chemical Dictionary, 15th edition, ed. R. J. Lewis, John Wiley & Sons Inc., Hoboken, NJ, C.2 Informational References. The following documents or portions thereof are listed here as informational resources only. They are not a part of the requirements of this document. C.2.1 NFPA Publications. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA NFPA 51, Standard for the Design and Installation of Oxygen Fuel Gas Systems for Welding, Cutting, and Allied Processes, 2007 edition. NFPA 91, Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Noncombustible Particulate Solids, 2010 edition. NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids, 2006 edition. C.2.2 Additional Publications. Furno, A. L., G. H. Martindill, and M. G. Zebetakis, Gas Explosion Hazards Associated with the Bulk Storage of Molten Sulfur, U.S. Department of the Interior, Bureau of Mines RI 6185 (1963). Handling and Storage of Solid Sulfur, National Safety Council, Data Sheet I-612, revised Handling Liquid Sulfur, National Safety Council, Data Sheet 592, revised Lagas, J. A., et al., Understanding the Formation of and Handling of H S and SO Emissions from Liquid 2 2 Sulphur During Storage and Transportation. Schicho, C. M., W. A. Watson, K. R. Clem, and D. Hartley, A New Safer Method of Sulfur Degassing, Chemical Engineering Progress, October 1985, pp Wiewiorwski, T. K., and F. J. Touro, The Sulfur-Hydrogen Sulfide System, Journal of Physical Chemistry, vol. 70, pp (January No. 1) (1966). The Sulphur Data Book, Library of Congress ISBN C.3 References for Extracts in Informational Sections. NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids, 2006 edition Statement of Problem and Substantiation for Public Input Referenced current addresses, and editions. Related Public Inputs for This Document Related Input Public Input No. 3-NFPA [Chapter 2] Relationship Referenced current editions. Submitter Information Verification Submitter Full Name: Aaron Adamczyk Organization: [ Not Specified ] Street Address:

21 National Fire Protection Association Report 0 of 11 2/4/2015 1:08 PM City: State: Zip: Submittal Date: Fri Jun 20 01:03:02 EDT 2014

22 National Fire Protection Association Report 1 of 11 2/4/2015 1:08 PM Public Input No. 8-NFPA [ Section No. C ] C Other Publications. Britton, L., Avoiding Static Ignition Hazards in Chemical Operations, CCPS, New York, NY, 1999, pp Ebadat, V., and Mulligan, J. C., Testing the Suitability of FIBCs for Use in Flammable Atmospheres, Process Safety Progress, Vol. 15, No. 3, Eckhoff, R. K., Dust Explosions in the Process Industries, Oxford, UK: Butterworth-Heinemann Ltd., 3rd edition, Hawley's Condensed Chemical Dictionary, 15th edition, ed. R. J. Lewis, John Wiley & Sons Inc., Hoboken, NJ, Mosher, A. D., McGuffie, S. M., and Martens, D.H., Molten Sulfur Fire Sealing Steam Requirements, Brimstone Sulfur Symposium, Vail CO., September Statement of Problem and Substantiation for Public Input This is additional information for 6-NFPA and 7-NFPA The system is not letting me link the public inputs. Submitter Information Verification Submitter Full Name: ALAN MOSHER Organization: Black & Veatch Street Address: City: State: Zip: Submittal Date: Fri Dec 19 18:29:43 EST 2014

23 National Fire Protection Association Report of /21/2015 3:09 PM Correlating Committee Note No. 1-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: National Fire Protection Assoc Street Address: City: State: Zip: Submittal Date: Tue Dec 16 16:16:30 EST 2014 Committee Statement Committee Statement: The Correlating Committee recommends that the 61 technical committee reconsider FR-52. The statement is considered to be broad and overreaching. The 61 committee is encouraged to review 61 in more detail to determine how it aligns with NFPA 652. Please refer to CN # 3 for direction on aligning the layout and content of 61 with NFPA 652. It is understood by the correlating committee that this alignment will be a process that may need to take place over several revision cycles.

24 National Fire Protection Association Report of /21/2015 3:09 PM Correlating Committee Note No. 13-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Thu Jan 08 20:24:54 EST 2015 Committee Statement Committee Statement: The Correlating Committee recommends that the 61 TC consider pointing the user in the direction of NFPA 87 and NFPA 30 for guidance on heat transfer systems. This may be best accomplished through the addition of annex material.

25 National Fire Protection Association Report of /21/2015 3:09 PM Correlating Committee Note No. 14-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: National Fire Protection Assoc Street Address: City: State: Zip: Submittal Date: Fri Jan 09 09:35:23 EST 2015 Committee Statement Committee Statement: The Correlating Committee recognizes the 61 technical committee for the significant progress they have made in this first draft.

26 National Fire Protection Association Report of /21/2015 3:09 PM Correlating Committee Note No. 15-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: National Fire Protection Assoc Street Address: City: State: Zip: Submittal Date: Fri Jan 09 10:42:50 EST 2015 Committee Statement Committee Statement: The 61 technical committee should consider including the language in Section of NFPA This standard shall be used to supplement the requirements established by NFPA 652. This clarifies the relationship between 652 and the commodity-specific standards.

27 National Fire Protection Association Report of /21/2015 3:09 PM Correlating Committee Note No. 16-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: National Fire Protection Assoc Street Address: City: State: Zip: Submittal Date: Fri Jan 09 11:08:13 EST 2015 Committee Statement Committee Statement: The Correlating Committee recommends that the 61 technical committee consider adding the following material to the proposed new chapter on general requirements. This material was added to the first draft of 654 as well as 664. This recommendation is also being made to 484 and 655 as they enter their revision cycles Owner's Obligation. The facility owner/operator shall be responsible for ensuring that the facility and the systems handling combustible particulate solids are designed, installed, and maintained in accordance with the requirements of this standard and NFPA 652

28 National Fire Protection Association Report of /21/2015 3:09 PM Correlating Committee Note No. 2-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Thu Jan 08 19:25:43 EST 2015 Committee Statement Committee Statement: The 61 technical committee should review the definitions in Chapter 3 for consistency with 652. The definitions in Chapter 3 of 652 should be considered a baseline for those in the other dust documents. In some cases, the occupancy specific document may elect to define a term differently. In those cases, the rationale for the differences should be documented. Note that this comment is also being made to the 654 and the 664 technical committees, and will be made to the 655 and 484 committees as they go through their next revision cycle.

29 National Fire Protection Association Report of /21/2015 3:09 PM Correlating Committee Note No. 3-NFPA [ Global Input ] Supplemental Information File Name 652_outline.docx Description Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Thu Jan 08 19:28:09 EST 2015 Committee Statement Committee Statement: The 61 technical committee should review the layout of the document for consistency with NFPA 652. The chapter layout for the commodity specific standards should align with the layout of NFPA 652 in order to facilitate their use with NFPA 652 in accordance with section of NFPA 652. This comment is also being made to the 654 and 664 technical committees, and will be made to the 655 and 484 technical committees as they go through the next revision cycle. The Correlating Committee is providing an outline taken from 652 to assist the commodity specific committees with their expected alignment to 652 over the next revision cycles. In addition the outline includes the level of subsection that a user would use to compare 652 to an industry specific standard. This is the minimum level of alignment expected, the committee is free to go beyond this level. Note that the unhighlighted sections are those that should be used. It is expected that this may not be able to be completed in the current revision cycle, but this a goal that committees should work toward.

30 652 Chapter 1 Administration 1.1 Scope 1.2 Purpose 1.3 Application 1.4 Conflicts 1.5 Retroactivity 1.6 Equivalency 1.7 Units and Formulas Chapter 2 Referenced Publications 2.1 General 2.2 NFPA Publications. 2.3 Other Publications 2.4 References for Extracts in Mandatory Sections Chapter 3 Definitions Committees should align with 652 definitons Chapter 4 General Requirements 4.1* General 4.2 Objectives Life Safety 4.2.2* Mission Continuity Mitigation of Fire Spread and Explosions Chapter 5 Hazard Identification 5.1* Responsibility 5.2 Overview Screening for Combustibility and Explosibility 5.3* Self-Heating and Reactivity Hazards (Reserved) 5.4 Combustibility and Explosibility Tests 5.4.1* Determination of Combustibility

31 5.4.2 Determination of Flash Fire Hazard (Reserved) Determination of Explosibility Quantification of Combustibility and Explosibility Characteristics 5.5 Sampling Sampling Plan Mixtures Representative Samples Chapter 6 Performance-Based Design Option 6.1* General Requirements Approved Qualifications 6.1.2* Document Requirements Sources of Data 6.1.5* Maintenance of the Design Features 6.2 Risk Component and Acceptability (Reserved) 6.3 Performance Criteria Life Safety Structural Integrity Mission Continuity Mitigation of Fire Spread and Explosions Effects of Explosions 6.4* Design Scenarios Fire Scenarios Explosion Scenarios 6.5 Evaluation of Proposed Design Chapter 7 Dust Hazard Analysis 7.1* General Requirements Responsibility 7.2 Criteria 7.2.1* Overview 7.2.2* Qualifications Documentation 7.3 Methodology General Material Evaluation Process Systems Facility Compartments

32 Chapter 8 Hazard Management: Mitigation and Prevention 8.1 Inherently Safe Designs (Reserved) 8.2 Building Design 8.2.1* Construction Building/Room Protection Life Safety Separation of Hazard Areas from Other Hazard Areas and from Other Occupancies 8.3 Equipment Design 8.3.1* Risk Assessment 8.3.2* Design for Dust Containment 8.3.3* Pneumatic Conveying, Dust Collection, and Centralized Vacuum Cleaning Systems AMS Locations Recycle of AMS Clean Air Exhaust AMS Transfer Points (Reserved) 8.4 Housekeeping General 8.4.2* Methodology Training Equipment (Reserved) Vacuum Trucks Frequency and Goal Auditing and Documentation 8.5 Ignition Source Control 8.5.1* General 8.5.2* Risk Assessment Hot Work Bearings Electrical Equipment and Wiring Electrostatic Discharges Open Flames and Fuel Fired Equipment Industrial Trucks Process Air and Media Temperatures Self-Heating Friction and Impact Sparks 8.6 Personal Protective Equipment Workplace Hazard Assessment

33 8.6.2 Limitations of PPE Application (Flame- Resistant Garments) Limitations of PPE to Combustible Dust Flash-Fires (Reserved) Face, Hands, and Footwear Protection (Reserved) 8.x Pyrophoric Dusts (Reserved) 8.7 Dust Control 8.7.2* Liquid Dust Suppression Methods for Dust Control Fans to Limit Accumulation (Reserved) 8.8 Explosion Prevention/Protection General Risk Assessment Equipment Protection Equipment Isolation 8.9 Fire Protection General Fire Extinguishers Hose, Standpipes, Hydrants, and Water Supply Automatic Sprinklers Spark/Ember Detection and Extinguishing Systems Special Fire Protection Systems Chapter 9 Management Systems 9.1 Retroactivity 9.2* General 9.3 Operating Procedures and Practices 9.4 Inspection, Testing, and Maintenance 9.5 Training and Hazard Awareness 9.6 Contractors 9.6.3* Contractor Training 9.7 Emergency Planning and Response 9.8* Incident Investigation 9.9 Management of Change 9.10* Documentation Retention 9.11 Management Systems Review 9.12* Employee Participation

34 National Fire Protection Association Report of /21/2015 3:09 PM Correlating Committee Note No. 4-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Thu Jan 08 19:30:29 EST 2015 Committee Statement Committee Statement: The 61 technical committee should review the document to ensure that retroactivity is handled consistently with the other combustible dust documents. Those sections that are to be applied retroactively should be explicitly designated in the document section. Typically, management system elements that do not require capital improvements, such as training and housekeeping, are retroactive. This comment is also being made to the 654 and 664 technical committees and will be made to the 655 and the 484 technical committees as they go through their next revision cycle.

35 National Fire Protection Association Report of /21/2015 3:09 PM Correlating Committee Note No. 5-NFPA [ Global Input ] Supplemental Information File Name Draft_Objectives_for_CC_review.docx Description Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Thu Jan 08 19:31:48 EST 2015 Committee Statement Committee Statement: The 61 committee should consider aligning their objectives with those presented in attached document developed by the correlating committee task group on objectives. The correlating committee would like to work towards having all of the dust documents have similar objectives. This document is a product of a task group with representation from all of the combustible dust committees and represents the direction the correlating committee would like to head in. This recommendation is also being made to the 654 and the 664 technical committees, and will be made to the 484, 655, and 652 technical committees as they enter the next revision cycle.

36 NFPA 652 Draft Objectives for CC review (product of the objectives task group) 4.2 Objectives The design of the facility, processes and equipment shall be based upon the goal of providing a reasonable level of safety and property protection by meeting the following objectives: 1.) Life Safety 2.) Mission Continuity 3.) Mitigation of Fire Spread and Explosions The objectives stated in Section 4.2 shall be interpreted as intended outcomes of this standard and not as prescriptive requirements The objectives stated in Section 4.2 shall be deemed to be met when, consistent with the goal in Section and the provisions in Sections 1.4 and 1.6, 1.) the facility, processes and equipment are designed, constructed and maintained in accordance with the prescriptive criteria set forth in this standard, and 2.) The management systems set forth in this standard are implemented Where a performance-based alternative design is used, it shall be documented to meet the same objectives as the prescriptive design it replaces, in accordance with Chapter 6 of this standard Life Safety. The life safety objective shall be deemed to have been met when, consistent with the goal in Section and the provisions in Sections 1.4 and 1.6, the occupants not in the immediate proximity of the ignition are protected from the effects of fires, flash-fires, and explosions for the time needed to evacuate, relocate, or take refuge in order to prevent serious injury * Mission Continuity. The mission continuity objective shall be deemed to have been met when, consistent with the goal in Section and the provisions in Sections 1.4 and 1.6, the protection features for the facility, processes and equipment limit damage to levels that ensure the ongoing mission, production, or operating capability of the facility to a degree acceptable to the owner/operator. A Other stakeholders could also have mission continuity goals that will necessitate more stringent objectives as well as more specific and demanding performance criteria. The protection of property beyond maintaining structural integrity long enough to escape is actually a mission continuity objective.

37 The mission continuity objective encompasses the survival of both real property, such as the building, and the production equipment and inventory beyond the extinguishment of the fire. Traditionally, property protection objectives have addressed the impact of the fire on structural elements of a building as well as the equipment and contents inside a building. Mission continuity is concerned with the ability of a structure to perform its intended functions and with how that affects the structure's tenants. It often addresses post-fire smoke contamination, cleanup, and replacement of damaged equipment or raw materials * Mitigation of Fire Spread and Explosions. The mitigation of fire spread and explosions shall be deemed to have been met when, consistent with the goal in Section and the provisions in Sections 1.4 and 1.6, the prescribed or performance based alternative design features are incorporated into the facility and processes to prevent or mitigate fires and explosions that can cause failure of adjacent buildings or building compartments, or other enclosures, emergency life safety systems, adjacent properties, adjacent storage, or the facility's structural elements. A Adjacent compartments share a common enclosure surface (wall, ceiling, floor) with the compartment of fire or explosion origin. The intent is to prevent the collapse of the structure during the fire or explosion Where a dust fire, deflagration, or explosion hazard exists within a process system, the hazards shall be managed in accordance with this standard Where a dust fire, deflagration, or explosion hazard exists with a facility compartment, the effects of the fire, deflagration, or explosion shall be managed in accordance with this standard * Compliance Options. The objectives in Section 4.2 shall be achieved by either of the following means: 1. A prescriptive approach in accordance with Chapters 5, 7, 8, and 9 in conjunction with any additional prescriptive provisions of applicable commodityspecific NFPA standards. 2. A performance-based approach in accordance with Chapter 6. A Usually a facility or process system is designed using the prescriptive criteria until a prescribed solution is found to be infeasible or impracticable. Then the designer can use the performance-based option to develop a design, addressing the full range of fire and explosion scenarios and the impact on other prescribed design features. Consequently, facilities are usually designed not by using performance-based design methods for all facets of the facility but rather by using a mixture of both design approaches as needed.

38 National Fire Protection Association Report 0 of 15 1/21/2015 3:09 PM Correlating Committee Note No. 6-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Thu Jan 08 19:51:07 EST 2015 Committee Statement Committee Statement: The correlating committee recommends that the 61 technical committee review the exceptions for bucket elevators with capacities less than 106 m3/hr (3750 ft3/hr) found in sections , , and The 61 committee should provide technical justification for these exceptions or remove them. Note that these exceptions have been removed from NFPA 654.

39 National Fire Protection Association Report 1 of 15 1/21/2015 3:09 PM Correlating Committee Note No. 11-NFPA [ New Section after ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Thu Jan 08 20:15:11 EST 2015 Committee Statement Committee Statement: The Correlating Committee recommends that the 61 technical committee consider including segregation and detachment as management strategies for consistency with the other combustible dust documents. In addition to including the other two management strategies, the 61 technical committee should include the definitions for these terms, as extracted from NFPA 652, in Chapter 3 of NFPA 61.

40 National Fire Protection Association Report 2 of 15 1/21/2015 3:09 PM Correlating Committee Note No. 9-NFPA [ Section No ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Thu Jan 08 20:08:30 EST 2015 Committee Statement Committee Statement: The correlating committee recommends that the 61 technical committee review the use of the term fire-resistance in this section. 654 made several first revisions changing the term fire-resistance rating to fire-protection rating for doors. The 61 committee should review the changes in 654 and ensure that it used the proper term throughout the document. This is a correlating issue between the documents.

41 National Fire Protection Association Report 3 of 15 1/21/2015 3:09 PM Correlating Committee Note No. 10-NFPA [ Section No. 6.2 ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Thu Jan 08 20:11:57 EST 2015 Committee Statement Committee Statement: The Correlating Committee recommends that the 61 technical committee review the use of the term "combustion explosion" in this section. This terminology is not consistent with those used throughout the other combustible dust standards.

42 National Fire Protection Association Report 4 of 15 1/21/2015 3:09 PM Correlating Committee Note No. 7-NFPA [ Section No ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Thu Jan 08 19:58:21 EST 2015 Committee Statement Committee Statement: The 61 technical committee should review FR-18 in light of the negative comments, specifically those that suggest that the provisions conflict with those in NFPA 68. First Revision No. 18-NFPA [Section No ]

43 National Fire Protection Association Report 5 of 15 1/21/2015 3:09 PM Correlating Committee Note No. 8-NFPA [ New Section after ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Thu Jan 08 20:00:22 EST 2015 Committee Statement Committee Statement: The Correlating Committee recommends that the 61 technical committee review its action relating to FR-50. The proposed text does not meet the standard of care established by the other combustible dust documents such as NFPA 652 and 654 with regards to dust hazard analysis (DHA). The Correlating Committee recognizes the work of the 61 technical committee. It is aware that the committee has a task group that is working on this issue for the second draft. The Correlating Committee encourages the 61 technical committee to review the material in NFPA 652 and strive to work towards the goals and objectives addressed in chapters 5 and 7 of NFPA 652. First Revision No. 50-NFPA [New Section after 13.11]

44 National Fire Protection Association Report of /21/2015 2:47 PM Correlating Committee Note No. 12-NFPA [ Global Input ] Supplemental Information File Name Draft_Objectives_for_CC_review.docx Description Submitter Information Verification Submitter Full Name: Susan Bershad Organization: National Fire Protection Assoc Street Address: City: State: Zip: Submittal Date: Wed Jan 07 16:55:15 EST 2015 Committee Statement Committee Statement: The 654 committee should consider aligning their objectives with those presented in attached document developed by the correlating committee task group on objectives. The correlating committee would like to work towards having all of the dust documents have similar objectives. This document is a product of a task group with representation from all of the combustible dust committees and represents the direction the correlating committee would like to head in. This recommendation is also being made to the 61 and the 664 technical committees, and will be made to the 484, 655, and 652 technical committees as they enter the next revision cycle.

45 NFPA 652 Draft Objectives for CC review (product of the objectives task group) 4.2 Objectives The design of the facility, processes and equipment shall be based upon the goal of providing a reasonable level of safety and property protection by meeting the following objectives: 1.) Life Safety 2.) Mission Continuity 3.) Mitigation of Fire Spread and Explosions The objectives stated in Section 4.2 shall be interpreted as intended outcomes of this standard and not as prescriptive requirements The objectives stated in Section 4.2 shall be deemed to be met when, consistent with the goal in Section and the provisions in Sections 1.4 and 1.6, 1.) the facility, processes and equipment are designed, constructed and maintained in accordance with the prescriptive criteria set forth in this standard, and 2.) The management systems set forth in this standard are implemented Where a performance-based alternative design is used, it shall be documented to meet the same objectives as the prescriptive design it replaces, in accordance with Chapter 6 of this standard Life Safety. The life safety objective shall be deemed to have been met when, consistent with the goal in Section and the provisions in Sections 1.4 and 1.6, the occupants not in the immediate proximity of the ignition are protected from the effects of fires, flash-fires, and explosions for the time needed to evacuate, relocate, or take refuge in order to prevent serious injury * Mission Continuity. The mission continuity objective shall be deemed to have been met when, consistent with the goal in Section and the provisions in Sections 1.4 and 1.6, the protection features for the facility, processes and equipment limit damage to levels that ensure the ongoing mission, production, or operating capability of the facility to a degree acceptable to the owner/operator. A Other stakeholders could also have mission continuity goals that will necessitate more stringent objectives as well as more specific and demanding performance criteria. The protection of property beyond maintaining structural integrity long enough to escape is actually a mission continuity objective.

46 The mission continuity objective encompasses the survival of both real property, such as the building, and the production equipment and inventory beyond the extinguishment of the fire. Traditionally, property protection objectives have addressed the impact of the fire on structural elements of a building as well as the equipment and contents inside a building. Mission continuity is concerned with the ability of a structure to perform its intended functions and with how that affects the structure's tenants. It often addresses post-fire smoke contamination, cleanup, and replacement of damaged equipment or raw materials * Mitigation of Fire Spread and Explosions. The mitigation of fire spread and explosions shall be deemed to have been met when, consistent with the goal in Section and the provisions in Sections 1.4 and 1.6, the prescribed or performance based alternative design features are incorporated into the facility and processes to prevent or mitigate fires and explosions that can cause failure of adjacent buildings or building compartments, or other enclosures, emergency life safety systems, adjacent properties, adjacent storage, or the facility's structural elements. A Adjacent compartments share a common enclosure surface (wall, ceiling, floor) with the compartment of fire or explosion origin. The intent is to prevent the collapse of the structure during the fire or explosion Where a dust fire, deflagration, or explosion hazard exists within a process system, the hazards shall be managed in accordance with this standard Where a dust fire, deflagration, or explosion hazard exists with a facility compartment, the effects of the fire, deflagration, or explosion shall be managed in accordance with this standard * Compliance Options. The objectives in Section 4.2 shall be achieved by either of the following means: 1. A prescriptive approach in accordance with Chapters 5, 7, 8, and 9 in conjunction with any additional prescriptive provisions of applicable commodityspecific NFPA standards. 2. A performance-based approach in accordance with Chapter 6. A Usually a facility or process system is designed using the prescriptive criteria until a prescribed solution is found to be infeasible or impracticable. Then the designer can use the performance-based option to develop a design, addressing the full range of fire and explosion scenarios and the impact on other prescribed design features. Consequently, facilities are usually designed not by using performance-based design methods for all facets of the facility but rather by using a mixture of both design approaches as needed.

47 National Fire Protection Association Report of /21/2015 2:47 PM Correlating Committee Note No. 13-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: National Fire Protection Assoc Street Address: City: State: Zip: Submittal Date: Wed Jan 07 17:09:33 EST 2015 Committee Statement Committee Statement: The correlating committee recommends that the 654 technical committee review and update if necessary, Annex B and C of the document. Both are extracted into 664 and neither has been updated over the past several revision cycles. They may be more recent material that could be incorporated into both annexes. It is understood that this may not take place until the next revision cycle for 654.

48 National Fire Protection Association Report of /21/2015 2:47 PM Correlating Committee Note No. 15-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: National Fire Protection Assoc Street Address: City: State: Zip: Submittal Date: Thu Jan 08 19:35:42 EST 2015 Committee Statement Committee Statement: The 654 technical committee should consider adding the language in the first draft of NFPA 61 on conflicts, section and section Where a requirement specified in this industry-specific standard differs from a requirement specified in NFPA 652, the requirement in this standard shall be permitted to be used instead Where a requirement specified in this standard specifically prohibits a requirement specified in NFPA 652, the prohibition in this standard shall be permitted. The Correlating Committee believes that adding this to 654 would provide clarity to the user of the document. This recommendation is also being made to the 664 technical committee and will be made to the 484 and the 655 technical committees as they enter their revisions cycles.

49 National Fire Protection Association Report of /21/2015 2:47 PM Correlating Committee Note No. 16-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: National Fire Protection Assoc Street Address: City: State: Zip: Submittal Date: Mon Jan 12 10:20:15 EST 2015 Committee Statement Committee Statement: The correlating committee recommends that the 654 technical committee revise the scope of the document to be consistent with the structure of the scope statement in NFPA 61. This scope states the "standard provides requirements...". The correlating committee is working towards aligning the scope statements in all of the dust document to be consistent. This recommendation is also being made to the 664 TC and the 484 and 655 technical committees as they enter their revision cycles.

50 National Fire Protection Association Report of /21/2015 2:47 PM Correlating Committee Note No. 2-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Tue Jan 06 18:28:34 EST 2015 Committee Statement Committee Statement: The 654 technical committee should review the responses to PI - 72, 73, 74, 75, 78, and 81. The terms defined in some of these public inputs are used in 654. Even if the terms are defined in 652, the 654 technical committee should reconsider whether or not these definitions should be included in 654. It may be easier for the user if the terms are also defined in 654.

51 National Fire Protection Association Report of /21/2015 2:47 PM Correlating Committee Note No. 3-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Tue Jan 06 18:33:04 EST 2015 Committee Statement Committee Statement: The 654 technical committee should review the definitions in Chapter 3 for consistency with 652. The definitions in Chapter 3 of 652 should be considered a baseline for those in the other dust documents. In some cases, the occupancy specific document may elect to define a term differently. In those cases, the rationale for the differences should be documented. Note that this comment is also being made to the 61 and the 664 technical committees, and will be made to the 655 and 484 committees as they go through their next revision cycle.

52 National Fire Protection Association Report of /21/2015 2:47 PM Correlating Committee Note No. 4-NFPA [ Global Input ] Supplemental Information File Name 652_outline_CC_meeting.docx Description Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Tue Jan 06 18:39:04 EST 2015 Committee Statement Committee Statement: The 654 technical committee should review the layout of the document for consistency with NFPA 652. The chapter layout for the commodity specific standards should align with the layout of NFPA 652 in order to facilitate their use with NFPA 652 in accordance with section of NFPA 652. This comment is also being made to the 61 and 664 technical committees, and will be made to the 655 and 484 technical committees as they go through the next revision cycle. The Correlating Committee is providing an outline taken from 652 to assist the commodity specific committees with their expected alignment to 652 over the next revision cycles. In addition the outline includes the level of subsection that a user would use to compare 652 to an industry specific standard. This is the minimum level of alignment expected, the committee is free to go beyond this level. Note that the highlighted sections are those that should be used. It is expected that this may not be able to be completed in the current revision cycle, but this a goal that committees should work toward.

53 652 Chapter 1 Administration 1.1 Scope 1.2 Purpose 1.3 Application 1.4 Conflicts 1.5 Retroactivity 1.6 Equivalency 1.7 Units and Formulas Chapter 2 Referenced Publications 2.1 General 2.2 NFPA Publications. 2.3 Other Publications 2.4 References for Extracts in Mandatory Sections Chapter 3 Definitions Committees should align with 652 definitions Chapter 4 General Requirements 4.1* General 4.2 Objectives Life Safety 4.2.2* Mission Continuity Mitigation of Fire Spread and Explosions Chapter 5 Hazard Identification 5.1* Responsibility 5.2 Overview Screening for Combustibility and Explosibility 5.3* Self-Heating and Reactivity Hazards (Reserved) 5.4 Combustibility and Explosibility Tests 5.4.1* Determination of Combustibility

54 5.4.2 Determination of Flash Fire Hazard (Reserved) Determination of Explosibility Quantification of Combustibility and Explosibility Characteristics 5.5 Sampling Sampling Plan Mixtures Representative Samples Chapter 6 Performance-Based Design Option 6.1* General Requirements Approved Qualifications 6.1.2* Document Requirements Sources of Data 6.1.5* Maintenance of the Design Features 6.2 Risk Component and Acceptability (Reserved) 6.3 Performance Criteria Life Safety Structural Integrity Mission Continuity Mitigation of Fire Spread and Explosions Effects of Explosions 6.4* Design Scenarios Fire Scenarios Explosion Scenarios 6.5 Evaluation of Proposed Design Chapter 7 Dust Hazard Analysis 7.1* General Requirements Responsibility 7.2 Criteria 7.2.1* Overview 7.2.2* Qualifications Documentation 7.3 Methodology General Material Evaluation Process Systems Facility Compartments

55 Chapter 8 Hazard Management: Mitigation and Prevention 8.1 Inherently Safe Designs (Reserved) 8.2 Building Design 8.2.1* Construction Building/Room Protection Life Safety Separation of Hazard Areas from Other Hazard Areas and from Other Occupancies 8.3 Equipment Design 8.3.1* Risk Assessment 8.3.2* Design for Dust Containment 8.3.3* Pneumatic Conveying, Dust Collection, and Centralized Vacuum Cleaning Systems AMS Locations Recycle of AMS Clean Air Exhaust AMS Transfer Points (Reserved) 8.4 Housekeeping General 8.4.2* Methodology Training Equipment (Reserved) Vacuum Trucks Frequency and Goal Auditing and Documentation 8.5 Ignition Source Control 8.5.1* General 8.5.2* Risk Assessment Hot Work Bearings Electrical Equipment and Wiring Electrostatic Discharges Open Flames and Fuel Fired Equipment Industrial Trucks Process Air and Media Temperatures Self-Heating Friction and Impact Sparks 8.6 Personal Protective Equipment Workplace Hazard Assessment

56 8.6.2 Limitations of PPE Application (Flame- Resistant Garments) Limitations of PPE to Combustible Dust Flash-Fires (Reserved) Face, Hands, and Footwear Protection (Reserved) 8.x Pyrophoric Dusts (Reserved) 8.7 Dust Control 8.7.2* Liquid Dust Suppression Methods for Dust Control Fans to Limit Accumulation (Reserved) 8.8 Explosion Prevention/Protection General Risk Assessment Equipment Protection Equipment Isolation 8.9 Fire Protection General Fire Extinguishers Hose, Standpipes, Hydrants, and Water Supply Automatic Sprinklers Spark/Ember Detection and Extinguishing Systems Special Fire Protection Systems Chapter 9 Management Systems 9.1 Retroactivity 9.2* General 9.3 Operating Procedures and Practices 9.4 Inspection, Testing, and Maintenance 9.5 Training and Hazard Awareness 9.6 Contractors 9.6.3* Contractor Training 9.7 Emergency Planning and Response 9.8* Incident Investigation 9.9 Management of Change 9.10* Documentation Retention 9.11 Management Systems Review 9.12* Employee Participation

57 National Fire Protection Association Report of /21/2015 2:47 PM Correlating Committee Note No. 5-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Tue Jan 06 18:44:59 EST 2015 Committee Statement Committee Statement: The 654 technical committee should consider referring to Chapter 5 of 652 for testing requirements for combustible dusts. This could be done by a reference to 652 or by extracting the material in Chapter 5 of 652 into 654.

58 National Fire Protection Association Report of /21/2015 2:47 PM Correlating Committee Note No. 8-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Tue Jan 06 19:15:20 EST 2015 Committee Statement Committee Statement: The 654 technical committee should review the document to ensure that retroactivity is handled consistently. Those sections that are to be applied retroactively should be explicitly designated in the document section. Typically, management system elements that do not require capital improvements, such as training and housekeeping, are retroactive. This comment is also being made to the 61 and 664 technical committees and will be made to the 655 and the 484 technical committees as they go through their next revision cycle.

59 National Fire Protection Association Report 0 of 15 1/21/2015 2:47 PM Correlating Committee Note No. 7-NFPA [ Section No ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Tue Jan 06 19:04:00 EST 2015 Committee Statement Committee Statement: The 654 technical committee should consider adding the term "flash fire" to fire and explosion hazard in this section. This would make the scope, section 1.1.1, consistent with the purpose, section The 654 technical committee should also review the rest of the document to ensure that these terms are used consistently.

60 National Fire Protection Association Report 1 of 15 1/21/2015 2:47 PM Correlating Committee Note No. 11-NFPA [ Section No. 1.4 ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Tue Jan 06 19:31:30 EST 2015 Committee Statement Committee Statement: The 654 technical committee should consider whether or not the annex material that was added as part of FR-2 is relevant to this section. It appears to be more appropriate to 652.

61 National Fire Protection Association Report 2 of 15 1/21/2015 2:47 PM Correlating Committee Note No. 9-NFPA [ Sections 4.3, 4.4 ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Tue Jan 06 19:21:10 EST 2015 Committee Statement Committee Statement: The 654 technical committee should compare Sections 4.3 and 4.4, Management of Change and Incident Investigation, to the analogous sections in 652. The committee should determine if any additions or omissions between the two documents are intentional or an oversight. An effort should be made to more closely align the two documents.

62 National Fire Protection Association Report 3 of 15 1/21/2015 2:47 PM Correlating Committee Note No. 6-NFPA [ Section No ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Tue Jan 06 18:56:50 EST 2015 Committee Statement Committee Statement: The 654 committee should review FR-27 as to whether or not other additional test methods should be included as part of this requirement. As a minimum, ASTM E 152, Standard Method of Fire Tests For Door Assemblies and FM Approvals Class 4100, Approval Standard for Fire Doors, as noted in the negative comments on the ballot, should be considered.

63 National Fire Protection Association Report 4 of 15 1/21/2015 2:47 PM Correlating Committee Note No. 10-NFPA [ Section No ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Tue Jan 06 19:25:41 EST 2015 Committee Statement Committee Statement: The 654 technical committee should consider revising (5) in FR-37 to include enforceable language as per the NFPA manual of style. Note that this comment was made by several committee members on the ballot.

64 National Fire Protection Association Report 5 of 15 1/21/2015 2:47 PM Correlating Committee Note No. 14-NFPA [ Section No ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: National Fire Protection Assoc Street Address: City: State: Zip: Submittal Date: Thu Jan 08 19:10:10 EST 2015 Committee Statement Committee Statement: The 654 technical committee should review this section in light of the response by the NFPA technical committee to PI-52 submitted to NFPA 61. PI-52 proposed to extract this requirement from 654 into 61. The NFPA 61 committee stated that: "The committee is not sure that a design that meets this requirement exists. The committee does not want to leave this as a potential requirement without additional information."

65 National Fire Protection Association Report of /21/2015 2:59 PM Correlating Committee Note No. 1-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Wed Jan 07 16:43:35 EST 2015 Committee Statement Committee Statement: The 664 technical committee should review the definitions in Chapter 3 for consistency with 652. The definitions in Chapter 3 of 652 should be considered a baseline for those in the other dust documents. In some cases, the occupancy specific document may elect to define a term differently. In those cases, the rationale for the differences should be documented. Note that this comment is also being made to the 61 and the 654 technical committees, and will be made to the 655 and 484 committees as they go through their next revision cycle.

66 National Fire Protection Association Report of /21/2015 2:59 PM Correlating Committee Note No. 13-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: National Fire Protection Assoc Street Address: City: State: Zip: Submittal Date: Thu Jan 08 19:38:41 EST 2015 Committee Statement Committee Statement: The 664 technical committee should consider adding the language in the first draft of NFPA 61 on conflicts, section and section Where a requirement specified in this industry-specific standard differs from a requirement specified in NFPA 652, the requirement in this standard shall be permitted to be used instead Where a requirement specified in this standard specifically prohibits a requirement specified in NFPA 652, the prohibition in this standard shall be permitted. The Correlating Committee believes that adding this to 664 would provide clarity to the user of the document. This recommendation is also being made to the 654 technical committee and will be made to the 484 and the 655 technical committees as they enter their revisions cycles.

67 National Fire Protection Association Report of /21/2015 2:59 PM Correlating Committee Note No. 16-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: National Fire Protection Assoc Street Address: City: State: Zip: Submittal Date: Thu Jan 08 20:38:31 EST 2015 Committee Statement Committee Statement: The Correlating Committee recommends that the 664 TC consider pointing the user in the direction of NFPA 87 for guidance on heat transfer systems. This may be best accomplished through the addition of annex material

68 National Fire Protection Association Report of /21/2015 2:59 PM Correlating Committee Note No. 17-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: National Fire Protection Assoc Street Address: City: State: Zip: Submittal Date: Fri Jan 09 10:45:30 EST 2015 Committee Statement Committee Statement: The 664 technical committee should consider including the language in Section of NFPA This standard shall be used to supplement the requirements established by NFPA 652. This clarifies the relationship between 652 and the commodity-specific standards.

69 National Fire Protection Association Report of /21/2015 2:59 PM Correlating Committee Note No. 2-NFPA [ Global Input ] Supplemental Information File Name 652_outline_CC_meeting.docx Description Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Wed Jan 07 16:45:03 EST 2015 Committee Statement Committee Statement: The 664 technical committee should review the layout of the document for consistency with NFPA 652. The chapter layout for the commodity specific standards should align with the layout of NFPA 652 in order to facilitate their use with NFPA 652 in accordance with section of NFPA 652. This comment is also being made to the 654 and 61 technical committees, and will be made to the 655 and 484 technical committees as they go through the next revision cycle. The Correlating Committee is providing an outline taken from 652 to assist the commodity specific committees with their expected alignment to 652 over the next revision cycles. In addition the outline includes the level of subsection that a user would use to compare 652 to an industry specific standard. This is the minimum level of alignment expected, the committee is free to go beyond this level. Note that the highlighted sections are those that should be used. It is expected that this may not be able to be completed in the current revision cycle, but this a goal that committees should work toward.

70 652 Chapter 1 Administration 1.1 Scope 1.2 Purpose 1.3 Application 1.4 Conflicts 1.5 Retroactivity 1.6 Equivalency 1.7 Units and Formulas Chapter 2 Referenced Publications 2.1 General 2.2 NFPA Publications. 2.3 Other Publications 2.4 References for Extracts in Mandatory Sections Chapter 3 Definitions Committees should align with 652 definitions Chapter 4 General Requirements 4.1* General 4.2 Objectives Life Safety 4.2.2* Mission Continuity Mitigation of Fire Spread and Explosions Chapter 5 Hazard Identification 5.1* Responsibility 5.2 Overview Screening for Combustibility and Explosibility 5.3* Self-Heating and Reactivity Hazards (Reserved) 5.4 Combustibility and Explosibility Tests 5.4.1* Determination of Combustibility

71 5.4.2 Determination of Flash Fire Hazard (Reserved) Determination of Explosibility Quantification of Combustibility and Explosibility Characteristics 5.5 Sampling Sampling Plan Mixtures Representative Samples Chapter 6 Performance-Based Design Option 6.1* General Requirements Approved Qualifications 6.1.2* Document Requirements Sources of Data 6.1.5* Maintenance of the Design Features 6.2 Risk Component and Acceptability (Reserved) 6.3 Performance Criteria Life Safety Structural Integrity Mission Continuity Mitigation of Fire Spread and Explosions Effects of Explosions 6.4* Design Scenarios Fire Scenarios Explosion Scenarios 6.5 Evaluation of Proposed Design Chapter 7 Dust Hazard Analysis 7.1* General Requirements Responsibility 7.2 Criteria 7.2.1* Overview 7.2.2* Qualifications Documentation 7.3 Methodology General Material Evaluation Process Systems Facility Compartments

72 Chapter 8 Hazard Management: Mitigation and Prevention 8.1 Inherently Safe Designs (Reserved) 8.2 Building Design 8.2.1* Construction Building/Room Protection Life Safety Separation of Hazard Areas from Other Hazard Areas and from Other Occupancies 8.3 Equipment Design 8.3.1* Risk Assessment 8.3.2* Design for Dust Containment 8.3.3* Pneumatic Conveying, Dust Collection, and Centralized Vacuum Cleaning Systems AMS Locations Recycle of AMS Clean Air Exhaust AMS Transfer Points (Reserved) 8.4 Housekeeping General 8.4.2* Methodology Training Equipment (Reserved) Vacuum Trucks Frequency and Goal Auditing and Documentation 8.5 Ignition Source Control 8.5.1* General 8.5.2* Risk Assessment Hot Work Bearings Electrical Equipment and Wiring Electrostatic Discharges Open Flames and Fuel Fired Equipment Industrial Trucks Process Air and Media Temperatures Self-Heating Friction and Impact Sparks 8.6 Personal Protective Equipment Workplace Hazard Assessment

73 8.6.2 Limitations of PPE Application (Flame- Resistant Garments) Limitations of PPE to Combustible Dust Flash-Fires (Reserved) Face, Hands, and Footwear Protection (Reserved) 8.x Pyrophoric Dusts (Reserved) 8.7 Dust Control 8.7.2* Liquid Dust Suppression Methods for Dust Control Fans to Limit Accumulation (Reserved) 8.8 Explosion Prevention/Protection General Risk Assessment Equipment Protection Equipment Isolation 8.9 Fire Protection General Fire Extinguishers Hose, Standpipes, Hydrants, and Water Supply Automatic Sprinklers Spark/Ember Detection and Extinguishing Systems Special Fire Protection Systems Chapter 9 Management Systems 9.1 Retroactivity 9.2* General 9.3 Operating Procedures and Practices 9.4 Inspection, Testing, and Maintenance 9.5 Training and Hazard Awareness 9.6 Contractors 9.6.3* Contractor Training 9.7 Emergency Planning and Response 9.8* Incident Investigation 9.9 Management of Change 9.10* Documentation Retention 9.11 Management Systems Review 9.12* Employee Participation

74 National Fire Protection Association Report of /21/2015 2:59 PM Correlating Committee Note No. 3-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Wed Jan 07 16:46:41 EST 2015 Committee Statement Committee Statement: The 664 technical committee should review the document to ensure that retroactivity is handled consistently. Those sections that are to be applied retroactively should be explicitly designated in the document section. Typically, management system elements that do not require capital improvements, such as training and housekeeping, are retroactive. This comment is also being made to the 61 and 654 technical committees and will be made to the 655 and the 484 technical committees as they go through their next revision cycle

75 National Fire Protection Association Report of /21/2015 2:59 PM Correlating Committee Note No. 4-NFPA [ Global Input ] Supplemental Information File Name Draft_Objectives_for_CC_review.docx Description Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Wed Jan 07 17:00:45 EST 2015 Committee Statement Committee Statement: The 664 committee should consider aligning their objectives with those presented in attached document developed by the correlating committee task group on objectives. The correlating committee would like to work towards having all of the dust documents have similar objectives. This document is a product of a task group with representation from all of the combustible dust committees and represents the direction the correlating committee would like to head in. This recommendation is also being made to the 61 and the 654 technical committees, and will be made to the 484, 655, and 652 technical committees as they enter the next revision cycle.

76 NFPA 652 Draft Objectives for CC review (product of the objectives task group) 4.2 Objectives The design of the facility, processes and equipment shall be based upon the goal of providing a reasonable level of safety and property protection by meeting the following objectives: 1.) Life Safety 2.) Mission Continuity 3.) Mitigation of Fire Spread and Explosions The objectives stated in Section 4.2 shall be interpreted as intended outcomes of this standard and not as prescriptive requirements The objectives stated in Section 4.2 shall be deemed to be met when, consistent with the goal in Section and the provisions in Sections 1.4 and 1.6, 1.) the facility, processes and equipment are designed, constructed and maintained in accordance with the prescriptive criteria set forth in this standard, and 2.) The management systems set forth in this standard are implemented Where a performance-based alternative design is used, it shall be documented to meet the same objectives as the prescriptive design it replaces, in accordance with Chapter 6 of this standard Life Safety. The life safety objective shall be deemed to have been met when, consistent with the goal in Section and the provisions in Sections 1.4 and 1.6, the occupants not in the immediate proximity of the ignition are protected from the effects of fires, flash-fires, and explosions for the time needed to evacuate, relocate, or take refuge in order to prevent serious injury * Mission Continuity. The mission continuity objective shall be deemed to have been met when, consistent with the goal in Section and the provisions in Sections 1.4 and 1.6, the protection features for the facility, processes and equipment limit damage to levels that ensure the ongoing mission, production, or operating capability of the facility to a degree acceptable to the owner/operator. A Other stakeholders could also have mission continuity goals that will necessitate more stringent objectives as well as more specific and demanding performance criteria. The protection of property beyond maintaining structural integrity long enough to escape is actually a mission continuity objective.

77 The mission continuity objective encompasses the survival of both real property, such as the building, and the production equipment and inventory beyond the extinguishment of the fire. Traditionally, property protection objectives have addressed the impact of the fire on structural elements of a building as well as the equipment and contents inside a building. Mission continuity is concerned with the ability of a structure to perform its intended functions and with how that affects the structure's tenants. It often addresses post-fire smoke contamination, cleanup, and replacement of damaged equipment or raw materials * Mitigation of Fire Spread and Explosions. The mitigation of fire spread and explosions shall be deemed to have been met when, consistent with the goal in Section and the provisions in Sections 1.4 and 1.6, the prescribed or performance based alternative design features are incorporated into the facility and processes to prevent or mitigate fires and explosions that can cause failure of adjacent buildings or building compartments, or other enclosures, emergency life safety systems, adjacent properties, adjacent storage, or the facility's structural elements. A Adjacent compartments share a common enclosure surface (wall, ceiling, floor) with the compartment of fire or explosion origin. The intent is to prevent the collapse of the structure during the fire or explosion Where a dust fire, deflagration, or explosion hazard exists within a process system, the hazards shall be managed in accordance with this standard Where a dust fire, deflagration, or explosion hazard exists with a facility compartment, the effects of the fire, deflagration, or explosion shall be managed in accordance with this standard * Compliance Options. The objectives in Section 4.2 shall be achieved by either of the following means: 1. A prescriptive approach in accordance with Chapters 5, 7, 8, and 9 in conjunction with any additional prescriptive provisions of applicable commodityspecific NFPA standards. 2. A performance-based approach in accordance with Chapter 6. A Usually a facility or process system is designed using the prescriptive criteria until a prescribed solution is found to be infeasible or impracticable. Then the designer can use the performance-based option to develop a design, addressing the full range of fire and explosion scenarios and the impact on other prescribed design features. Consequently, facilities are usually designed not by using performance-based design methods for all facets of the facility but rather by using a mixture of both design approaches as needed.

78 National Fire Protection Association Report of /21/2015 2:59 PM Correlating Committee Note No. 5-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Wed Jan 07 17:05:41 EST 2015 Committee Statement Committee Statement: The correlating committee recommends that the 664 TC review their response to PI -2 and PI-24 based on CN #4

79 National Fire Protection Association Report of /21/2015 2:59 PM Correlating Committee Note No. 6-NFPA [ Global Input ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Wed Jan 07 17:13:29 EST 2015 Committee Statement Committee Statement: The correlating committee recommends that the 664 technical committee review its response to PI made several first revisions changing the term fire-resistance rating to fire-protection rating for doors. The 664 committee should review the changes in 654 and ensure that it used the proper term throughout the document. This is a correlating issue between the documents.

80 National Fire Protection Association Report 0 of 16 1/21/2015 2:59 PM Correlating Committee Note No. 14-NFPA [ Section No. 1.1 [Excluding any Sub-Sections] ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: National Fire Protection Assoc Street Address: City: State: Zip: Submittal Date: Thu Jan 08 20:36:35 EST 2015 Committee Statement Committee Statement: The correlating committee recommends that the 664 technical committee revise the scope of the document to be consistent with the structure of the scope statement in NFPA 61. This scope states the "standard provides requirements...". The correlating committee is working towards aligning the scope statements in all of the dust document to be consistent. This recommendation is also being made to the 654 TC and the 484 and 655 technical committees as they enter their revision cycles.

81 National Fire Protection Association Report 1 of 16 1/21/2015 2:59 PM Correlating Committee Note No. 7-NFPA [ New Section after ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Wed Jan 07 17:18:09 EST 2015 Committee Statement Committee Statement: The correlating committee recommends that the 664 committee review this first revision in light of the negative comments received on the ballot. This criteria is not consistent with material in 652 for triggering a dust hazard analysis. First Revision No. 2-NFPA [New Section after 1.4.3]

82 National Fire Protection Association Report 2 of 16 1/21/2015 2:59 PM Correlating Committee Note No. 8-NFPA [ New Section after ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Wed Jan 07 17:21:48 EST 2015 Committee Statement Committee Statement: The correlating committee recommends the 664 technical committee reconsider this FR based on the negative comments received on the ballot. This term is used throughout this document as well as the other dust documents and should be defined consistently, if it needs to be defined at all. First Revision No. 35-NFPA [New Section after ]

83 National Fire Protection Association Report 3 of 16 1/21/2015 2:59 PM Correlating Committee Note No. 12-NFPA [ Section No. 4.5 ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Wed Jan 07 17:35:46 EST 2015 Committee Statement Committee Statement: The 664 technical committee should review this section and correlate it with the material in 652 on dust hazard analysis. This would ensure consistency between the two documents.

84 National Fire Protection Association Report 4 of 16 1/21/2015 2:59 PM Correlating Committee Note No. 11-NFPA [ New Section after 6.3 ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Wed Jan 07 17:33:02 EST 2015 Committee Statement Committee Statement: The 664 technical committee should consider extracting the definitions for separation, segregation, and detachment from 652 into this document. The material is extracted from 652, but the terms are not defined. This will ensure consistency with 652. First Revision No. 32-NFPA [New Section after 6.3]

85 National Fire Protection Association Report 5 of 16 1/21/2015 2:59 PM Correlating Committee Note No. 10-NFPA [ Section No ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Wed Jan 07 17:31:02 EST 2015 Committee Statement Committee Statement: The correlating committee recommends that the 664 technical committee review this FR in light of the negative comments received on the ballot. First Revision No. 16-NFPA [Section No ]

86 National Fire Protection Association Report 6 of 16 1/21/2015 2:59 PM Correlating Committee Note No. 9-NFPA [ Section No ] Submitter Information Verification Submitter Full Name: Susan Bershad Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Wed Jan 07 17:28:33 EST 2015 Committee Statement Committee Statement: The correlating committee recommends that the 664 committee reconsider its action on this FR based on the negative ballot comments. This material is in a section on storage and the use of the term "storage" may be more consistent. First Revision No. 57-NFPA [Section No ]

87 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS Proposed Modifications to NFPA 655 Alan D. Mosher Principal Process Engineer Black & Veatch Corporation Overland Park, KS, USA Sean M. McGuffie Senior Engineer Porter McGuffie, Inc. Lawrence, KS, USA Dennis H. Martens Consultant and Technical Advisor Porter McGuffie, Inc. Lawrence, KS, USA Abstract To Be Presented at the Brimstone Sulfur Symposium Vail, Colorado September 14-18, 2015 National Fire Protection Association (NFPA) 655 Standard for Prevention of Sulfur Fires and Explosions (current edition: 2012), Chapter 5, Handling of Liquid Sulfur at Normal Handling Temperatures, Section 5.5, Fire Fighting, states that protection of covered liquid sulfur storage tanks, pits and trenches shall be by one of the following means: (1) inert gas system, (2) steam extinguishing system capable of delivering a minimum of 2.5 lb/min (1.13 kg/min) of steam per 100 ft 3 (2.83 m 3 ) of volume, or (3) rapid sealing of enclosure to exclude air. The NFPA snuffing steam rate stated in the standard results in a large steam rate being fed to sulfur tanks and sulfur pits that typically have a low design pressure. The sulfur tanks and sulfur pits are typically designed with air sweep systems to prevent the accumulation of hydrogen sulfide (H 2 S) in the vapor space, thereby eliminating the flammable mixture. The air intake and exhaust systems are typically designed with very low pressure drops for normal operation. If snuffing steam is fed to sulfur tanks and sulfur pits at the rate specified in NFPA 655, the built-up back pressure typically far exceeds the design pressure of the enclosure. For these reasons, the refining and gas plant industry has tended to choose not to follow the NFPA 655-specified snuffing steam rate. Actual operating data from sulfur fires in sulfur tanks and sulfur pits indicate that a lower sealing steam rate is adequate to extinguish the fire by sealing the sulfur tank or sulfur pit from air ingress and purging some of the air as the fire is extinguished by lack of oxygen. Some computational fluid dynamics (CFD) modeling has been completed that supports the field data showing that a lower steam rate is adequate to extinguish the fires. This paper focuses on the potential problems caused by the current NFPA 655 snuffing steam rate, analysis of actual field data for fires in sulfur tanks and pits, and a recommendation for the NFPA 655 committee to consider regarding a steam rate to seal the enclosure and extinguish the fire in a sulfur tank and sulfur pit. The paper also includes comments on good engineering practice resulting from the calculations and CFD analyses that were completed. NFPA 655 is currently being updated and will be reissued in This paper was initially prepared to document issues with the current NFPA 655 snuffing steam rate for molten sulfur and to recommend a reduced rate to NFPA during the first public comment period that ended on January 5, 2015.

88 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 Table of Contents Executive Summary Introduction Brief History of NFPA 655 Snuffing Steam Requirements Edition Edition Edition Edition Edition Edition Edition Equivalency of various required snuffing steam rates Issues with Current NFPA 655 Snuffing Steam Requirement Attempted Oxygen Concentration Dilution Calculation Actual Operating Data for Molten Sulfur Fire Extinguishing Steam Detection of Sulfur Pit and tank Fires Sulfur Pit Fires Sulfur Tank Fires Computational Fluid Dynamics Modeling of a Sulfur Pit Selection and Construction of Computational Domains Development of Computational Grid Selection of Domain Physics Selection of Boundary Conditions Solution Results Current Configuration Results Relocated Configuration Results Velocity Streamline Comparisons General Discussion Potential Rapid Sealing Steam Rate Good Engineering Practice for Use of Sealing Steam Conclusions Recommendations Acknowledgements References i

89 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 LIST OF TABLES Table 1 Snuffing Steam Rates for Molten Sulfur Listed in NFPA Table 2 Existing Sulfur Tanks with Steam at 2.5 lb/min per 100 ft Table 3 Existing Sulfur Pits with Steam at 2.5 lb/min per 100 ft Table 4 Existing Sulfur Tanks with Steam at 1.0 lb/min per 100 ft 3 Compared to 2.5 lb/min per 100 ft Table 5 Existing Sulfur Pits with Steam at 1.0 lb/min per 100 ft 3 Compared to 2.5 lb/min per 100 ft LIST OF FIGURES Figure 1 Incinerator Stack SO 2 and Sulfur Pit Vapor Space Temperature during a Sulfur Fire Figure 2 Sulfur Pit Fire DCS Temperature Data Figure 3 Domains Used for CFD Analyses Figure 4 Computational Grid Developed for CFD Analyses Figure 5 Boundary Conditions Applied for Current Configuration Analysis Figure 6 Boundary Conditions Applied to Steam Inlet Moved Model Figure 7 Common Boundary Conditions Applied to Models Figure 8 Oxygen Concentrations in Sulfur Pit Vapor Space Figure 9 Oxygen Concentrations in Sulfur Pit Vapor Space, Air Inlet, and Ejector Suction Figure 10 Oxygen Concentration in Sulfur Pit Vapor Space with Steam Relocated Near Air Inlet Figure 11 Velocity Streamlines for Current Configuration Analysis Figure 12 Velocity Streamlines for Moved Steam Inlet Case ii

90 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 Executive Summary On the basis of the data collected and analysis performed for this paper, the authors recommend the following changes to National Fire Protection Association (NFPA) 655, Standard for Prevention of Sulfur Fires and Explosions (current edition: 2012), Chapter 5, Handling of Liquid Sulfur at Normal Handling Temperatures: 5.5 Fire Fighting Protection for covered liquid sulfur storage tanks, pits, and trenches shall be by one of the following means: (1) Inert gas system in accordance with NFPA 69, Standard on Explosion Prevention Systems (2)*Steam extinguishing system capable of delivering a minimum of 2.5 lb/min (1.13 kg/min) of steam per 100 ft 3 (2.83 m 3 ) of volume. (3) Rapid sealing of the enclosure to exclude air (3)*Rapid sealing of the enclosure to exclude air. For sulfur tanks and sulfur pits, the use of a steam rate of 1.0 lb/min (0.45 kg/min) of steam per 100 ft 3 (2.83 m 3 ) of total tank or pit volume is expected to develop a positive pressure in the enclosure, thereby sealing the sulfur tank or sulfur pit, preventing air ingress, and extinguishing the fire Snuffing Steam and Sealing Steam Precautions The vent systems on enclosed sulfur tanks and sulfur pits must be designed to allow the required snuffing steam rate or sealing steam rate to vent without overpressuring the enclosure. The vent systems must also be designed for proper operation during normal operation Water Extinguishing Precautions Liquid sulfur stored in open containers shall be permitted to be extinguished with a fine water spray Use of high-pressure hose streams shall be avoided The quantity of water used shall be kept to a minimum Dry Chemical Extinguishers. Where sulfur is being heated by a combustible heat transfer fluid, dry chemical extinguishers complying with NFPA 17, Standard for Dry Chemical Extinguishing Systems, shall be provided. A.5.5.1(3) For enclosed sulfur tanks or sulfur pits with air sweep systems, the sealing steam should be fed into the enclosure very near the air inlets. As the sealing steam vents backward through the air inlets, the sealing steam will quickly stop air ingress to the fire. Sealing steam should be fed into the sulfur tank or sulfur pit for a minimum of 15 minutes or until the temperature has returned to near normal. For further information and good engineering practice regarding sealing steam see Molten Sulfur Fire Sealing Steam Requirements. C Other Publications. Mosher, A. D., McGuffie, S. M., and Martens, D.H., Molten Sulfur Fire Sealing Steam Requirements, Brimstone Sulfur Symposium, Vail, CO, September

91 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA Introduction National Fire Protection Association (NFPA) 655, Standard for Prevention of Sulfur Fires and Explosions, (1) contains information about snuffing steam requirements for extinguishing fires in sulfur tanks and sulfur pits. The rate that is listed in Chapter 5, Handling of Liquid Sulfur at Normal Handling Temperatures, is excessive and causes problems with the venting systems of these enclosures and can cause built-up back pressure within these enclosures that exceeds the original design pressure. Sulfur produced in oil and gas facilities contains quantities of hydrogen sulfide (H 2 S). This H 2 S is slowly released from the molten sulfur during storage. To eliminate the flammable mixture, sulfur tanks and sulfur pits in these facilities are typically designed with air sweep systems to prevent the accumulation of H 2 S in the vapor space. Continuous sweeping with air also prevents accumulation of pyrophoric iron sulfide (FeS) by oxidizing the material. The FeS is generated by corrosion of carbon steel components in contact with H 2 S. The air intake and exhaust systems for sulfur tanks and sulfur pits must be carefully designed with consideration for very low pressure drops during normal operation, must account for the buoyancy effect of the heated air intakes, and must account for the effect of wind blowing across the vents. Developing a vent design that accounts for all the normal operating parameters can be quite difficult and can become impractical when the vents must also be capable of venting the snuffing steam fed at the NFPA 655 rate of 2.5 pounds per minute (lb/min) per 100 cubic feet (ft 3 ) of volume. This paper focuses on the potential problems caused by the current NFPA 655 snuffing steam rate. The paper presents analysis of available actual field data for extinguishing fires in sulfur tanks and sulfur pits provided by owners of oil and gas facilities. This paper provides the basis for a recommendation to the NFPA 655 committee to consider defining a steam rate to suitably seal the sulfur tanks and sulfur pits to exclude oxygen and, thereby, safely extinguish sulfur fires. This paper recommends a sealing steam rate based on documented industry practice for extinguishing fires in sulfur tanks and sulfur pits and computational fluid dynamics (CFD) studies. The paper also includes comments on good engineering practice resulting from the analysis of the information gathered and from CFD modeling that was completed. NFPA 655 is currently being updated and will be reissued in This paper was initially prepared to document issues with the current NFPA 655 snuffing steam rate for molten sulfur fires and recommend incorporating a sealing steam rate to NFPA during the first public comment period that ended on January 5, Note: No part of this document addresses fire fighting for solid dust sulfur fires. This document only addresses steam requirements for molten sulfur fires. 2

92 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA Brief History of NFPA 655 Snuffing Steam Requirements The fire fighting techniques listed by NFPA for molten sulfur have evolved since the initial adoption of NFPA 655 in The following information was taken from documents such as revision history, Technical Committee Reports, etc., available on NFPA s website EDITION The Technical Committee Report for Amendments to be included in the 1968 edition of NFPA 655 included the following text: 45. Fire Fighting Covered liquid sulfur storage tanks should be provided with some inert gas system for extinguishing fires that may occur in the tank. The inert gas may consist of carbon dioxide, nitrogen, flue gas or steam. Since the inert must be supplied rapidly enough to displace the ventilation air from the vents, steam is usually the most effective and economical choice Where liquid sulfur containers are of sufficiently small size to permit such action, it is recommended that they be so arranged so that they can be sealed rapidly to exclude air in case of fire; formation of sulfur dioxide will exhaust the oxygen in the enclosure and smother the fire. The system should be allowed to cool below 154C (310F) before reopening it to the atmosphere Liquid sulfur stored in open containers can best be extinguished with a fine water spray. Avoid the use of pressure hose streams which may scatter the burning liquid sulfur. The quantity of water used should be kept to a minimum EDITION The Technical Committee Report for Amendments to be included in the 1982 edition of NFPA 655 included the following text: 4-4 Fire Fighting Covered liquid sulfur tanks shall be provided with a gaseous fire extinguishing system. (See Appendix E of NFPA 86A, Standard Ovens and Furnaces, Appendix E, and NFPA 69, Standard on Explosion Prevention Systems.) * Where a fixed inerting system is used, thin Teflon rupture discs shall be placed over the inerting nozzles so that sulfur cannot condense within the nozzle. 1 NFPA s website is 3

93 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA * Where liquid sulfur containers are small enough, they may be arranged so that they can be rapidly sealed to exclude air in case of fire. The sulfur dioxide produced by the fire will smother the fire. In such cases, the system shall be allowed to cool below 154C before reopening Liquid sulfur stored in open containers may be extinguished with a fine water spray. Use of high pressure hose streams shall be avoided. Quantity of water used shall be kept to a minimum EDITION The Report of the Committee included the following recommendation, which was accepted and became part of the 1993 edition: 1. Revise 4-4.1" and add an Exception to read: 4-4.1* Covered liquid sulfur tanks shall be provided with a steam extinguishing system or an inert gas system in accordance with NFPA 86, Standard for Ovens and Furnaces and NFPA 69, Standard on Explosion Protection Systems. Exception: Where liquid sulfur containers can be rapidly sealed to exclude air, the SO 2 produced will smother the fire. In such cases, steam extinguishing systems or inert gas systems shall not be required. The system shall be allowed to cool below 154 C (309 F) before reopening. 2. Delete existing text of EDITION The Report of the Committee included the following recommendation, which was accepted and became part of the 2001 edition: RECOMMENDATION : Revise as follows: Protection for covered liquid sulfur storage tanks, pits and trenches shall be by one of the following means: (a) Inert gas system in accordance with NFPA 69, Standard for Explosion Prevention Systems. (b)* Steam extinguishing system capable of delivering 8 lbs/min of steam per 100 cu ft of volume. Bold added by current authors (c) Rapidly seal the enclosure to exclude air. A-4-4.1(b) The steam should preferably be introduced near the surface of the molten sulfur. See NFPA 86, Standard for Ovens and Furnaces, Appendix E-3. 4

94 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 SUBSTANTIATION: This recommendation brings the steam flooding requirement in line with NFPA 86. The recommendation is based on 1934 FMRC fire test of a gasoline fire where the steam was applied above the gasoline fire and combustion air was introduced below the steam injection point. It in essence requires supplying 200 cu ft/min steam for every 100 cu ft of enclosure volume. For hot enclosures (above 220 F) where the steam is injected at the surface of the liquid sulfur, a supply capable of 4 cu ft/min per 100 cu ft of enclosure volume would be satisfactory. This requirement ensures that the available steam supply is adequate to furnish enough steam at a rate sufficient to extinguish the fire EDITION The Report of the Committee shows a recommendation and acceptance of a complete revision of the 2001 edition of NFPA 655 to become the 2007 edition. The 2007 edition showed the following text: 5.5 Fire Fighting Protection for covered liquid sulfur storage tanks, pits, and trenches shall be by one of the following means: (1) Inert gas system in accordance with NFPA 69, Standard on Explosion Prevention Systems (2)* Steam extinguishing system capable of delivering a minimum of 2.5 lb/min (1.13 kg/min) of steam per 100 ft 3 (2.83 m 3 ) of volume Bold added by current authors (3) Rapid sealing of the enclosure to exclude air 5.5.2* Where a fixed inerting system is used, thin corrosion-resistant rupture discs shall be placed over the inerting nozzles so that sulfur cannot condense within the nozzle Water Extinguishing Precautions Liquid sulfur stored in open containers shall be permitted to be extinguished with a fine water spray Use of high-pressure hose streams shall be avoided The quantity of water used shall be kept to a minimum Dry Chemical Extinguishers. Where sulfur is being heated by a combustible heat transfer fluid, dry chemical extinguishers complying with NFPA 17, Standard for Dry Chemical Extinguishing Systems shall be provided. 5

95 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA EDITION The Report of the Committee shows a recommendation and acceptance of a revised wording of the 2007 edition of NFPA 655 to become the 2012 edition as follows: 5.5 Fire Fighting Protection for covered liquid sulfur storage tanks, pits, and trenches shall be by one of the following means: (1) Inert gas system in accordance with NFPA 69, Standard on Explosion Prevention Systems (2)* Steam extinguishing system capable of delivering a minimum of 2.5 lb/min (1.13 kg/min) of steam per 100 ft 3 (2.83 m 3 ) of volume (3) Rapid sealing of the enclosure to exclude air 5.5.2* Where a fixed inerting system is used, thin corrosion-resistant rupture discs shall be placed over the inerting nozzles so that sulfur cannot condense within the nozzle Water Extinguishing Precautions Liquid sulfur stored in open containers shall be permitted to be extinguished with a fine water spray Use of high-pressure hose streams shall be avoided The quantity of water used shall be kept to a minimum Dry Chemical Extinguishers. Where sulfur is being heated by a combustible heat transfer fluid, dry chemical extinguishers complying with NFPA17, Standard for Dry Chemical Extinguishing Systems, shall be provided EDITION The next edition of NFPA 655 is due to be published in The public input closing date was January 5,

96 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA EQUIVALENCY OF VARIOUS REQUIRED SNUFFING STEAM RATES Table 1 provides a comparison of different snuffing steam rates for molten sulfur that have been listed in different editions of NFPA 655. Table 1 Snuffing Steam Rates for Molten Sulfur Listed in NFPA 655 LB/MIN per 100 FT 3 FT 3 /MIN per 100 FT 3 COMMENT 2001 Edition Based on 1934 Factory Mutual Research Corporation (FMRC) fire test of a gasoline fire discussion prior to issue of official edition Comment made as part of substantiation of item above. When steam is injected at the surface of the liquid sulfur, this rate would be satisfactory Edition

97 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA Issues with Current NFPA 655 Snuffing Steam Requirement Most existing and new sulfur recovery units (SRUs) within oil refineries and gas processing facilities have enclosed below grade sulfur pits and/or above grade sulfur tanks for storage of produced molten sulfur. Many of these sulfur pits and sulfur tanks have been designed with air sweep systems in the vapor space to maintain the concentration of H 2 S below 25 percent of the lower flammable limit (LFL) in accordance with NFPA 69, Standard on Explosion Prevention Systems (2), Chapter 8, Deflagration Prevention by Combustible Concentration Reduction. Because of safety concerns regarding possible venting of H 2 S to the environment through leaks in the sulfur pit, many of the sulfur pits and sulfur tanks are operated with a slight vacuum. The vacuum is often created by mechanical blowers or ejectors that pull the required amount of sweep air through the vapor space of the enclosure and then discharge that air/vapor to an appropriate disposal location/device at a slightly elevated pressure. Because of the buoyancy effect, the vacuum can also be created by the height difference between a heated vent stack and the heated air intake. The typical design internal and external pressures of sulfur tanks are low (approximately -3 to +10 inch water column [ WC] or less), and therefore, the vent systems must be carefully designed to prevent excessive vacuum from causing damage to the sulfur tank. Unlike tanks or vessels, sulfur pits may or may not be designed with the intention of having a specific internal design pressure. However, sulfur pits are typically designed with a concrete roof thickness of 12 to 15 inches. Based solely on the weight of the roof slab, the sulfur pit should be able to contain a pressure of pounds per square inch (psi) (28-36 WC). However, sulfur pit roofs frequently contain access hatches. Precast concrete hatches typically range from 4 to 6 inches thick and can therefore withstand an internal pressure of only approximately psi (10-14 WC) before lifting. Roof hatches or deflagration hatches can also be made from thin aluminum sheet material that is much lighter than the concrete and therefore able to withstand an internal pressure of only approximately WC before lifting. The air inlets to the sulfur pit or sulfur tank are typically heated with steam (steam jacketed) to prevent sulfur solidification and the resulting plugging within the air inlet. The heating of the air intakes causes a buoyancy effect to occur, and the sulfur pit or sulfur tank must be operated under a slight vacuum to overcome this buoyancy effect and ensure that air is flowing into the sulfur pit or sulfur tank. Wind blowing across the roof of a sulfur tank also causes uplift on the leeward side that can cause a reversal of air flow from the air intakes and vent the vapor space out through the air intakes rather than out through the exhaust. The typical operating pressure of the vapor space of a sulfur pit or sulfur tank is in the range of WC vacuum. The number and size of the air inlets must be carefully selected so that the air inlets will provide enough air flow to achieve the required air sweep but also induce enough pressure drop so that the vapor space remains at or below the required vacuum needed to offset the buoyancy effect and uplift caused by wind. If there is too much air inlet area, the air intakes can draft backward and allow the air intakes to exhaust H 2 S to the atmosphere. Therefore, the air inlet area is set on the basis of the required air rate for a proper sweep of the vapor space but, at the same time, making sure that the vapor space stays at a vacuum level greater than the buoyancy effect caused by the heated air intakes. 8

98 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 After the air intake area is set for normal operation (and in the absence of a relief valve, which most sulfur pits and sulfur tanks do not have), then that is the only area available to vent snuffing steam when steam is used to extinguish an internal fire. The current snuffing steam extinguishing system requirements in NFPA 655 of 2.5 lb/min per 100 ft 3 of volume become a very high steam flow rate for most sulfur tanks and some sulfur pits so that this rate can easily overpressure the sulfur tank and sulfur pit, causing the sulfur tank or sulfur pit to rupture. It is not practical to design a sulfur tank air sweep system to provide the necessary vacuum to prevent flow reversals in the air inlets during normal operation and provide the necessary air intake area to vent the required snuffing steam rate during a fire scenario. To illustrate the issues with overpressure of sulfur tanks, the authors evaluated six existing sulfur tanks that were designed for air sweep of the vapor space to reduce the H 2 S concentration and the resulting back pressure if steam is fed to snuff a fire according to NFPA 655 s rate of 2.5 lb/min per 100 ft 3 (refer to Table 2). As shown in Table 2, the NFPA 655 snuffing steam rate ranges from approximately 30 to 200 times the original sweep air rate. This snuffing steam rate results in a built-up back pressure within the sulfur tank of WC. This built-up back pressure would exceed the design pressure of 4 out of 6 of the sulfur tanks, as shown by the red text in Table 2. Tanks C and D have lower built-up back pressure, and they have a total volume less than 6,000 ft 3. All the tanks with a volume of approximately 50,000 ft 3 and larger would have built-up back pressure far higher than their design pressure. A general statement can likely be made that the vents on smaller tanks may be able to vent the current NFPA 655 snuffing steam rate, but it is likely that the vents on larger tanks cannot vent the current NFPA 655 snuffing steam rate without the built-up back pressure exceeding the tank design pressure. 9

99 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 Table 2 Existing Sulfur Tanks with Steam at 2.5 lb/min per 100 ft 3 TANK A TANK B TANK C TANK D TANK E TANK F Dimensions 66-6" Dia x 35'-0" H 59-6" Dia x 48'-0" H 19'-8" Dia x 17'-9" H 14'-5" Dia x 16'-4" H 42'-8" Dia x 32'-10" H 47'-6" Dia x 24'-10" H Volume, ft 3 138, ,635 5,800 2,833 48,885 49,435 Design Pressure, "WC -3 / / / / / / +3.5 Air Inlets Six - 10" Two - 16" Three - 6" Three - 6" Six - 6" Six - 6" Air Outlet One - 10" One - 16" One - 8" One - 8" One - 18" One - 8" Air Movement Method Blower sucks air through tank and pushes through caustic scrubber Natural draft 2 inlets, 1 outlet Natural draft 3 inlets, 1 outlet Natural draft 3 inlets, 1 outlet Natural draft 6 inlets, 1 outlet Natural draft 6 inlets, 1 outlet Normal Op Pressure, "WC Unknown Air Sweep Objective <16% H 2 S LFL, with 150 ppmwt H 2 S in Sulfur feed <21% H 2 S LFL, with 150 ppmwt H 2 S in sulfur feed <50% H 2 S LFL, with 150 ppmwt H 2 S in sulfur feed <50% H 2 S LFL, with 150 ppmwt H 2 S in sulfur feed <25% H 2 S LFL, with 300 ppmwt H 2 S in sulfur feed Unknown Pressure "WC with steam at 2.5 lb/min/100 ft 3 Steam volumetric rate (@ 2.5 lb/min/100 ft 3 ) compared to sweep air rate x 190 x 198 x 79 x 53 x Unknown 10

100 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 To illustrate the issues with overpressure of sulfur pits, the authors evaluated five existing sulfur pits that were designed for air sweep of the vapor space to reduce the H 2 S concentration and the resulting back pressure if steam is fed to snuff a fire according to NFPA 655 s rate of 2.5 lb/min per 100 ft 3 (refer to Table 3). As shown in Table 3, the NFPA 655 snuffing steam rate ranges from approximately 10 to 31 times the original sweep air rate. This snuffing steam rate results in a built-up back pressure within the sulfur pits of 17.6 WC 1,585 WC (50 psig). This built-up back pressure would exceed the pressure rating of the hatch covers on all five sulfur pits, as shown by the red text in Table 3. For all five sulfur pits analyzed, the hatch covers would lift if steam was fed at the current NFPA 655 rate of 2.5 lb/min per 100 ft 3. No calculations were performed to determine the resulting built-up back pressure that would remain in the sulfur pit after the hatch covers lifted, because that would require extensive and difficult calculations. The one sulfur pit that would theoretically achieve 50 psig pressure in the pit (if the hatch covers did not lift) is large, with a total capacity of 60,665 ft 3. This sulfur pit is associated with an SRU with a capacity of approximately 675 long tons per day (LTPD), which is a big plant, but certainly there are other existing plants that are much larger. This particular sulfur pit has a large reduction in inlet line size--8 inches down to 4 inches to feed into a flow meter. The flow reaches sonic velocity in this 4 inch diameter section, resulting in very high built-up back pressures. A general statement can likely be made that the vents on most sulfur pits associated with an SRU cannot vent the current NFPA 655 snuffing steam rate without the built-up back pressure exceeding the pressure that can be contained by the hatch covers. When these hatch covers lift, steam containing H 2 S and sulfur dioxide (SO 2 ) will vent to the atmosphere at ground level and cause a serious safety concern. 11

101 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 Table 3 Existing Sulfur Pits with Steam at 2.5 lb/min per 100 ft 3 PIT A PIT B PIT C PIT D PIT E Dimensions 24'-0"W x 35'-0"L x 10'-6"D 47'-7"W x 72'-2"L x 17'-8"D 14'-0"W x 34'-0"L x 11'-0"D 13'-2"W x 49'-10"L x 9'-2"D 21'-0"W x 30'-0"L x 8'-0"D Volume, ft 3 8,820 60,665 5,236 6,015 5,040 Design Pressure, "WC -unknown / +9.5 set by precast concrete access hatch covers -unknown / set by aluminum hatch covers -unknown / +9.6 set by precast concrete access hatch covers -unknown / set by precast concrete access hatch covers -unknown / set by aluminum hatch covers Air Inlets One - 6" Two - 8" One - 4" One - 4" One - 6" Air Outlet One - 6" Two - 8" One - 4" Two - 3" One - 6" Air Movement Method Ejector sucks air through air inlet and pushes to thermal reactor Ejector sucks air through air inlets and pushes to thermal reactor Ejector sucks air through air inlet and pushes to thermal reactor Ejector sucks air through air inlet and pushes to incinerator Ejector sucks air through air inlet and pushes to incinerator Normal Op Pressure, "WC Air Sweep Objective <15% H 2 S LFL, with 300 ppmwt H 2 S in sulfur feed <25% H 2 S LFL, with 300 ppmwt H 2 S in sulfur feed <25% H 2 S LFL, with 300 ppmwt H 2 S in sulfur feed Unknown Unknown Pressure "WC with steam at 2.5 lb/min/100 ft psig if hatch covers do not lift, sonic velocity back through air inlets /17.6(Note 1) Steam volumetric rate (@ 2.5 lb/min/100 ft 3 ) compared to sweep air rate 16 X 31 x 17 x 30 x 9.7 x Notes: 1. The second value listed is the built-up back pressure for this sulfur pit based on the ejector staying in operation. All other sulfur pits analyzed have a safety instrumented system (SIS) that will trip ejectors when fire is detected. 12

102 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA Attempted Oxygen Concentration Dilution Calculation When considering a new approach to determining an adequate steam rate to extinguish a sulfur fire, the authors first considered a dilution calculation for oxidant concentration reduction or combustible concentration reduction as described in NFPA 69, Standard on Explosion Protection Systems. To be able to complete the dilution calculation, the limiting oxygen concentration (LOC) or LFL of the vapor mixture must be known. Surprisingly, the LOC and LFL for molten sulfur could not be found. Several searches were conducted: an internet search, a search of common reference books, and a search of sulfur specific books. Several research organizations and numerous engineering/operating/simulation companies that specialize in SRUs were contacted. The LOC and LFL of molten sulfur are not readily available at any of these sources. Some material safety data sheet (MSDS) were located that showed an LFL of molten sulfur, but further investigation showed that the LFL listed was actually for H 2 S. Some MSDS actually added a footnote indicating the value listed is for H 2 S, and others did not include the detail. At the normal temperature that molten sulfur is typically stored, it could be argued that the sulfur vapor pressure is so low that the real danger for fire is based on the concentration of H 2 S that has evolved from the sulfur and not the sulfur itself. The LOC and LFL for H 2 S are available. It has been shown experimentally that the LFL of a substance typically decreases with increasing temperature. Zabetakis (3) developed some correlations for predicting the temperature effect on the LFL for paraffin hydrocarbons. The LFL of a paraffin hydrocarbon approaches zero at temperatures above approximately 2,192 F (1,200 C). The LOC of a substance also typically decreases with increasing temperature. The LFL and LOC of a substance also vary with the specific inert that is present. Without experimental data for H 2 S and molten sulfur with steam as the inert, it can only be speculated on what happens to the LFL and LOC in gas mixtures near an existing fire. However, it could reasonably be speculated that the LFL and LOC of H 2 S and molten sulfur will fall to near zero, if the fire raises localized temperatures to where they approach 2,192 F (1,200 C). Even at lower localized temperatures, the LFL and LOC concentration will be very low. Therefore, once a fire has started, considering LFL and LOC as parameters to target for snuffing steam dilution calculations is not productive. 13

103 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA Actual Operating Data for Molten Sulfur Fire Extinguishing Steam The authors were unable to find any published data on testing completed on molten sulfur fires or data collected from actual fires in industrial molten sulfur applications. Through various molten sulfur production forums (technical conferences, sulfur production specialist user groups, etc.) and personal contacts in the industry, the authors contacted a broad spectrum of sulfur production specialists at the major refining and gas plant companies in North America that operate SRUs to request data on any sulfur fires that have occurred in sulfur pits and sulfur tanks at the owner s facilities. The sulfur production specialists contacted should have had access to data from approximately 75 locations in North American that operate SRUs. Some locations operate more than one SRU and some locations have as many as 10 sulfur pits or sulfur tanks. On the conservatively low side, the request should have been able to gather data from 100 to 200 sulfur pits and sulfur tanks. The request was made with the promise that the sources of all data would remain anonymous. The request elicited some useful information about actual molten sulfur fires that have occurred in sulfur pits and sulfur tanks. Many owner responses indicated they had been fortunate enough to never have experienced a fire. Several owner responses indicated that they have had fires, but they occurred more than 10 years ago and therefore cannot remember much about them. Some owner responses indicated that they had experienced fires, but their corporate practice is such that they could not get corporate legal approval to allow data released outside of the organization. Some owner responses indicated that they had experienced sulfur fires, but they were unable to find sufficient documentation to indicate how the fires had been extinguished, or they knew that steam had been used, but they had no way to determine how much steam was used and the duration of the steam flow. One owner indicated that fires had occurred in three separate sulfur pits at one location and the fires were extinguished with a combination of steam and nitrogen, but no rate information was available. The authors analyzed the sulfur fire data that were made available by four owners. The rest of this section describes the data that were collected and the analysis of that data. 14

104 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA DETECTION OF SULFUR PIT AND TANK FIRES As a side note, one outcome of the data collection was to discover how some owners detected and responded to sulfur pit fires. For newer unit designs, it is relatively common to have a Safety Instrumented System (SIS) that receives inputs from instrumentation around the sulfur pit. If unsafe conditions are detected, the SIS will isolate certain systems around the sulfur pit in an attempt to prevent damage to equipment, environmental releases, and exposure of operators to toxic or dangerous environments. It is not uncommon for the SIS to monitor the vapor space temperature of a sulfur pit, and if the temperature increases above a high set point, the SIS will trip the ejector system and stop drawing air through the sulfur pit. This trip system is in place to prevent air from being drawn through the sulfur pit and intensifying the fire. One owner responded that it specifically did not want its ejector system to shut down on high sulfur pit vapor space temperature. That owner wanted the ejector system to stay online during a fire so that the majority of the SO 2 generated could be routed by the ejector to the SRU incinerator, allowing the emissions to be tracked and recorded. If the ejector system was shut down, the owner would need to estimate the emissions to be able to report them to the regulator agency. This particular owner experienced a number of sulfur pit fires in two sulfur pits over a 5 year period before the systems could be analyzed and modified to eliminate the sources of the fires. During this 5 year period, the owner s operations staff determined that whenever they experienced a rapid increase in the incinerator stack SO 2 emissions (the concentration would increase from a normal value of parts per million by volume [ppmv], through the alarm point at 125 ppmv, to 1,000-1,200 ppmv), it was typically a sulfur pit fire. This causal relationship was so strong that procedures were modified to train the operators to immediately start steam to the sulfur pit whenever they saw the incinerator stack SO 2 emissions climb rapidly. The operators would start steam to the sulfur pit and allow the steam to flow for 15 minutes before shutting it off. After the steam was shut off, the operators would monitor the incinerator stack SO 2 emissions, and in most cases, the emissions levels returned to normal. If the emissions limits did not return to normal, the operators would then look at other causes, such as an upset in the tail gas treating unit (TGTU). This owner stated that when a fire occurred in the sulfur pits, the results could be seen in the incinerator stack first, then, about 30 seconds later, the sulfur pit vapor space temperature would begin to rise. The sulfur pit vapor space temperature would only increase approximately F (28-33 C) during a fire. The operators considered the sulfur pit vapor space temperature increase as confirmation of a fire but used the incinerator stack emissions increase as their indication to immediately start steam to the sulfur pit. 15

105 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 Figure 1 is a plot of the distributed control system (DCS) data showing the incinerator stack SO 2 emissions and the sulfur pit vapor space temperature during a typical sulfur pit fire for this owner. The data on Figure 1, show a 30 to 40 second difference in the time between when the incinerator stack SO 2 emissions start to increase and when the sulfur pit vapor space temperature starts to increase. Figure 1 is a re-plot of the raw data and not the actual plot the operators would see. When operators look at a plot trend generated by the DCS, it will have different scales associated with each parameter. In fact, the incinerator stack SO 2 emissions are reported by both a low range analyzer ppmv and a high range analyzer > 500 ppmv. Therefore, it makes sense that the operators would notice the initial rapid increase in the incinerator stack SO 2 emissions more easily than the slower increase in the sulfur pit vapor temperature. Because of the quick action by the operators, the incinerator stack SO 2 emissions decreased below the alarm setting of 125 ppmv within 25 minutes of the initial alarm. Figure 1 Incinerator Stack SO 2 and Sulfur Pit Vapor Space Temperature during a Sulfur Fire 16

106 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 It should be considered that, for the example described above, the thermocouple that was in the sulfur pit vapor space never indicated a significant temperature increase during fire events. This is likely due to the location of the thermocouple compared to the location of the fire within the vapor space. It could be concluded that, during the fires experienced in the sulfur pit examples described above, the fires were somewhat localized and did not consume the entire vapor space. For configurations that intend to leave the ejectors operating through a fire event, locating the temperature indicator in the ejector suction line is likely better than locating it in the sulfur pit vapor space. At least with the temperature indicator in the ejector suction line, the thermocouple will see an average temperature of the gas passing through the sulfur pit vapor space rather than seeing a point temperature at a single location within the vapor space. Sulfur tanks typically do not include an SIS with high temperature input, and therefore, the typical method for sulfur fire detection is a visual indication of a yellow plume being vented from the tank. Some tanks do have a temperature indicator that operators can use to indicate that a fire is occurring. 5.2 SULFUR PIT FIRES Owner No. 1 experienced a number of sulfur pit fires in two sulfur pits over a 5 year period before the systems could be analyzed and modified to eliminate the sources of the fires. This owner provided data on how sulfur pit fires are extinguished. The sulfur pits in question are 21'-0" W x 30'-0" L x 8'-0" D, and each has a single 2 inch steam line from the header that reduces to 1 ½ inches near the connection on the roof of each sulfur pit. The sulfur pits are typical concrete pits that are completely enclosed, with one air inlet line and one air exit line that feeds an ejector for each sulfur pit. The ejector sweeps air through the vapor space of the sulfur pit and discharges to an incinerator. When a sulfur fire is suspected, the operators immediately open the 2 inch gate valve in the steam line to start steam flow to the sulfur pit. The owner reported that the operators will open the gate valve to a point where they see steam flowing out of the single 6 inch air intake line on the sulfur pit, which indicates they have put in enough steam to overcome the capacity of the sulfur pit ejector and sealed the enclosure/sulfur pit. The owner reported that the 2 inch gate valve is approximately one-third open when the operators see steam exiting from the air intake line. The steam is left flowing for a period of 15 minutes, then the flow is stopped, and the operators look at the incinerator stack SO 2 emissions to see if they have returned to normal. In almost all cases that this owner experienced, after 15 minutes of steam flow, the fire had been extinguished. The owner could only recall one incident when the fire returned after the steam was stopped. The owner speculated that for this one case, a re-ignition event may have occurred, rather than lack of suppression of the first fire. 17

107 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 Owner No. 1 provided the piping isometric for the steam line. Hydraulic calculations were completed for the steam based on the steam header pressure, the one-third open gate valve, and information from the piping isometric. The analysis showed that the steam flow achieves sonic velocity in the 1 ½ inch section of pipe near the steam line exit into the sulfur pit. The flow of the steam was calculated to be 2,644 lb/hr. The total volume of the sulfur pit is 5,040 ft 3. Calculating the steam rate to sulfur pit volume ratio shows that the steam rate this owner has been using is 0.87 lb/min per 100 ft 3 of total sulfur pit volume. The owner reported that multiple sulfur fires have been successfully extinguished in the sulfur pits with this rate when the steam has flowed for 15 minutes. This rate is 2.87 times less than (or about 35 percent of) the current NFPA 655 specified value of 2.5 lb/min per 100 ft 3 for snuffing steam methodology. The owner reported that no damage has been experienced in these sulfur pits by the numerous fires because of the fact that the fire can be extinguished in 15 minutes. It is difficult to accurately determine the resistance coefficient (K) for a partially opened gate valve without having true flow test data from the manufacturer of the actual gate valve. The authors determined that, with a completely open full port gate valve (K values are available), the flow of steam would only increase to 2,900 lb/hr because the steam flow hits sonic velocity in the 1 ½ inch section near the sulfur pit roof. Therefore, the maximum flow of steam possible with the existing piping configuration is 2,900 lb/hr. Calculating the steam rate to sulfur pit volume ratio shows the maximum steam rate this owner could possibly feed, assuming a completely open gate valve, would be 0.96 lb/min per 100 ft 3 of total sulfur pit volume. This number is not substantially different from the estimated rate with the gate valve only one-third open. It should be considered that for the sulfur pit evaluated above, the operators specifically adjust the steam flow until they see steam coming out of the air intake piping. The flow of steam effectively seals the air intake and prevents air from entering the sulfur pit. The steam is also diluting the air that is in the vapor space and pushing some of it out of the air intake piping. In Section 6.0 computational fluid dynamics (CFD) is used to determine the oxygen concentration during the 15 minute period when steam is fed. As the fire consumes sulfur and oxygen from the air, SO 2 is produced. This SO 2 is heavy and could possibly sit on the surface of the molten sulfur, helping to limit the fire access to oxygen in the vapor space. Alberta Sulphur Research Ltd (ASRL) has completed some preliminary evaluations of fires in rail cars. According to Clark [Clark, P.D. personal communication October 8, 2014], ASRL completed experiments that simulated what happens if a rail car of solid sulfur ignited. What they observed was that the sulfur started to burn only after it became liquid. In addition, they saw that the flame temperature never reached the maximum value in air (ca. 1,200 F [650 C]) but stalled around 840 F (450 C), after all of the solid had liquefied. They preliminarily concluded that the SO 2 produced at the sulfur surface prevented mass transfer of air to the sulfur, limiting the rate of combustion. These experiments were done in an open box without a lid. Clark also speculated that since the surface of the liquid sulfur was adjacent to the hot vapor at 840 F (450 C), evaporation of liquid sulfur to the gas phase may be impeded by a viscous sulfur layer at or near the surface. Thus, the equilibrium vapor pressure at the bulk liquid sulfur temperature (ca. 356 F [180 C]) might not be obtained during a fire in a pit due to the kinetic effects of evaporation. 18

108 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 Even if the SO 2 is well dispersed within the vapor space, by effectively sealing all air entrances to the sulfur pit with steam, the fire becomes self-limiting and is quickly extinguished. Owner No. 2 experienced a sulfur pit fire in one sulfur pit recently. This owner provided the authors with data on how the sulfur pit fire was extinguished. The sulfur pit in question is 19'-6" W x 57'-0" L x 10'-0" D and has a single 2 inch steam line from the header that branches into three separate 2 inch lines, which each feed a 3 inch connection with a rupture disk on 3 inch connections on the roof of each sulfur pit. The three connections on the sulfur pit roof are roughly 20 feet apart and feed the common vapor space above different sections within the sulfur pit. The sulfur pit is a typical concrete pit that is completely enclosed with one air inlet line and one air exit line that feeds two ejectors (one ejector can be used to feed the sulfur pit sweep air to the incinerator, and the other can be used to feed the sulfur pit sweep air back to the front end of the SRU at the thermal reactor). The owner reported that when an increase in temperature of the sulfur pit vapor space was noticed (120 F [66.7 C] in just a few minutes), the steam 2 inch ball valve was opened about one-quarter. The steam was left flowing for a period of approximately 2 minutes, the sulfur pit vapor space temperature began to decrease, and the steam flow was stopped. The operators then monitored the sulfur pit vapor space temperature and noticed that, approximately 30 minutes after stopping the steam flow, the temperature started to increase again. At that point, the operator cracked open the 2 inch ball valve in the steam line and let the steam flow for an additional minute until they saw the sulfur pit vapor space temperature start to decrease. The steam valve was then closed, and the fire did not return. Figure 2 is DCS data showing the temperature of the sulfur pit vapor space and the liquid sulfur temperature during the fire in Owner No. 2 s sulfur pit. As can been seen, the sulfur pit vapor temperature increased 120 F (66.7 C) approximately 8 minutes after a sulfur pump tripped due to high viscosity (molten sulfur viscosity increases as temperature increases). Steam was started for 2 minutes and, when the operators saw the temperature begin to decrease, the steam was stopped. The sulfur pit vapor space and liquid sulfur temperature continued to decrease to normal values over an approximate 30 minute period. Then a second temperature spike occurred in the sulfur pit vapor and liquid sulfur. A small amount of steam was added for about 1 minute, and the temperatures again started to decrease toward normal values. 19

109 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 Figure 2 Sulfur Pit Fire DCS Temperature Data When the steam flow was initially started, only one of the three rupture disks actually burst. The rupture disk that was closest to the steam supply valve was the disk that burst. The other two rupture disks remained intact through both steam events. Although not perhaps apparent during the original design, but obvious in hindsight, having multiple rupture disks on a single steam supply line will likely result in only one disk bursting. The rupture disks are located directly on the sulfur pit nozzles to prevent sulfur pit vapors from backing into the steam line, condensing, and then solidifying and plugging the line during normal operation. The rupture disks are located at practically the lowest pressure in the piping system. Therefore, with slight differences in the actual bursting pressure of the rupture disks and slightly different pressures in each section of piping feeding the rupture disks, it is logical that only one of the rupture disks would burst, and all the flow would enter the sulfur pit at that location. 20

110 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 Owner No. 2 provided the piping isometric for the steam line. Hydraulic calculations were completed for the steam based on the steam header pressure, the one-quarter open ball valve, and information from the piping isometric. The flow of the steam was calculated to be 891 lb/hr. The analysis shows that the steam flow only achieves about 10 percent of sonic velocity in the upsized 3 inch section of pipe near the steam line exit into the sulfur pit. The total volume of the sulfur pit is 11,115 ft 3. Calculating the steam rate to sulfur pit volume ratio shows the steam rate this owner used was 0.13 lb/min per 100 ft 3 of total sulfur pit volume. This rate likely was successful in extinguishing the initial sulfur fire in the sulfur pit when this rate was used for only about 2 minutes. The owner did experience a second fire 30 minutes later, but it was likely a re-ignition event. The authors did not calculate a steam rate for the second event because the operators said they only cracked the valve open slightly for 1 minute. Therefore, the steam rate fed the second time was less than the first rate shown above. The steam rate above is 19 times less than (or about 5 percent of) the current NFPA 655 specified value of 2.5 lb/min per 100 ft 3. The rate discussed above of 0.13 lb/min per 100 ft 3 is practically the same value as listed in Table 1 of Section 2.8 regarding a statement made in substantiation of changes to the 2001 edition of NFPA 655, namely, that, if steam is injected at the surface of the sulfur, 4 ft 3 /min per 100 ft 3 of enclosure volume would be satisfactory (4 ft 3 /min per 100 ft 3 is equal to 0.14 lb/min per 100 ft 3 ). It is difficult to accurately determine the resistance coefficient (K) for a partially opened ball valve without having true flow test data from the manufacturer of the actual ball valve. The authors determined that with a completely open full port ball valve (K values are available), the flow of steam would only increase to 2,779 lb/hr. The velocity at this rate was still only 29 percent of sonic velocity in the 3 inch section near the sulfur pit roof. The maximum flow of steam possible with the existing piping configuration is 2,779 lb/hr. Calculating the steam rate to sulfur pit volume ratio shows the maximum steam rate this owner could possibly feed, assuming a completely open ball valve, would be 0.41 lb/min per 100 ft 3 of total sulfur pit volume. This number is more than 3 times the estimated rate with the ball valve only one-quarter open. However, this steam rate is still 6 times less than (or about 16 percent of) the current NFPA 655 specified value of 2.5 lb/min per 100 ft 3. 21

111 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 Owner No. 3 experienced a sulfur pit fire in one sulfur pit in December That fire was the first known sulfur pit fire in the 21 years of operation of that unit. This owner provided data on how the sulfur pit fire was extinguished. The sulfur pit in question is 12'-0" W x 36'-6" L x 8'-0" D and has a single 2 inch steam line from the header that branches into three separate 2 inch lines, each of which feeds a 3 inch connection on the roof of the sulfur pit. The three connections on the sulfur pit roof feed the vapor space in the sulfur pit. The sulfur pit is a typical concrete pit that is completely enclosed, with one air inlet line and one air exit line that feeds an ejector. The steam driven ejector sweeps air through the vapor space of the sulfur pit and discharges to an incinerator. The owner stated that their written procedure for a sulfur pit fire is to open the 2 inch valve in the steam line 100 percent and keep the steam on for at least 15 minutes. The owner reported that, when troubleshooting high incinerator stack SO 2 emissions, they reduced the motive steam flow to the ejector, and almost immediately (less than 5 minutes) the incinerator stack SO 2 emissions returned to normal. By temporarily reducing the motive steam flow to the ejector, the ejector pulled less air through the sulfur pit, and the fire extinguished itself. No steam flow was required for this particular sulfur fire. 5.3 SULFUR TANK FIRES Owner No. 4 experienced a few sulfur tank fires. This owner provided data on how the sulfur pit fires were extinguished. The sulfur tank in question is 20'-0" Dia x 32'-0" H and has a 4 inch steam line from the header that feeds four 2 inch connections on the roof of the sulfur tank. The sulfur tanks are typical carbon steel tanks with a fixed roof and with multiple air inlet lines around the periphery of the roof and one center air exit line that vents to the atmosphere. The owner reported that, when they noticed a fire in the sulfur tank, they opened the steam 4 inch ball valve about one-quarter. The steam was left flowing for a period of 30 minutes and then the flow was stopped. The owner stated that they noticed the temperature in the tank decreased after 5 to 10 minutes, but they kept the steam on for 30 minutes to be sure the fire was completely extinguished. The authors completed hydraulic calculations for the steam based on the steam header pressure, the one-quarter open valve, and information regarding the piping routing. The flow of the steam was calculated to be 10,840 lb/hr. The analysis showed that the steam flow achieves only about 60 percent of sonic velocity in the downsized 2 inch sections of pipe at the nozzles on the sulfur tank. The total volume of the sulfur tank is 123,150 ft 3. Calculating the steam rate to sulfur pit volume ratio showed the steam rate this owner has been using is 0.15 lb/min per 100 ft 3 of total sulfur pit volume. The owner reported successfully extinguishing the sulfur fire in the sulfur tank with this rate when the steam flowed for 30 minutes (fire was likely out in 5 to 10 minutes). This rate is 17 times less than (or about 6 percent of) the current NFPA 655 specified value of 2.5 lb/min per 100 ft 3. The owner reported that no damage was experienced in the sulfur tank by this fire, because it was likely extinguished in 5 to 10 minutes. 22

112 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 It is difficult to accurately determine the resistance coefficient (K) for a partially opened valve without having true flow test data from the manufacturer of the actual valve. The authors determined that with a completely open full port valve (K values are available), the flow of steam would only increase to 14,836 lb/hr. The velocity at this rate was still only 80 percent of sonic velocity in the 2 inch section of pipe at the nozzles on the sulfur tank roof. The maximum flow of steam possible with the existing piping configuration is 14,836 lb/hr. Calculating the steam rate to sulfur pit volume ratio shows the maximum steam rate this owner could possibly feed, assuming a completely open valve, would be 0.20 lb/min per 100 ft 3 of total sulfur pit volume. This number is not substantially different from the estimated rate with the valve only one-quarter open. Owner No. 4 reported that fires had occurred in sulfur tanks at another location, but it had been 10 years or more since the last one. For this site, when a fire occurred steam valve(s) would be opened for a period of 20 to 30 minutes. 23

113 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA Computational Fluid Dynamics Modeling of a Sulfur Pit A CFD model of the first sulfur pit described in Section 5.2 was created. The CFD model was set up to determine concentrations of oxygen and steam as well as the velocities throughout the model. The model did not include the effects of actual combustion of oxygen with sulfur. Therefore, all changes in oxygen concentration are a direct result of dilution of the oxygen with steam and exhausting the oxygen-containing air from the sulfur pit through the ejector suction line and backward through the air intake line. All reported oxygen concentrations are, therefore, conservative, and the actual values would be lower because of the consumption of oxygen by combustion of sulfur. Two flow conditions were considered with the model: a current configuration model and a model that considered a relocation of the steam inlet. It should be noted that the disturbance of the sulfur s surface by possible high-speed jets, which would result in more sulfur available for a pit fire, was not considered in these analyses. As has been shown in a previous publication by one of this paper s authors (4), the following steps are involved in all CFD analyses: Selection and construction of computational domains. Development of computational grid. Selection of domain physics. Application of boundary conditions. Solution. The following subsections detail how each of these steps was implemented for the CFD analyses, the results and general discussion from the analyses. 6.1 SELECTION AND CONSTRUCTION OF COMPUTATIONAL DOMAINS The model was based on the overall internal dimensions of the sulfur pit, along with the dimensions of the air inlet and ejector suction lines. The overall domain for both models included the pit vapor space at a 45 percent fill level. Figure 3 shows the three geometric domains created for the analyses, the main pit space (steel blue light, 40 percent transparent) and the two abandoned sparger boxes (turquoise green). 6.2 DEVELOPMENT OF COMPUTATIONAL GRID The computational grid was constructed using Star-CCM+ s automatic polyhedral mesher with wall prism layers enabled. The final computational grid contained 1,001,116 cells and is shown on Figure 4. 24

114 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 Figure 3 Domains Used for CFD Analyses Figure 4 Computational Grid Developed for CFD Analyses 25

115 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA SELECTION OF DOMAIN PHYSICS The following physics models were enabled for the analyses: Space 3-dimensional. Time Implicit unsteady. Material Multispecies, gas (H 2 S, H 2 O, O 2 and N 2 ). Equation of state Ideal gas. Turbulence - RANS, Realizable k-, All y+ Wall Law. Segregated fluid temperature. Gravity (-9.81 m/s in y-direction). 6.4 SELECTION OF BOUNDARY CONDITIONS Figure 5 shows the boundary conditions applied for the current configuration analysis. The steam inlet is denoted by the dot in the red circle and the air inlet is denoted by the top of the pipe in the blue circle. The ejector outlet is shown in yellow. The steam inlet was defined as a mass flow inlet, with an inlet flow rate of 2,456 lb/hr. The steam inlet was sized to have an inlet velocity of 0.7 Mach, as sonic flow would require considerably more computational resources to solve. The air inlet was defined as a stagnation inlet at atmospheric pressure. The ejector was defined as a velocity outlet with a flow rate based on the design data sheet value of 350 actual cubic feet per minute (acfm). Figure 5 Boundary Conditions Applied for Current Configuration Analysis 26

116 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 Figure 6 shows the boundary conditions applied to the steam inlet moved model. The air inlet is circled in blue, the steam inlet is circled in red and the ejector outlet is circled in yellow. Since this model was originally run with a pressure boundary at the ejector outlet, there is a contraction to prevent backflow. The same values listed above were applied to this model. Figure 6 Boundary Conditions Applied to Steam Inlet Moved Model Figure 7 shows the common boundary conditions applied to the models. The unheated sparger walls are shown in magenta. The heated sulfur level is shown in yellow, and the sulfur rundowns are shown in white. Both the sulfur level and rundowns were set to a defined temperature of F (157.5 C). 27

117 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 Figure 7 Common Boundary Conditions Applied to Models 6.5 SOLUTION The transient solutions were conducted on a high-performance computing cluster (HPCC) using 120 processors. An adaptive time-step was used so that the maximum convective Courant number was below 1 for each time-step. 6.6 RESULTS The following subsections detail the results for the two configurations that were analyzed Current Configuration Results The maximum and the average oxygen concentration in the sulfur pit vapor space versus time, for the current configuration case, are plotted on Figure 8. As can be seen on the figure, at the end of the 15 minute steam period, the maximum oxygen concentration in the sulfur pit vapor space is about 0.24 mole%. However, the average oxygen concentration is only about mole%. The average oxygen concentration is 16 times lower than the maximum value, indicating that there are very few locations within the vapor space of the sulfur pit with oxygen concentrations near the maximum. The very low average oxygen concentration supports the field data that the sulfur pit fire is extinguished before the steam is stopped after 15 minutes. The actual oxygen concentration in the sulfur pit vapor space will be even lower than indicated on the figure because the CFD model does not account for the oxygen consumed by the sulfur fire. 28

118 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 Figure 8 Oxygen Concentrations in Sulfur Pit Vapor Space Data were also extracted from the CFD model to show the maximum oxygen concentration in the sulfur pit air inlet line and in the suction line to the ejector. These data, along with the maximum oxygen and the average oxygen concentration in the sulfur pit vapor space, are plotted on Figure 9. The figure shows that the maximum oxygen concentration in the ejector suction line immediately starts to decrease after the steam is started. This is as expected since the steam is fed into the sulfur pit near the nozzle on the sulfur pit that feeds the ejector suction. The figure shows that the maximum oxygen concentration in the air inlet line remains at the ambient value of 21 mole% for about 15 seconds as the steam passes through the vapor space of the sulfur pit to reach the air inlet on the far side of the sulfur pit. After about 15 seconds, the maximum oxygen concentration in the air inlet line begins to decrease (as steam begins flowing backward through the air inlet line) and basically matches the maximum oxygen concentration in the ejector suction line after 90 seconds. The maximum oxygen concentration in the ejector suction and the maximum oxygen concentration in the air inlet line practically lie on top of the line for the average oxygen concentration in the sulfur pit vapor space, making it difficult to distinguish the three lines in the figure. Although not shown on the figure, the average oxygen concentration and the maximum oxygen concentration in the ejector suction line do not differ by more than 1 percent after about 25 seconds of elapsed purge time. The fact that the maximum oxygen concentration in the ejector suction line, air inlet line, and the vapor space are basically the same value indicates that the sulfur pit vapor space is fairly well mixed and venting the same concentration from both ends of the sulfur pit. 29

119 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 Figure 9 Oxygen Concentrations in Sulfur Pit Vapor Space, Air Inlet, and Ejector Suction Relocated Configuration Results The maximum and the average oxygen concentration in the sulfur pit vapor space versus time for the current steam location, with the steam relocated near the air inlet line, are plotted on Figure 10. As can be seen on the figure, relocating the steam inlet near the air inlet line significantly lowers the average and maximum oxygen concentration in the sulfur pit vapor space compared to those same parameters with the steam at its existing location. The model was stopped after about 12 minutes (720 seconds) because the oxygen concentrations were so low. At the end of 12 minutes, the maximum oxygen concentration in the sulfur pit vapor space was less than mole%, and the average oxygen concentration in the sulfur pit vapor space was less than mole%. Again, the actual oxygen concentration in the sulfur pit vapor space will be even lower than indicated on the figure because the CFD model does not account for the oxygen consumed by the sulfur fire. It is obvious from the data that introducing the steam near the air inlet line will seal the air inlet line quicker and thereby drive the oxygen concentration in the vapor space to low levels much faster than locating the steam on the far side of the sulfur pit near the ejector suction line. The data indicate that by relocating the steam feed to near the air inlet line, after about 5 minutes the maximum and average oxygen concentrations in the sulfur pit vapor space can be decreased to values similar to the values achieved in 15 minutes with the existing steam location. 30

120 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 Figure 10 Oxygen Concentration in Sulfur Pit Vapor Space with Steam Relocated Near Air Inlet Velocity Streamline Comparisons Figure 11 shows the velocity streamlines for the current configuration analysis. As can be seen, the high-speed jet impinges on the liquid sulfur surface and then travels around the perimeter. In this flow condition, little purging is occurring in the center of the pit, which results in the longer purge times shown on Figure 8 through Figure 10. Figure 12 shows the velocity streamlines for the steam inlet relocated configuration. As can be seen in this case, a large portion of the steam enters the pit and is immediately exhausted through the air inlet. This will result in rapidly stopping all O 2 flow into the pit. 31

121 MOLTEN SULFUR FIRE SEALING STEAM REQUIREMENTS PROPOSED MODIFICATIONS TO NFPA 655 Figure 11 Velocity Streamlines for Current Configuration Analysis Figure 12 Velocity Streamlines for Moved Steam Inlet Case 32