TECHNICAL COMMITTEE ON AUTOMOTIVE and MARINE SERVICE STATIONS

Transcription

1 TECHNICAL COMMITTEE ON AUTOMOTIVE and MARINE SERVICE STATIONS MEMORANDUM TO: FROM: Technical Committee on Automotive and Marine Service Stations R. P. Benedetti DATE: October 26, 2015 SUBJECT: Agenda for NFPA 30A First Draft Meeting November 16, :00 AM to 5:00 PM November 17, :00 AM to 5:00 PM Ladies and Gentlemen: Attached is the Agenda for the NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages, First Draft meeting to be held Monday, November 16, and Tuesday, November 17, 2015, at the offices of UL LLC, 2191 Zanker Road, San Jose CA. The meeting is scheduled to run from 8:00 AM to 5:00 PM, both days. This Agenda will also be posted to the NFPA 30A Document Information Page at If you have additional items for the Agenda, please bring them with you to the meeting. rpb/ cc AUV Meeting Folder AUV/NM AUV Agenda.doc

2 TECHNICAL COMMITTEE ON AUTOMOTIVE and MARINE SERVICE STATIONS AGENDA NFPA 30A First Draft Meeting Technical Committee on Automotive and Marine Service Stations Offices of UL LLC, 2191 Zanker Road San Jose CA Monday, November 16, 2015, 8:00 AM to 5:00 PM Tuesday, November 17, 2015, 8:00 AM to 5:00 PM 1. Call to Order. 2. Introduction of Attendees. Update of Committee Roster. [Attachment A1] 3. Approval of Minutes of Last Meeting. [June, 2013, San Antonio TX] [Attachment A2] 4. Report of Committee Chair. 5. Report of Staff Liaison. Technical Committee Scope. [See Attachment A3 for Proposed New Scope.] (New Scope Statement was approved at last meeting, but not balloted.) Technical Committee Membership Status. [Attachment A4] Document Revision Schedule for Annual 2017 Cycle. [Attachment A5] 6. Member Reports on Current Issues. [As Necessary] 7. Multiple Fuels Dispensing Stations - NFPA 2 and NFPA 30A. [Attachment A6] Review of NFPA 2, Hydrogen Technologies Code Review Current Status of Alternative Fuels Dispensed Alongside Legacy Fuels Consider Creation of Task Group to Address Requirements for Alternative Fuels for Dispensing (NFPA 30A, Chapter 12) and Repair Garages (NFPA 30A, Chapter 7) 8. Review and Act on Public Inputs to Amend the 2015 edition of NFPA 30A [Attachment A7 Public Inputs & Attachments to Same] 9. Old Business. 10. New Business. Revisit (Failed) Tentative Interim Amendment No [Attachment No. A8] Double-Poppet Shear Valves. [Attachment No. A9] Inquiry from WI SFMO: Does NFPA 30A apply to non-registered vehicles? AUV Agenda.doc

3 Better definitions for Major Repair Garage and Minor Repair Garage. (Related Issue: Does Chapter 7 of NFPA 30A apply to a Tesla service facility?) Installation of small pumps directly on small tanks without minimum separation distance. Revisions to Section 6.7, Emergency Electrical Disconnects. [Attachment No. A10] Table Add the following entry to correlate with NFPA 30: Tank-aboveground, Div. 1 Zone 0 area inside vent piping fixed roof or vent opening Required Separation: delivery vehicle to aboveground storage tanks. [Attachment No. A11] Lightning Strikes and UST Explosions. [Attachment No. A12] Correlation with NFPA 52 Emergency Electrical Disconnects. [Attachment No. A13] Presentation on FlexStation Modular Fueling Facility. [Attachment A14] 11. Schedule Next Meeting(s). 12. Adjournment. AUV Agenda.doc

4 Address List No Phone Automotive and Marine Service Stations 10/27/2015 Robert P. Benedetti AUV-AAA Alfredo M. Ramirez Chair UL LLC 333 Pfingsten Road Northbrook, IL Alternate: Roland A. Riegel RT 4/15/2004 AUV-AAA Dennis Boyd Principal BP Corporation NA Inc. 1 West Warrenville Road, MC Naperville, IL American Petroleum Institute Alternate: Richard S. Kraus U 03/07/2013 AUV-AAA Rob Brown Principal Husky Corporation 2325 Husky Way Pacific, MO Alternate: Keith Weepie M 8/9/2011 AUV-AAA Charles A. Burns Principal Oscar W. Larson Company Dixie Highway Clarkston, MI IM 3/4/2009 AUV-AAA Sullivan D. Curran Principal Fiberglass Tank & Pipe Institute Heatherfield Houston, TX M 1/1/1993 AUV-AAA Nils Deacon Principal Mutual Service Office, Inc Morris Avenue Point Pleasant, NJ I 08/09/2012 AUV-AAA Brian C. Donovan Principal Steel Tank Mutual Insurance Company (STICO) 171 West Wing Street, Suite 208 Arlington Heights, IL I 1/1/1993 AUV-AAA Paul J. Doyle Principal Petroleum Marine Consultants, LLC Wellington Trace, E4 #207 Wellington, FL IM 10/18/2011 AUV-AAA Thomas K. Drube Principal Chart Industries, Inc th Street NW New Prague, MN M 4/3/2003 AUV-AAA Thomas J. Forsythe Principal JENSEN HUGHES 2950 Buskirk Avenue Suite 225 Walnut Creek, CA Alternate: Alwin A Kelly SE 4/28/2000 AUV-AAA Fred B. Goodnight Principal Amerex Corporation 7595 Gadsden Highway PO Box 81 Trussville, AL Fire Equipment Manufacturers' Association M 1/1/1988 AUV-AAA John M. Gray Principal OPW Fueling Components 9393 Princeton-Glendale Road Hamilton, OH M 10/29/2012 AUV-AAA Curtis N. Harding Principal Tyco Fire Suppression & Building Products One Stanton Street Marinette, WI Alternate: Adam Stewart M 8/5/2009 AUV-AAA Marshall A. Klein Principal Marshall A. Klein & Associates, Inc Autumn View Drive Eldersburg, MD Automotive Aftermarket Industry Association Alternate: Andrew S. Klein U 1/1/1987 AUV-AAA 1

5 Address List No Phone Automotive and Marine Service Stations 10/27/2015 Robert P. Benedetti AUV-AAA Ronald B. Laurence, Jr. Principal Stantec Consulting Services, Inc. 5 Dartmouth Drive, Suite 101 Auburn, NH SE 8/9/2011 AUV-AAA Thomas J. Marhevko Principal National Marine Manufacturers Association 231 South LaSalle Street, Suite 2050 Chicago, IL U 10/27/2005 AUV-AAA Randy Moses Principal Wayne Fueling Systems LLC 1000 East Walnut Street Heritage Campus, Suite 404 Perkasie, PA M 3/1/2011 AUV-AAA Donald R. Offerdahl Principal Intertek Testing Services 515 Arabian Avenue Bismarck, ND RT 1/10/2008 AUV-AAA David T. Phelan Principal Bergenfield Fire Department 114 Niagara Street Dumont, NJ E 03/05/2012 AUV-AAA Marcia Jo Poxson Principal Michigan Bureau of Fire Service PO Box Lansing, MI Alternate: R. Jeff Tanner E 10/29/2012 AUV-AAA Robert N. Renkes Principal Petroleum Equipment Institute 6514 East 69th Street Tulsa, OK M 1/1/1987 AUV-AAA Jess A. Robbins Principal Plasteel Inc South Coast Highway Oceanside, CA M 08/09/2012 AUV-AAA James R. Rocco Principal Sage Risk Solutions, LLC 360 Heritage Road Aurora, OH Petroleum Marketers Association of America Alternate: Charles R. Plummer U 3/21/2006 AUV-AAA Joel E. Sipe Principal Exponent, Inc Lakeshore Avenue, #5 Oakland, CA SE 8/9/2011 AUV-AAA Joseph Spaeder IM 04/08/2015 Principal AUV-AAA Atlantic Fire Equipment Company, Inc Delaware Avenue Upper Darby, PA National Association of Fire Equipment Distributors Bruce J. Swiecicki Principal National Propane Gas Association South LaGrange Road, Suite 353 Frankfort, IL Alternate: Don Singleton IM 7/1/1996 AUV-AAA Alwin A Kelly Alternate JENSEN HUGHES 3610 Commerce Dr Ste 817 Baltimore, MD Principal: Thomas J. Forsythe SE 08/11/2014 AUV-AAA Andrew S. Klein Alternate Marshall A. Klein & Associates, Inc. 2 Rose Court Pasco, WA Automotive Aftermarket Industry Association Principal: Marshall A. Klein U 10/29/2012 AUV-AAA 2

6 Address List No Phone Automotive and Marine Service Stations 10/27/2015 Robert P. Benedetti AUV-AAA Richard S. Kraus Alternate API/Petroleum Safety Consultants 210 East Fairfax Street, Apt. 600 Falls Church, VA American Petroleum Institute Principal: Dennis Boyd U 3/1/2011 AUV-AAA Charles R. Plummer Alternate PPM Consultants, Inc Lamy Lane Monroe, LA Petroleum Marketers Association of America Principal: James R. Rocco U 4/14/2005 AUV-AAA Roland A. Riegel Alternate UL LLC 1285 Walt Whitman Road Melville, NY Principal: Alfredo M. Ramirez RT 4/15/2004 AUV-AAA Don Singleton Alternate Blossman Gas Inc Hanshaw Road Ocean Springs, MS National Propane Gas Association Principal: Bruce J. Swiecicki IM 10/29/2012 AUV-AAA Adam Stewart Alternate Tyco Fire Protection Products One Stanton Street Marinette, WI Principal: Curtis N. Harding M 03/05/2012 AUV-AAA R. Jeff Tanner Alternate Michigan Department of Environmental Quality PO Box Lansing, MI Principal: Marcia Jo Poxson E 10/29/2012 AUV-AAA Keith Weepie Alternate Husky Corporation 2325 Husky Way Pacific, MO Principal: Rob Brown M 10/29/2012 AUV-AAA William R. Hamilton Nonvoting Member US Department of Labor Occupational Safety & Health Administration 200 Constitution Ave. NW, Room N3609 Washington, DC Alternate: Matthew I. Chibbaro E 3/4/2009 AUV-AAA Matthew I. Chibbaro Alt. to Nonvoting Member US Department of Labor Occupational Safety & Health Administration 200 Constitution Ave. NW, Room N3609 Washington, DC Occupational Safety & Health Administration Principal: William R. Hamilton E 4/15/2004 AUV-AAA Robert P. Benedetti Staff Liaison National Fire Protection Association 1 Batterymarch Park Quincy, MA /22/2008 AUV-AAA 3

7 TECHNICAL COMMITTEE ON AUTOMOTIVE and MARINE SERVICE STATIONS I. Attendance AUV Minutes.doc MINUTES of MEETING Technical Committee on Automotive and Marine Service Stations East Lansing Marriott at University Place East Lansing, MI Thursday, August 22, 2013 F. G. Biancucci, Hamilton ON Fire Department Fire Prevention Division D. Boyd, BP Corporation NA, Inc. (Rep. American Petroleum Institute) C. A. Burns, Oscar W. Larson Company B. C. Donovan, Steel Tank Mutual Insurance Company (STICO) P. J. Doyle, Petroleum Marine Consultants, LLC C. N. Harding, Tyco Fire Suppression & Building Products M. A. Klein, Marshall A. Klein & Associates, Inc. (Rep. Automotive Aftermarket Industry Association) R. B. Laurence Jr., Stantec Consulting Services, Inc. R. Moses, Wayne Fueling Systems, LLC D. T. Phelan, Bergenfield NJ Fire Department M. J. Poxson, Michigan Bureau of Fire Services A. M. Ramirez, UL LLC, CHAIR J. R. Rocco, Sage Risk Solutions, LLC (Rep. Petroleum Marketers Association of America) B. J. Swiecicki, National Propane Gas Association R. J. Tanner, Michigan Department of Environmental Quality (Alternate to M. J. Poxson) K. Weepie, Husky Corporation (Alternate to R. Brown) R. P. Benedetti, NFPA, STAFF LIAISON Technical Committee Members not Present: R. Brown, Husky Corporation M. I. Chibbaro, U. S. Occupational Safety and Health Administration (Nonvoting Member - Alternate to W. R. Hamilton) S. D. Curran, Fiberglass Tank & Pipe Institute N. Deacon, Mutual Service Office, Inc. J. B. Dimmick, Clean Vehicle Education Foundation (Alternate to D. B. Horne) T. K. Drube, Chart Industries, Inc. NexGen Fueling Division T. J. Forsythe, Hughes Associates/RJA Group F. B. Goodnight, Amerex Corporation (Rep. Fire Equipment Manufacturers' Association) J. M. Gray, OPW Fueling Components W. R. Hamilton, U. S. Occupational Safety and Health Administration (Nonvoting Member) D. B. Horne, DBHorne LLC (Rep. Clean Vehicle Education Foundation) A. S. Klein, Marshall A. Klein & Associates, Inc. (Alternate to M. A. Klein - Rep. Automotive Aftermarket Industry Association) R. S. Kraus, Petroleum Safety Consultants (Alternate to D. Boyd - Rep. American Petroleum Institute) T. J. Marhevko, National Marine Manufacturers Association

8 C. R. Plummer, PPM Consultants, Inc. (Alternate to J. R. Rocco - Rep. Petroleum Marketers Association of America) W. E. Rehr, International Code Council R. N. Renkes, Petroleum Equipment Institute R. A. Riegel, UL LLC (Alternate to A. M. Ramirez) J. A. Robbins, Plasteel, Inc. D. Singleton, Blossman Gas Inc. (Alternate to B. J. Swiecicki - Rep. National Propane Gas Association) J. E. Sipe, Exponent, Inc. A. Stewart, Tyco Fire Protection Products (Alternate to C. N. Harding) C. A. Sunderhaus, OPW Fueling Components (Alternate to J. M. Gray) Minutes 1. The meeting was called to order at 8:10 AM by Technical Committee Chair Al Ramirez. 2. Attendees introduced themselves and necessary corrections were made to the Technical Committee roster. The corrected roster will be posted to the NFPA 30A Document Information Web Page. 3. The Minutes of the previous meeting (December 11, 2012, NFPA Offices, Quincy MA were unanimously approved as corrected with the addition to Mr. Kraus to the attendance list. 4. Technical Committee Chair Al Ramirez reviewed the meeting agenda. 5. The Staff Liaison reported on the following items: Technical Committee Membership Status. The Staff Liaison reviewed recent changes to the Technical Committee s membership. A2014 Document Revision Schedule. The Staff Liaison reviewed the schedule of the Annual 2014 document revision cycle. 6. The Technical Committee reviewed the proposed new scope statement, as recommended by a Task Group chaired by Marshall Klein. The Technical Committee made the following changes: - Replace automotive with motor vehicle. Replace repair garages with repair facilities. - Change ventilations to singular. - Change name of committee to Technical Committee on Motor Fuel Dispensing Facilities and Motor Vehicle Repair Facilities. The Staff Liaison was directed to ballot these changes through the Technical Committee in preparation for submitting to the NFPA Standards Council. 7. The Technical Committee reviewed the report of the Chapter 12 Task Group, chaired by Douglas Horne. 8. The Technical Committee reviewed and took action on all Public Comments received on the First Draft Report on NFPA 30A. 9. There was no correspondence requiring the Technical Committee s attention. 10. There was no old business requiring the Technical Committee s attention. 11. The following items of new business were handled: Impact of Alternative Fuels. The Technical Committee held a round table discussion on the various new fuels and their probable impact on NFPA 30A. AUV Minutes.doc

9 Amendments to Section The Technical Committee agreed to review the entirety of Chapter 11 during the next cycle. Work Areas for Next Revision Cycle. The Technical Committee agreed to identify agenda items for the next document revision cycle for NFPA Schedule Next Meeting(s). The Technical Committee deferred scheduling the next meeting. 13. The meeting adjourned at 3:00 PM. AUV Minutes.doc

10 Proposed New Technical Committee Name and Scope 1. Replace the current name of the Technical Committee (Technical Committee on Automotive and Marine Service Stations) with the following: Technical Committee on Motor Fuel Dispensing Facilities and Motor Vehicle Repair Facilities JUSTIFICATION: First, the current committee name dates back to its inception, when it dealt almost exclusively with traditional retail service stations. It now covers fleet fuel dispensing operations and repair garages (having absorbed the former NFPA 88B, Standard for Repair Garages). The scope of the committee now embraces almost all motor vehicle fuel dispensing operations, except those dealing exclusively with gaseous fuels and major repair facilities, such as fleet and vehicle dealership maintenance operations. YES NO ABSTAIN Reason for NO or ABSTAIN: 2. Revise the Technical Committee Scope to read as follows: This Committee shall have primary responsibility for documents on safeguarding against the fire and explosion hazards associated with the general storage, handling, and dispensing of flammable liquids, and combustible liquids, and gaseous fuels at motor fuel dispensing facilities; automotive and marine service stations, farms;, and isolated construction sites; and with related activities, such as operation, inspection, and maintenance of fuel dispensing and storage systems and components gaseous fuels. This Committee shall have responsibility for the dispensing of gaseous fuels only at facilities where liquid fuels are also dispensed. This committee shall also have primary responsibility for documents on construction, control of fire hazards, ventilation, fire protection, and maintenance of motor vehicle repair facilities garages. Responsible for NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages. JUSTIFICATION: These amendments accomplish two objectives. They succinctly and comprehensively describe the subject areas covered by the document(s) under the jurisdiction of this committee. A specific statement is made governing this committee s limitations with respect to gaseous fueling operations. YES NO ABSTAIN Reason for NO or ABSTAIN:

11 TECHNICAL COMMITTEE ON AUTOMOTIVE and MARINE SERVICE STATIONS SCOPE STATEMENT This Committee shall have primary responsibility for documents on safeguarding against the fire and explosion hazards associated with the general storage, handling, and dispensing of flammable and combustible liquids at automotive and marine service stations, farms, and isolated construction sites and with related activities, such as dispensing gaseous fuels. This committee shall also have primary responsibility for documents on construction, control of fire hazards, ventilation, fire protection, and maintenance of repair garages. Responsible for NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages. COMMITTEE MEMBERSHIP BALANCE Principals: 26 M: 9 (35%)* U: 4 (15%)** Voting Alternates: 0 I/M: 4 (15%)*** L/C: 0 Alternates: 9 R/T: 2 (8%) E: 2 (8%) Non-Voting: 2 I: 2 (8%) SE: 3 (12%) Emeritus 0 Task Group: 0 Hold List: 0 Balance: Overbalanced by 1 M *(fuel handling equipment - all fuels: 2 fuel handling equipment - CNG: 0 fuel handling equipment - liquid fuels: 2 fuel handling equipment - LNG: 1 fire suppression equipment: 2 storage tanks - liquid fuels: 2) **(fleet operators: 0 lube-only/repair: 1 marine: 1 retail: 2) ***(fire suppression systems: 1 liquid & gaseous fuel dispensing/storage systems: 1 liquid fuel dispensing systems: 0 LPG dispensing systems: 1 marine fuel dispensing systems: 1) AUV Scope Statement & Member Balance.doc - 10/27/2015

12 2017 ANNUAL 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* 7/6/15 7/6/15 Final Date for TC First Draft Meeting 12/14/15 9/14/15 Public Input Posting of First Draft and TC Ballot 2/1/16 10/26/15 Stage Final date for Receipt of TC First Draft ballot 2/22/16 11/16/15 `(First Draft) Final date for Receipt of TC First Draft ballot recirc 2/29/16 11/23/15 Posting of First Draft for CC Meeting 11/30/15 Final date for CC First Draft Meeting 1/11/16 Posting of First Draft and CC Ballot 2/1/16 Final date for Receipt of CC First Draft ballot 2/22/16 Final date for Receipt of CC First Draft ballot recirc 2/29/16 Post First Draft Report for Public Comment 3/7/16 3/7/16 Public Comment closing date 5/16/16 5/16/16 Final Date to Publish Notice of Consent Standards (Standards that 5/30/16 5/30/16 received no Comments) Appeal Closing Date for Consent Standards (Standards that received 6/13/16 6/13/16 no Comments) Final date for TC Second Draft Meeting 10/31/16 7/25/16 Comment Posting of Second Draft and TC Ballot 12/12/16 9/5/16 Stage Final date for Receipt of TC Second Draft ballot 1/2/17 9/26/16 (Second Final date for receipt of TC Second Draft ballot recirc 1/9/17 10/3/16 Draft) Posting of Second Draft for CC Meeting 10/10/16 Final date for CC Second Draft Meeting 11/21/16 Posting of Second Draft for CC Ballot 12/12/16 Final date for Receipt of CC Second Draft ballot 1/2/17 Final date for Receipt of CC Second Draft ballot recirc 1/9/17 Post Second Draft Report for NITMAM Review 1/16/17 1/16/17 Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 2/20/17 2/20/17 Preparation Posting of Certified Amending Motions (CAMs) and Consent 4/17/17 4/17/17 Standards (& Issuance) Appeal Closing Date for Consent Standards 5/2/17 5/2/17 SC Issuance Date for Consent Standards 5/12/17 5/12/17 Tech Session Association Meeting for Standards with CAMs 6/4 7/2017 6/4 7/2017 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

13 Benedetti, Bob From: Sent: To: Subject: Bershad, Susan Friday, October 02, :06 PM Bershad, Susan; Benedetti, Bob; Joint Task Group on Multiple Fuels Dispensing Stations - NFPA 2 and NFPA 30A See below for the proposed scope for a joint task group between NFPA 30A and 2 on Multiple Fuels Dispensing Stations. This will be discussed at the upcoming NFPA 30A first draft meeting in October. If you are interested in participating on the task group, please let me (Susan Bershad, staff liaison for NFPA 2), Bob Benedetti (staff liaison for NFPA 30A) or your respective chair know. Please let me know if you have any questions or need additional information. Thanks. Joint Task Group NFPA 30A/NFPA 2 Multiple Fuels Dispensing Stations Scope: Joint task group between NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages and NFPA 2, Hydrogen Technologies Code to investigate requirements related to multi fuel (traditional gasolines, diesel fuels) combined with alternative fuels (hydrogen) in a retail fueling station setting. Dispensers for hydrogen will be located on the same fueling island as dispensers for traditional fuels. Review current content of both NFPA 30A and NFPA 2. Confirm adequacy of and proper coordination of code requirements in both NFPA 30A and NFPA 2. Develop and submit code change proposals as needed to correct any issues identified. 1

14 of /26/2015 7:46 AM Public Input No. 2-NFPA 30A-2015 [ Global Input ] Throughout standard remove references to the following and replace with the following: (1) ANSI/UL and replace with UL. (2) ANSI Z129.1 and replace with ANSI Z400.1/Z (3) API # and so on and replace API STD # or API RP #. Referenced recommended updates to correlate with PI-3 and P1-4. Related Public Inputs for This Document Related Input Public Input No. 3-NFPA 30A-2015 [Section No. 2.3] Public Input No. 4-NFPA 30A-2015 [Section No. D.1.2] Relationship Referenced current SDO addresses, standard numbers, names, and years. Referenced current SDO addresses, standard numbers, names, and years. Submitter Full Name: Aaron Adamczyk Organization: [ Not Specified ] Submittal Date: Fri Feb 06 23:51:05 EST 2015

15 of /26/2015 7:46 AM Public Input No. 39-NFPA 30A-2015 [ Section No ] 1.1.3* This code shall not apply to those motor fuel dispensing facilities where only liquefied petroleum gas (LP-Gas), liquefied natural gas (LNG), or compressed natural gas (CNG), or hydrogen is dispensed as motor fuel. NFPA 2, Hydrogen Technologies Code, is not currently recognized in Chapter 1 Administration yet NFPA 2 contains two chapters on hydrogen fueling facilities (i.e. - Chapter 10 GH2 Vehicle Fueling Facilities; and Chapter 11 LH2 Fueling Facilities) as well as a chapter on repair garages servicing hydrogen-fueled vehicles (i.e. - Chapter 18 Repair Garages). These requirements are contained only in NFPA 2 and nowhere else. Previous text in NFPA 52 has been removed. The Standards Council has revised the Scope of NFPA 52 and removed fueling of hydrogen-fuel cell vehicles (FCV). Therefore, fueling requirements for hydrogen are contained in NFPA 2 and the exclusion of section NFPA 30A should be extended to hydrogen fueling as well as CNG and LPG. Related Public Inputs for This Document Related Input Public Input No. 40-NFPA 30A-2015 [Section No. A.1.1.3] Relationship Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC Submittal Date: Wed Jul 01 17:30:24 EDT 2015

16 of /26/2015 7:46 AM Public Input No. 5-NFPA 30A-2015 [ Section No ] 1.1.3* This code shall not apply to those motor fuel dispensing facilities where only liquefied petroleum gas (LP-Gas), liquefied natural gas (LNG), or compressed natural gas (CNG), or hydrogen is dispensed as motor fuel. NFPA Standard Council has moved all hydrogen requirements from NFPA52 to NFPA2, including those for Motor Fueling Dispensing and Repair Garages. The 2011 version of the NFPA2 code had specific information on Dispensing, but not for Repair Garages (reserved). The 2016 version of NFPA2 will have specific requirements for Repair Garages and will be published prior to NFPA30A. Therefore, in order to prevent conflicting requirements, hydrogen should be excluded from NFPA30A, as is LPG, LNG, and CNG. Related Public Inputs for This Document Related Input Public Input No. 23-NFPA 30A-2015 [Section No ] Public Input No. 76-NFPA 30A-2015 [Section No. A.1.1.3] Relationship Submitter Full Name: Spencer Quong Organization: Quong & Associates Inc. Affilliation: Toyota Submittal Date: Wed Mar 18 13:22:57 EDT 2015

17 of /26/2015 7:46 AM Public Input No. 41-NFPA 30A-2015 [ Section No. 2.2 ] 2.2 NFPA Publications. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA NFPA 2, Hydrogen Technoloigies Code, 2016 edition. NFPA 10, Standard for Portable Fire Extinguishers, 2013 edition. NFPA 13, Standard for the Installation of Sprinkler Systems, 2013 edition. NFPA 14, Standard for the Installation of Standpipe and Hose Systems, 2013 edition. NFPA 30, Flammable and Combustible Liquids Code, 2015 edition. NFPA 31, Standard for the Installation of Oil-Burning Equipment, 2011 edition. NFPA 33, Standard for Spray Application Using Flammable or Combustible Materials, 2011 edition. NFPA 51, Standard for the Design and Installation of Oxygen Fuel Gas Systems for Welding, Cutting, and Allied Processes, 2013 edition. NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, 2014 edition. NFPA 52, Vehicular Gaseous Fuel Systems Code, 2013 edition. NFPA 54, National Fuel Gas Code, 2015 edition. NFPA 55, Compressed Gases and Cryogenic Fluids Code, 2013 edition. NFPA 58, Liquefied Petroleum Gas Code, 2014 edition. NFPA 70, National Electrical Code, 2014 edition. NFPA 72, National Fire Alarm and Signaling Code, 2013 edition. NFPA 80, Standard for Fire Doors and Other Opening Protectives, 2013 edition. NFPA 82, Standard on Incinerators and Waste and Linen Handling Systems and Equipment, 2014 edition. NFPA 85, Boiler and Combustion Systems Hazards Code, 2011 edition. NFPA 86, Standard for Ovens and Furnaces, 2015 edition. NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems, 2015 edition. NFPA 91, Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Noncombustible Particulate Solids, 2010 edition. NFPA 101, Life Safety Code, 2015 edition. NFPA 211, Standard for Chimneys, Fireplaces, Vents, and Solid Fuel Burning Appliances, 2013 edition. NFPA 220, Standard on Types of Building Construction, 2015 edition. NFPA 253, Standard Method of Test for Critical Radiant Flux of Floor Covering Systems Using a Radiant Heat Energy Source, 2011 edition. NFPA 326, Standard for the Safeguarding of Tanks and Containers for Entry, Cleaning, or Repair, 2010 edition. NFPA 385, Standard for Tank Vehicles for Flammable and Combustible Liquids, 2012 edition. Adds NFPA edition to list of references. NFPA 2, Hydrogen Technologies Code, is not currently referenced in Section 2.2 NFPA Publications. Terra seems to have added additional underlines but this is the only proposed change.

18 of /26/2015 7:46 AM Requirements for hydrogen refueling, hydrogen generation, hydrogen fuel cells, hydrogen-fueled vehicles in parking / repair garages, etc. are contained only in NFPA 2 and nowhere else. Previous text in NFPA 52 has been removed. The Standards Council has revised the Scope of NFPA 52 and removed fueling of hydrogen-fuel cell vehicles. Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC Submittal Date: Wed Jul 01 18:01:48 EDT 2015

19 of /26/2015 7:46 AM Public Input No. 8-NFPA 30A-2015 [ Section No. 2.2 ] 2.2 NFPA Publications. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA NFPA 2, Hydrogen Technologies Code, 2016 edition NFPA 10, Standard for Portable Fire Extinguishers, 2013 edition. NFPA 13, Standard for the Installation of Sprinkler Systems, 2013 edition. NFPA 14, Standard for the Installation of Standpipe and Hose Systems, 2013 edition. NFPA 30, Flammable and Combustible Liquids Code, 2015 edition. NFPA 31, Standard for the Installation of Oil-Burning Equipment, 2011 edition. NFPA 33, Standard for Spray Application Using Flammable or Combustible Materials, 2011 edition. NFPA 51, Standard for the Design and Installation of Oxygen Fuel Gas Systems for Welding, Cutting, and Allied Processes, 2013 edition. NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, 2014 edition. NFPA 52, Vehicular Gaseous Fuel Systems Code, 2013 edition. NFPA 54, National Fuel Gas Code, 2015 edition. NFPA 55, Compressed Gases and Cryogenic Fluids Code, 2013 edition. NFPA 58, Liquefied Petroleum Gas Code, 2014 edition. NFPA 70, National Electrical Code, 2014 edition. NFPA 72, National Fire Alarm and Signaling Code, 2013 edition. NFPA 80, Standard for Fire Doors and Other Opening Protectives, 2013 edition. NFPA 82, Standard on Incinerators and Waste and Linen Handling Systems and Equipment, 2014 edition. NFPA 85, Boiler and Combustion Systems Hazards Code, 2011 edition. NFPA 86, Standard for Ovens and Furnaces, 2015 edition. NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems, 2015 edition. NFPA 91, Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Noncombustible Particulate Solids, 2010 edition. NFPA 101, Life Safety Code, 2015 edition. NFPA 211, Standard for Chimneys, Fireplaces, Vents, and Solid Fuel Burning Appliances, 2013 edition. NFPA 220, Standard on Types of Building Construction, 2015 edition. NFPA 253, Standard Method of Test for Critical Radiant Flux of Floor Covering Systems Using a Radiant Heat Energy Source, 2011 edition. NFPA 326, Standard for the Safeguarding of Tanks and Containers for Entry, Cleaning, or Repair, 2010 edition. NFPA 385, Standard for Tank Vehicles for Flammable and Combustible Liquids, 2012 edition. The reference to NFPA2 is missing. In addition, the NFPA Standard Council has moved all hydrogen requirements from NFPA52 to NFPA2, including those for Motor Fueling Dispensing and Repair Garages. The 2011 version of the NFPA2 had specific information on Dispensing, but not for Repair Garages (reserved). The 2016 version of NFPA2 will have specific requirements for Repair Garages and will be published prior to NFPA30A.

20 of /26/2015 7:46 AM Submitter Full Name: Spencer Quong Organization: Quong & Associates Inc. Affilliation: Toyota Submittal Date: Wed Mar 18 13:53:16 EDT 2015

21 of /26/2015 7:46 AM Public Input No. 3-NFPA 30A-2015 [ Section No. 2.3 ] 2.3 Other Publications API Publications. American Petroleum Institute, 1220 L Street, N.W., Washington, DC API 607 API STD 607, Fire Test for Soft-Seated For Quarter-Turn Valvees And Valves Equipped With Nonmetallic Seats, 5th 6th edition, June ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA ASTM D 5 D5, Standard Test Method of Test for Penetration of Bituminous Materials, ASTM D 56 D56, Standard Test Method for Flash Point by Tag Closed Cup Tester, 2005, Reappoved ASTM D 93 D93, Standard Test Methods for Flash Point by Pensky-Martens Closed Cup Tester, 2013 e1. ASTM D 323 D323, Standard Method of Test for Vapor Pressure of Petroleum Products (Reid Method), 2008, Reapproved ASTM D 3278 D3278, Standard Test Methods for Flash Point of Liquids by Small Scale Closed-Cup Apparatus, 1996, Reapproved ASTM D 3828 D3828, Standard Test Methods for Flash Point of Liquids by Small Scale Closed Cup Tester, ASTM D 4359 D4359, Standard Test for Determining Whether a Material in a Liquid or a Solid, , Reapproved UL Publications. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL UL 87, Standard for Power-Operated Dispensing Devices for Petroleum Products, 2001, Revised ANSI/ UL 842, Standard for Valves for Flammable Fluids, 2007, Revised ANSI/ UL 2080, Standard for Fire Resistant Tanks for Flammable and Combustible Liquids, ANSI/ UL 2085, Standard for Protected Aboveground Tanks for Flammable and Combustible Liquids, 1997, Revised UL 2245, Standard for Below-Grade Vaults for Flammable Liquid Storage Tanks, ANSI/ UL 2586, Standard for Hose Nozzle Valves, 2011, Revised Other Publications. Merriam-Webster s Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, Referenced current SDO standard names, and years. Related Public Inputs for This Document Related Input Public Input No. 2-NFPA 30A-2015 [Global Input] Public Input No. 4-NFPA 30A-2015 [Section No. D.1.2] Relationship

22 of /26/2015 7:46 AM Submitter Full Name: Aaron Adamczyk Organization: [ Not Specified ] Submittal Date: Fri Feb 06 23:53:13 EST 2015

23 0 of /26/2015 7:46 AM Public Input No. 58-NFPA 30A-2015 [ Section No ] API Publications. American Petroleum Institute, 1220 L Street, N.W., Washington, DC API Std 607, Fire Test for Soft-Seated Quarter-Turn Valves, 5th edition, June and Valves Equipped with Non-Metallic Seats, 6th edition, 2010 API RP 1626, Storing and Handling of Ethanol and Gasoline-Ethanol Blends at Distribution Terminals and Filling Stations, 2nd Edition 2010 included Errata 1 (2011) and Addendum (2012) API RP 1646, Safe Work Practices for Petroleum/Convenience Facilities Downstream Segment. 1st Edition, 2006 updates and correct referenced standard. Adds two new referenced RPs proposed for addition in this code. Submitter Full Name: RICHARD KRAUS Organization: APIPETROLEUM SAFETY CONSULTAN Submittal Date: Thu Jul 02 15:20:30 EDT 2015

24 1 of /26/2015 7:46 AM Public Input No. 80-NFPA 30A-2015 [ Section No ] UL Publications. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL ANSI/ UL 79, Standard for Power-Operated Pumps for Petroleum Dispensing Products, 2014 ANSI/UL 79A Standard for Power-Operated Pumps for Gasoline and Gasoline/Ethanol Blends with Nominal Ethanol Concentrations up to 85 Percent (E0 E85), 2015 UL 87, Standard for Power-Operated Dispensing Devices for Petroleum Products, 2001, Revised ANSI/UL 87A, Standard for Power-Operated Dispensing Devices for Gasoline and Gasoline/Ethanol Blends with Nominal Ethanol Concentrations Up to 85 Percent (E0-E85), 2015 ANSI/UL 330, Standard for Hose and Hose Assemblies for Dispensing Flammable Liquids, 2013 UL 330A Outline of Investigation for Hose and Hose Assemblies for Use With Dispensing Devices Dispensing Gasoline and Gasoline/Ethanol Blends With Nominal Ethanol Concentrations Up To 85 Percent (E0 - E85), 2012 ANSI/UL 567, Standard for Emergency Breakaway Fittings, Swivel Connectors and Pipe-Connection Fittings for Petroleum Products and LP-Gas, 2014 ANSI/UL 567A Standard for Emergency Breakaway Fittings, Swivel Connectors and Pipe-Connection Fittings for Gasoline and Gasoline/Ethanol Blends with Nominal Ethanol Concentrations up to 85 Percent (E0 - E85), 2015 ANSI/UL 842, Standard for Valves for Flammable Fluids, 2007, Revised ANSI/UL 842A Standard for Valves for Gasoline and Gasoline/Ethanol Blends with Nominal Ethanol Concentrations up to 85 Percent (E0 - E85), 2015 ANSI/UL 2080, Standard for Fire Resistant Tanks for Flammable and Combustible Liquids, ANSI/UL 2085, Standard for Protected Aboveground Tanks for Flammable and Combustible Liquids, 1997, Revised UL 2245, Standard for Below-Grade Vaults for Flammable Liquid Storage Tanks, ANSI/UL 2586, Standard for Hose Nozzle Valves, 2011, Revised ANSI/UL 2586A Standard for Hose Nozzle Valves for Gasoline and Gasoline/Ethanol Blends with Nominal Ethanol Concentrations up to 85 Percent (E0 - E85), 2015 These standards have been added as reference standards in the body of the code, many of them were previously included in the annex. Corresponding code changes propose reference to these standards in the body of the code. This change will now allow them to be enforced rather than suggested to be followed. Submitter Full Name: HOWARD HOPPER Organization: UL LLC Submittal Date: Mon Jul 06 16:28:47 EDT 2015

25 2 of /26/2015 7:46 AM Public Input No. 42-NFPA 30A-2015 [ Section No. 2.4 ] 2.4 References for Extracts in Mandatory Sections. NFPA 2, Hydrogen Technologies Code, 2016 edition. NFPA 30, Flammable and Combustible Liquids Code, 2015 edition. Adds NFPA to the list in section 2.4. No other changes proposed despite what Terra may be showing. NFPA 2, Hydrogen Technologies Code, is not currently referenced in Section 2.4 References for Extracts in Mandatory Sections. Requirements for hydrogen refueling, hydrogen generation, hydrogen fuel cells, hydrogen-fueled vehicles in parking / repair garages, etc. are contained only in NFPA 2 and nowhere else. Previous text in NFPA 52 has been removed. The Standards Council has revised the Scope of NFPA 52 and removed fueling of hydrogen-fuel cell vehicles (FCV). NFPA 30A contains section that are mandatory per NFPA 2. NFPA 2 is a mandatory reference. Related Public Inputs for This Document Related Input Public Input No. 38-NFPA 30A-2015 [Section No ] Relationship The text proosed in as well in other sections makes NFPA 2 a mandatory reference. Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC Submittal Date: Wed Jul 01 18:07:24 EDT 2015

26 3 of /26/2015 7:46 AM Public Input No. 63-NFPA 30A-2015 [ Section No. 2.4 ] 2.4 References for Extracts in Mandatory Sections. NFPA 2, Hydrogen Technologies Code, 2016 edition. NFPA 30, Flammable and Combustible Liquids Code, 2015 edition. NFPA Standard Council has moved all hydrogen requirements from NFPA52 to NFPA2, including those for Motor Fueling Dispensing and Repair Garages. The 2011 version of the NFPA2 had specific information on Dispensing, but not for Repair Garages (reserved). The 2016 version of NFPA2 will have specific requirements for Repair Garages and will be published prior to NFPA30A. PI 22 makes a mandatory reference to NFPA2. Related Public Inputs for This Document Related Input Public Input No. 22-NFPA 30A-2015 [Section No ] Relationship PI 22 provides a mandatory reference to NFPA2 Submitter Full Name: SPENCER QUONG Organization: QUONG & ASSOCIATES INC Affilliation: TOYOTA Submittal Date: Mon Jul 06 13:36:55 EDT 2015

27 4 of /26/2015 7:46 AM Public Input No. 57-NFPA 30A-2015 [ Section No. 4.2 ] 4.2 General Requirements Liquids shall be stored in the following: (1) Approved closed containers that do not exceed 227 L (60 gal) capacity and are located outside buildings (2) Tanks or approved closed containers located inside motor fuel dispensing facilities or repair garages (3) Aboveground tanks, underground tanks, and containers in accordance with the requirements of Section 4.3 (4) Tanks supplying marine service stations in accordance with Section A motor fuel dispensing facility located at a bulk plant shall be separated from areas in which bulk plant operations are conducted by a fence or other approved barrier. Dispensing devices at the motor fuel dispensing facility shall not be supplied by aboveground tanks located in the bulk plant. Storage tanks at motor fuel dispensing facilities shall not be connected by piping to aboveground tanks located in the bulk plant Class I liquids shall not be stored or handled in a building that has a basement or pit into which ignitible vapors can travel, unless the basement or pit is provided with ventilation that will prevent the accumulation of vapors. The ventilation system shall be capable of providing at least 0.3 m 3 /min of exhaust per m 2 of floor area (1 cfm per ft 2 ), but not less than 4 m 3 /min (150 ft 3 /min) Where tanks are at an elevation that produces a gravity head on the dispensing device, the tank outlet shall be equipped with a device, such as a normally closed solenoid valve, positioned adjacent to and downstream from the valve specified in of NFPA 30, Flammable and Combustible Liquids Code, that is installed and adjusted so that liquid cannot flow by gravity from the tank if the piping or hose fails when the dispenser is not in use Storage of ethanol and gasoline ethanol blends shll be in coordance with the requirements of API RP adds new section providing for safe handling and storage of ethanol based fuels Submitter Full Name: RICHARD KRAUS Organization: APIPETROLEUM SAFETY CONSULTAN Submittal Date: Thu Jul 02 15:14:32 EDT 2015

28 5 of /26/2015 7:46 AM Public Input No. 61-NFPA 30A-2015 [ New Section after ] TITLE OF NEW CONTENT Type your content here Non-metallic tanks manufactured in compliance with and listed to UL SU 2258 shall be applicable in indoor and outdoor aboveground installation for Class II, Class IIIA and Class IIIB liquids. Installation, spacing and venting per the requirements of Section 4.3, Storage of Liquids This addition to NFPA 30A would allow tanks manufactured to UL SU 2259 to be applied in combustible liquids storage installations where specified in the scope of SU 2258 supported by extensive and rigorous testing requirements of the standard. From Subject 2258 Introduction: 1.1 These requirements cover nonmetallic or composite primary, secondary and diked type atmospheric tanks from gallons ( L) intended primarily for the storage and supply of heating fuel for oil burning equipment, or alternately the storage of diesel fuels for compression ignition engines and motor oils (new and used) for automotive service stations, in above ground installations. With the exception of standards UL 2080 (fire resistant tanks) and UL 2085 (protected tanks), UL SU 2258 would be the only other construction standard for combustible liquid storage with a pool fire test requirement. Submitter Full Name: BRUCE STOWE Organization: ROTH INDUSTRIES INCORPORATED Affilliation: N/A Submittal Date: Mon Jul 06 11:17:30 EDT 2015

29 6 of /26/2015 7:46 AM Public Input No. 35-NFPA 30A-2015 [ New Section after ] All devices and components of the tank and piping system must follow manufactures recommendations for installation, calibration, maintenance, etc. Not enforceable as written. Must have guideline requirements to ensure proper installation and maintenance. Submitter Full Name: MARCIA POXSON Organization: MICHIGAN BUREAU OF FIRE SERVIC Submittal Date: Tue Jun 30 14:24:46 EDT 2015

30 7 of /26/2015 7:46 AM Public Input No. 36-NFPA 30A-2015 [ New Section after 5.7 ] 5.8 Underground Piping. Underground piping must be approved doublewall with approved monitoring. Aligns NFPA requirements with federal underground storage tank rules. Requiring monitoring of underground piping would prevent or limit environment exposure and hence, fire potential. Submitter Full Name: MARCIA POXSON Organization: MICHIGAN BUREAU OF FIRE SERVIC Submittal Date: Tue Jun 30 14:27:19 EDT 2015

31 8 of /26/2015 7:46 AM Public Input No. 79-NFPA 30A-2015 [ New Section after ] Fuel dispensing systems and components intended for use with ethanol or gasoline/ethanol mixtures above E10 shall be listed in accordance with the following standards. (1) Dispensers: ANSI/UL 87A Standard for Power-Operated Dispensing Devices for Gasoline or Gasoline/Ethanol Blends with Nominal Ethanol Concentrations Up to 85 Percent (E0-E85). (2) Pumps: ANSI/UL 79 Standard for Power-Operated Pumps for Gasoline and Gasoline/Ethanol Blends with Nominal Ethanol Concentrations Up to 85 Percent (E0 - E85). (3) Hose Assemblies: UL 330A Outline for Hose and Hose Assemblies for Use With Dispensing Devices Dispensing Gasoline and Gasoline/Ethanol Blends With Nominal Ethanol Concentrations Up To 85 Percent (E0 - E85), (4) Hose Nozzles Valves: UL 2586A Standard for Hose Nozzle Valves for Gasoline and Gasoline/Ethanol Blends with Nominal Ethanol Concentrations Up to 85 Percent (E0 - E85). (5) Swivel Connectors: UL 567A Standard for Emergency Breakaway Fittings, Swivel Connectors and Pipe-Connection Fittings for Gasoline/Ethanol Blends with Nominal Ethanol Concentrations Up to 85 Percent (E0 - E85. (6) Breakaways: UL 567A Standard for Emergency Breakaway Fittings, Swivel Connectors and Pipe-Connection Fittings for Gasoline/Ethanol Blends with Nominal Ethanol Concentrations Up to 85 Percent (E0 - E85). (7) Dispenser Emergency Shutoff Valves UL 842A Standard for Valves for Gasoline and Gasoline/Ethanol Blends with Nominal Ethanol Concentrations up to 85 Percent (E0 - E85) Section currently requires dispensing equipment intended for use with alcohol-blended motor fuels to be listed or approved for the specific purpose. This was a good requirement when systems and components were not listed for this use. However a new generation of UL standards was developed to evaluate and list the components covered by this section for such use. This proposal provides the code user with references to the standards used to evaluate fuels with ethanol concentrations above E10. Submitter Full Name: HOWARD HOPPER Organization: UL LLC Submittal Date: Mon Jul 06 16:10:28 EDT 2015

32 9 of /26/2015 7:46 AM Public Input No. 78-NFPA 30A-2015 [ Section No ] * Fuel dispensing systems, including dispensers, hoses, nozzles, breakaway fittings, swivels, flexible connectors, dispenser emergency shutoff valves, vapor recovery systems, and pumps that are used for alcohol-blended motor fuels shall be listed or approved for the specific purpose. and components shall be listed in accordance with the following standards, or the standards included in Section 6.2.4: (1) Dispensers: ANSI/UL 87A Standard for Power-Operated Dispensing Devices for Petroleum Products. (2) Pumps: ANSI/UL 79, Standard for Powered-Operated Pumps for Petroleum Dispensing Products. (3) Hose Assemblies: ANSI/UL 330, Standard for Hose and Hose Assemblies for Dispensing Flammable Liquids. (4) Hose Nozzles Valves: ANSI/UL 2586, Standard for Hose Nozzle Valves. (5) Swivel Connectors: ANSI/UL 567, Standard for Emergency Breakaway Fittings, Swivel Connectors and Pipe-Connection Fittings for Petroleum Products. (6) Breakaways: ANSI/UL 567, Standard for Emergency Breakaway Fittings, Swivel Connectors and Pipe-Connection Fittings for Petroleum Products. (7) Dispenser Emergency Shutoff Valves ANSI/UL 842, Standard for Valves for Flammable Fluids. The body of the code stated that specific products were to be listed but there was no listed standard in the body of the code to support the requirement it was located in the Annex, which is unenforceable. This creates an enforcement nightmare because there was a disconnection between what the code demands and the means to attain it. This change resolves that issue. Submitter Full Name: HOWARD HOPPER Organization: UL LLC Submittal Date: Mon Jul 06 16:00:10 EDT 2015

33 0 of /26/2015 7:46 AM Public Input No. 83-NFPA 30A-2015 [ Section No ] Dispensing devices for Class I and Class II liquids shall be listed in accordance with ANSI/UL 87A Standard for Power-Operated Dispensing Devices for Gasoline or ANSI/UL 87A Standard for Power- Operated Dispensing Devices for Gasoline or Gasoline/Ethanol Blends with Nominal Ethanol Concentrations Up to 85 Percent (E0-E85) Existing listed or labeled dispensing devices shall be permitted to be modified provided that the modifications made are Listed by Report by an approved testing laboratory or as otherwise approved by the authority having jurisdiction. Modification proposals shall contain a description of the component parts used in the modification and the recommended methods of installation on specific dispensing devices. Modification proposals shall be made available to the authority having jurisdiction upon request. This proposal clarifies the standards used to list dispensing devices. In a separate proposal UL 87A was added to Section Submitter Full Name: HOWARD HOPPER Organization: UL LLC Submittal Date: Mon Jul 06 16:41:43 EDT 2015

34 1 of /26/2015 7:46 AM Public Input No. 14-NFPA 30A-2015 [ Section No ] Each pump shall have installed on the discharge side a listed leak detection device that will provide an audible or visible indication restricts or shuts off the flow of product. if the piping or a dispenser is leaking. Each leak-detecting device shall be checked and tested at least annually according to the manufacturer's specifications to ensure proper installation and operation. Exception: A leak detection device shall not be required if all piping is visible. Additional Proposed Changes File Name 30A-PC7.pdf Description Approved 30A PC7 NOTE: The following Public Input appeared as "Reject but Hold" in Public Comment No. 7 of the A2014 Second Draft Report for NFPA 30A and per the Regs. at The wording in this section of the code makes it impossible to comply with. No leak detector installed on the discharge side of the pump provides an audible or visible alarm. Line leak detectors used on remote submersible pumps are not capable of sounding an audible or visible alarm, they use a pressure differential in the piping to either restrict the flow of product to the dispenser (mechanical line leak detectors) or shut off the flow of product (electronic line leak detectors). Submitter Full TC ON AUV-AAA Name: NFPA Technical Committee on Automotive and Marine Service Organization: Stations Submittal Date: Thu Mar 26 10:49:50 EDT 2015

35 of 1 3/26/2015 9:45 AM Public Comment No. 7-NFPA 30A-2013 [ Section No ] Each pump shall have installed on the discharge side a listed leak detection device that will provide an audible or visible indication restricts or shuts off the flow of product if the piping or a dispenser is leaking. Each leak-detecting device shall be checked and tested at least annually according to the manufacturer's specifications to ensure proper installation and operation. Exception : A leak detection device shall not be required if all piping is visible. Additional Proposed Changes File Name Description Approved 30A_Ralston_6.4.2.docx Cover Sheet Statement of Problem and Substantiation for Public Comment The wording in this section of the code makes it impossible to comply with. No leak detector installed on the discharge side of the pump provides an audible or visible alarm. Line leak detectors used on remote submersible pumps are not capable of sounding an audible or visible alarm, they use a pressure differential in the piping to either restrict the flow of product to the dispenser (mechanical line leak detectors) or shut off the flow of product (electronic line leak detectors). Submitter Full Name: ALEX RALSTON Organization: PETCON INC Submittal Date: Tue Apr 23 08:30:19 EDT 2013 Committee Statement Committee Action: Resolution: Rejected but held Public Comment No. 7 proposes a change to a paragraph in NFPA 30A that was not amended at the First Draft stage of this revision cycle. To accept this change would effect an amendment to the Code without its having undergone public review and comment. Therefore, in accordance with Paragraphs and of the Regulations Governing the Development of NFPA Standards, the Technical Committee has voted to reject Public Comment No. 7 and hold it for processing as a Public Input at the next document revision cycle. Copyright Assignment I, ALEX RALSTON, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am ALEX RALSTON, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature

36 2 of /26/2015 7:46 AM Public Input No. 84-NFPA 30A-2015 [ Section No ] Listed hose assemblies shall be used to dispense fuel. Hose Hose assemblies shall be be listed in accordance with ANSI/UL 330, Standard for Hose and Hose Assemblies for Dispensing Flammable Liquids or UL 330A Outline for Hose and Hose Assemblies for Use With Dispensing Devices Dispensing Gasoline and Gasoline/Ethanol Blends With Nominal Ethanol Concentrations Up To 85 Percent (E0 - E85). H ose length at automotive motor fuel dispensing facilities shall not exceed 5.5 m (18 ft). Where hose length at marine motor fuel dispensing facilities exceeds 5.5 m (18 ft), the hose shall be secured so as to protect it from damage. This identifies the standards used to investigate and list hose assemblies. Submitter Full Name: HOWARD HOPPER Organization: UL LLC Submittal Date: Mon Jul 06 16:47:54 EDT 2015

37 3 of /26/2015 7:46 AM Public Input No. 15-NFPA 30A-2015 [ Sections 6.7.1, ] Sections 6.7.1, At attended motor fuel dispensing facilities, the devices or disconnects shall be readily accessible to the attendant and labeled with an approved sign stating "EMERGENCY FUEL SHUTOFF" At unattended motor fuel dispensing facilities, the devices or disconnects shall be readily accessible to patrons and at least one additional device or disconnect shall be readily accessible to each group of dispensing devices on an individual island. The device(s) or disconnect(s) shall be labeled with an approved sign stating "EMERGENCY FUEL SHUTOFF". Additional Proposed Changes File Name Description Approved 30A-PC4.pdf NFPA 30A Public Comment 4. NOTE: The following Public Input appeared as "Reject but Hold" in Public Comment No. 4 of the A2014 Second Draft Report for NFPA 30A and per the Regs. at Shut-offs should be labeled as to their operation so they can be easily identified by attendants and/or patrons that may be required to use them. Submitter Full TC ON AUV-AAA Name: NFPA Technical Committee on Automotive and Marine Service Organization: Stations Submittal Date: Thu Mar 26 11:01:26 EDT 2015

38 of 1 3/26/2015 9:48 AM Public Comment No. 4-NFPA 30A-2013 [ Sections 6.7.1, ] Sections 6.7.1, At attended motor fuel dispensing facilities, the devices or disconnects shall be readily accessible to the attendant and labeled with an approved sign stating EMERGENCY FUEL SHUTOFF At unattended motor fuel dispensing facilities, the devices or disconnects shall be readily accessible to patrons and at least one additional device or disconnect shall be readily accessible to each group of dispensing devices on an individual island. The device(s) or disconnect(s) shall be labeled with an approved sign stating EMERGENCY FUEL SHUTOFF. Statement of Problem and Substantiation for Public Comment Shut-offs should be labeled as to their operation so they can be easily identified by attendants and/or patrons that may be required to use them. Submitter Full Name: Doug Hohbein Organization: Northcentral Fire Code Develop Submittal Date: Tue Apr 02 22:00:55 EDT 2013 Committee Statement Committee Action: Resolution: Rejected but held Public Comment No. 4 proposes a change to a paragraph in NFPA 30A that was not amended at the First Draft stage of this revision cycle. To accept this change would effect an amendment to the Code without its having undergone public review and comment. Therefore, in accordance with Paragraphs and of the Regulations Governing the Development of NFPA Standards, the Technical Committee has voted to reject Public Comment No. 4 and hold it for processing as a Public Input at the next document revision cycle. Copyright Assignment I, Doug Hohbein, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Doug Hohbein, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature

39 4 of /26/2015 7:46 AM Public Input No. 59-NFPA 30A-2015 [ New Section after 7.2 ] TITLE OF NEW CONTENT Type your content here Safe Construction Practices Contractors working at service station facilities shall comply with the requirements of API RP 1646, Safe Work Practices for Contractors Working at Retail Petroleum/Convenience Facilities.... Provides safety requirements for contractors working in service stations Submitter Full Name: RICHARD KRAUS Organization: APIPETROLEUM SAFETY CONSULTAN Submittal Date: Thu Jul 02 15:37:10 EDT 2015

40 5 of /26/2015 7:46 AM Public Input No. 45-NFPA 30A-2015 [ Section No ] Occupancy Classification. The occupancy classification of a motor fuel dispensing facility that is located inside a building or structure shall be a special purpose industrial occupancy as defined in NFPA 101, Life Safety Code determined in accordance with the building code adopted for the jurisdiction. Occupancy classifications are assigned by the Building code adopted in a jurisdiction. Special purpose industrial occupancy is an incorrect classification (see below) and this is a complicated situation best handled by requirements already clearly established in the building code. For most occupancies, adding a motor fuel dispensing facility inside an existing building would cause the MAQ to be exceeded if the storage is also inside, which would cause the occupancy to be a high hazard Group H occupancy and/or invoke additional Protection Level requirement (analogous to Group H) if NFPA 1 were to be enforced. Regardless, a special purpose industrial occupancy has lower egress requirements (not higher) that a standard industrial occupancy so this is not an appropriate occupancy classification. Special-purpose industrial occupancies are intended for occupancies with uniquely low occupant load factors; not for occupancies that perform unique operations. Fuel dispensing facilities do not experience uniquely low occupant loads. In addition, egress may be inadequate if classified as a special purpose industrial occupancy. Refer to definition in NFPA 101 below as evidence that this classification is not applicable to fuel dispensing facilities: Special-Purpose Industrial Occupancy. An industrial occupancy in which ordinary and low hazard industrial operations are conducted in buildings designed for, and suitable only for, particular types of operations, characterized by a relatively low density of employee population, with much of the area occupied by machinery or equipment. Related Public Inputs for This Document Related Input Public Input No. 46-NFPA 30A-2015 [Section No ] Relationship Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC Submittal Date: Wed Jul 01 18:35:03 EDT 2015

41 6 of /26/2015 7:46 AM Public Input No. 46-NFPA 30A-2015 [ Section No ] Occupancy Classification. The occupancy classification of a motor fuel dispensing facility that is located inside a building or structure shall be a special purpose an industrial occupancy as defined in NFPA 101, Life Safety Code. The change proposed in PI No 45 is preferred over this one but if PI No 45 is rejected (resolved) then this one is my 2nd choice. Special-purpose industrial occupancies are intended for occupancies with uniquely low occupant load factors; not for occupancies that perform unique operations. Fuel dispensing facilities do not experience uniquely low occupant loads. In addition, egress may be inadequate if classified as a special purpose industrial occupancy. Refer to definition in NFPA 101 below as evidence that this classification is not applicable to fuel dispensing facilities: Special-Purpose Industrial Occupancy. An industrial occupancy in which ordinary and low hazard industrial operations are conducted in buildings designed for, and suitable only for, particular types of operations, characterized by a relatively low density of employee population, with much of the area occupied by machinery or equipment. Related Public Inputs for This Document Related Input Public Input No. 45-NFPA 30A-2015 [Section No ] Relationship If PI 45 is accepted then this one should be rejected. And vice-versa. Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC Submittal Date: Wed Jul 01 18:53:49 EDT 2015

42 7 of /26/2015 7:46 AM Public Input No. 64-NFPA 30A-2015 [ Section No ] Occupancy Classification. The occupancy classification of a motor fuel dispensing facility that is located inside a building or structure shall be a special purpose industrial occupancy as defined in NFPA 101, Life Safety Code be in accordance with the building code adopted for the jurisdiction. Occupancy classifications are assigned by the Building code adopted in a jurisdiction. Special purpose industrial occupancy is an incorrect classification (see below) and this is a complicated situation best handled by requirements already clearly established in the building code. For most occupancies, adding a motor fuel dispensing facility inside an existing building would cause the MAQ to be exceeded if the storage is also inside, which would cause the occupancy to be a high hazard Group H occupancy and/or invoke additional Protection Level requirement (analogous to Group H) if NFPA 1 were to be enforced. Regardless, a special purpose industrial occupancy has lower egress requirements (not higher) that a standard industrial occupancy so this is not an appropriate occupancy classification. Special-purpose industrial occupancies are intended for occupancies with uniquely low occupant load factors; not for occupancies that perform unique operations. Fuel dispensing facilities do not experience uniquely low occupant loads. In addition, egress may be inadequate if classified as a special purpose industrial occupancy. Refer to definition in NFPA 101 below as evidence that this classification is not applicable to fuel dispensing facilities: Special-Purpose Industrial Occupancy. An industrial occupancy in which ordinary and low hazard industrial operations are conducted in buildings designed for, and suitable only for, particular types of operations, characterized by a relatively low density of employee population, with much of the area occupied by machinery or equipment. Related Public Inputs for This Document Related Input Public Input No. 65-NFPA 30A-2015 [Section No ] Relationship Submitter Full Name: SPENCER QUONG Organization: QUONG ASSOCIATES INC Affilliation: TOYOTA Submittal Date: Mon Jul 06 13:50:05 EDT 2015

43 8 of /26/2015 7:46 AM Public Input No. 65-NFPA 30A-2015 [ Section No ] Occupancy Classification. The occupancy classification of a motor fuel dispensing facility that is located inside a building or structure shall be a special purpose an industrial occupancy as defined in NFPA 101, Life Safety Code. PI 65 should only be considered if PI 64 is rejected. Special-purpose industrial occupancies are intended for occupancies with uniquely low occupant load factors; not for occupancies that perform unique operations. Fuel dispensing facilities do not experience uniquely low occupant loads. In addition, egress may be inadequate if classified as a special purpose industrial occupancy. Refer to definition in NFPA 101 below as evidence that this classification is not applicable to fuel dispensing facilities: Special-Purpose Industrial Occupancy. An industrial occupancy in which ordinary and low hazard industrial operations are conducted in buildings designed for, and suitable only for, particular types of operations, characterized by a relatively low density of employee population, with much of the area occupied by machinery or equipment. Related Public Inputs for This Document Related Input Public Input No. 64-NFPA 30A-2015 [Section No ] Relationship Optional proposal if PI64 rejected Submitter Full Name: SPENCER QUONG Organization: QUONG ASSOCIATES INC Affilliation: TOYOTA Submittal Date: Mon Jul 06 13:53:24 EDT 2015

44 9 of /26/2015 7:46 AM Public Input No. 47-NFPA 30A-2015 [ Section No ] Means of Egress. In a motor fuel dispensing facility that is located inside a building or structure, the required number, location, and construction of means of egress shall meet all applicable requirements for special purpose industrial occupancies, as set forth in NFPA 101, Life Safety Code. Occupancy classifications are assigned by the Building code adopted in a jurisdiction. The building code adopted by the jurisdiction will address egress. This section is not needed. If a jurisdiction uses NFPA 101 for egress, then the conflict between the IBC and NFPA 101 will be addressed in their adopting ordinances (typically by adopting NFPA 101 instead of IBC Ch 10. Either way, this section is not needed and creates conflict as is. Related Public Inputs for This Document Related Input Public Input No. 48-NFPA 30A-2015 [Section No ] Relationship Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC Submittal Date: Wed Jul 01 19:02:38 EDT 2015

45 0 of /26/2015 7:46 AM Public Input No. 48-NFPA 30A-2015 [ Section No ] Means of Egress. In a motor fuel dispensing facility that is located inside a building or structure, the required number, location, and construction of means of egress shall meet all applicable requirements for special purpose industrial occupancies, as set forth in NFPA 101, Life Safety Code. Only needed if PI47 is rejected. If PI47 is approve then reject this one. Special-purpose industrial occupancies are intended for occupancies with uniquely low occupant load factors; not for occupancies that perform unique operations. Fuel dispensing facilities do not experience uniquely low occupant loads. In addition, egress may be inadequate if classified as a special purpose industrial occupancy. Refer to definition in NFPA 101 below as evidence that this classification is not applicable to fuel dispensing facilities: Special-Purpose Industrial Occupancy. An industrial occupancy in which ordinary and low hazard industrial operations are conducted in buildings designed for, and suitable only for, particular types of operations, characterized by a relatively low density of employee population, with much of the area occupied by machinery or equipment. Related Public Inputs for This Document Related Input Public Input No. 47-NFPA 30A-2015 [Section No ] Relationship If PI 47 is approved then this one is not needed and should be rejected. Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC Submittal Date: Wed Jul 01 19:15:47 EDT 2015

46 1 of /26/2015 7:46 AM Public Input No. 66-NFPA 30A-2015 [ Section No ] Means of Egress. In a motor fuel dispensing facility that is located inside a building or structure, the required number, location, and construction of means of egress shall meet all applicable requirements for special purpose industrial occupancies, as set forth in NFPA 101, Life Safety Code. This section is not needed because occupancy classifications and "means of egress" are assigned by the Building code adopted in a jurisdiction.if a jurisdiction uses NFPA 101 for egress, then the conflict between the IBC and NFPA 101 will be addressed in their adopting ordinances (typically by adopting NFPA 101 instead of IBC Ch 10. Either way, this section is not needed and creates conflict as is. Related Public Inputs for This Document Related Input Public Input No. 67-NFPA 30A-2015 [Section No ] Relationship Submitter Full Name: SPENCER QUONG Organization: QUONG ASSOCIATES INC Affilliation: TOYOTA Submittal Date: Mon Jul 06 13:57:59 EDT 2015

47 2 of /26/2015 7:46 AM Public Input No. 67-NFPA 30A-2015 [ Section No ] Means of Egress. In a motor fuel dispensing facility that is located inside a building or structure, the required number, location, and construction of means of egress shall meet all applicable requirements for special purpose industrial occupancies, as set forth in NFPA 101, Life Safety Code. This PI should only be considered if PI66 is rejected. Special-purpose industrial occupancies are intended for occupancies with uniquely low occupant load factors; not for occupancies that perform unique operations. Fuel dispensing facilities do not experience uniquely low occupant loads. In addition, egress may be inadequate if classified as a special purpose industrial occupancy. Refer to definition in NFPA 101 below as evidence that this classification is not applicable to fuel dispensing facilities: Special-Purpose Industrial Occupancy. An industrial occupancy in which ordinary and low hazard industrial operations are conducted in buildings designed for, and suitable only for, particular types of operations, characterized by a relatively low density of employee population, with much of the area occupied by machinery or equipment. Related Public Inputs for This Document Related Input Public Input No. 66-NFPA 30A-2015 [Section No ] Relationship PI 67 is an optional proposal only to be considered if PI 66 is rejected Submitter Full Name: SPENCER QUONG Organization: QUONG ASSOCIATES INC Affilliation: TOYOTA Submittal Date: Mon Jul 06 14:00:02 EDT 2015

48 3 of /26/2015 7:46 AM Public Input No. 70-NFPA 30A-2015 [ Section No ] Occupancy Classification. The occupancy classification of a repair garage shall be a special purpose industrial occupancy as defined in NFPA 101, Life Safety Code. in accordance with the building code adopted for the jurisdiction PI Occupancy classifications are assigned by the Building code adopted in a jurisdiction. Special purpose industrial occupancy is an incorrect classification (see below) and this is a complicated situation best handled by requirements already clearly established in the building code. A special purpose industrial occupancy has lower egress requirements (not higher) that a standard industrial occupancy so this is not an appropriate occupancy classification. Special-purpose industrial occupancies are intended for occupancies with uniquely low occupant load factors; not for occupancies that perform unique operations. Repair garages do not experience uniquely low occupant loads. In addition, egress may be inadequate if classified as a special purpose industrial occupancy. Refer to definition in NFPA 101 below as evidence that this classification is not applicable to fuel dispensing facilities: Special-Purpose Industrial Occupancy. An industrial occupancy in which ordinary and low hazard industrial operations are conducted in buildings designed for, and suitable only for, particular types of operations, characterized by a relatively low density of employee population, with much of the area occupied by machinery or equipment. Related Public Inputs for This Document Related Input Public Input No. 77-NFPA 30A-2015 [Section No ] Relationship Submitter Full Name: SPENCER QUONG Organization: QUONG ASSOCIATES INC Affilliation: TOYOTA Submittal Date: Mon Jul 06 14:16:40 EDT 2015

49 4 of /26/2015 7:46 AM Public Input No. 77-NFPA 30A-2015 [ Section No ] Occupancy Classification. The occupancy classification of a repair garage shall be a special purpose an industrial occupancy as defined in NFPA 101, Life Safety Code. If the technical committee rejects my preferred option to remove the reference to NFPA101 as proposed in PI 70, then, I propose removing the "special purpose" from industrial occupancies. Special-purpose industrial occupancies are intended for occupancies with uniquely low occupant load factors; not for occupancies that perform unique operations. Repair garages do not experience uniquely low occupant loads. In addition, egress may be inadequate if classified as a special purpose industrial occupancy. Refer to definition in NFPA 101 below as evidence that this classification is not applicable to repair garages: Special-Purpose Industrial Occupancy. An industrial occupancy in which ordinary and low hazard industrial operations are conducted in buildings designed for, and suitable only for, particular types of operations, characterized by a relatively low density of employee population, with much of the area occupied by machinery or equipment. Related Public Inputs for This Document Related Input Public Input No. 70-NFPA 30A-2015 [Section No ] Relationship Secondary proposal if PI70 is rejected Submitter Full Name: SPENCER QUONG Organization: QUONG ASSOCIATES INC Affilliation: TOYOTA Submittal Date: Mon Jul 06 15:01:09 EDT 2015

50 5 of /26/2015 7:46 AM Public Input No. 81-NFPA 30A-2015 [ Section No ] Occupancy Classification. The occupancy classification of a repair garage shall be a special purpose industrial occupancy as defined in NFPA 101, Life Safety Code in accordance with the building code adopted for the jurisdiction. Occupancy classifications are assigned by the Building code adopted in a jurisdiction. Special purpose industrial occupancy is an incorrect classification (see below) and this is a complicated situation best handled by requirements already clearly established in the building code. A special purpose industrial occupancy has lower egress requirements (not higher) that a standard industrial occupancy so this is not an appropriate occupancy classification. Special-purpose industrial occupancies are intended for occupancies with uniquely low occupant load factors; not for occupancies that perform unique operations. Repair garages do not experience uniquely low occupant loads. In addition, egress may be inadequate if classified as a special purpose industrial occupancy. Refer to definition in NFPA 101 below as evidence that this classification is not applicable to fuel dispensing facilities: Special-Purpose Industrial Occupancy. An industrial occupancy in which ordinary and low hazard industrial operations are conducted in buildings designed for, and suitable only for, particular types of operations, characterized by a relatively low density of employee population, with much of the area occupied by machinery or equipment. Related Public Inputs for This Document Related Input Public Input No. 82-NFPA 30A-2015 [Section No ] Relationship Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC Submittal Date: Mon Jul 06 16:29:34 EDT 2015

51 6 of /26/2015 7:46 AM Public Input No. 82-NFPA 30A-2015 [ Section No ] Occupancy Classification. The occupancy classification of a repair garage shall be a special purpose an industrial occupancy as defined in NFPA 101, Life Safety Code. If the technical committee rejects my preferred option to remove the reference to NFPA101 as proposed in PI 81, then, I propose removing the "special purpose" from industrial occupancies. Special-purpose industrial occupancies are intended for occupancies with uniquely low occupant load factors; not for occupancies that perform unique operations. Repair garages do not experience uniquely low occupant loads. In addition, egress may be inadequate if classified as a special purpose industrial occupancy. Refer to definition in NFPA 101 below as evidence that this classification is not applicable to repair garages: Special-Purpose Industrial Occupancy. An industrial occupancy in which ordinary and low hazard industrial operations are conducted in buildings designed for, and suitable only for, particular types of operations, characterized by a relatively low density of employee population, with much of the area occupied by machinery or equipment. Related Public Inputs for This Document Related Input Public Input No. 81-NFPA 30A-2015 [Section No ] Relationship preferred option is in PI 81. This is a secondary input Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC Submittal Date: Mon Jul 06 16:33:56 EDT 2015

52 7 of /26/2015 7:46 AM Public Input No. 22-NFPA 30A-2015 [ Section No ] General Construction Requirements. In major repair garages, where CNG-fueled vehicles, hydrogen-fueled vehicles, LNG-fueled vehicles, or LP-Gas-fueled vehicles are repaired, all applicable requirements of NFPA 52, Vehicular Gaseous Fuel Systems Code, NFPA2, Hydrogen Technologies Code, or NFPA 58, Liquefied Petroleum Gas Code, whichever is applicable, shall be met. NFPA Standard Council has moved all hydrogen requirements from NFPA52 to NFPA2, including those for Motor Fueling Dispensing and Repair Garages. The 2011 version of the NFPA2 code had specific information on Dispensing, but not for Repair Garages (reserved). The 2016 version of NFPA2 will have specific requirements for Repair Garages and will be published prior to NFPA30A. Therefore, in order to prevent conflicting requirements, repair garages should reference NFPA2 and not NFPA52. Related Public Inputs for This Document Related Input Public Input No. 63-NFPA 30A-2015 [Section No. 2.4] Relationship Submitter Full Name: SPENCER QUONG Organization: QUONG ASSOCIATES INC Affilliation: Toyota Submittal Date: Fri May 15 03:05:23 EDT 2015

53 8 of /26/2015 7:46 AM Public Input No. 38-NFPA 30A-2015 [ Section No ] General Construction Requirements. In major repair garages, where CNG-fueled vehicles, hydrogen-fueled vehicles, LNG-fueled vehicles, or LP-Gas-fueled vehicles are repaired, all applicable requirements of NFPA 52, Vehicular Gaseous Fuel Systems Code, NFPA 2, Hydrogen Technologies Code, or NFPA 58, Liquefied Petroleum Gas Code, whichever is applicable, shall be met. Requirements for repair garages servicing hydrogen-fueled vehicles are contained only in NFPA 2 and nowhere else. Previous text in NFPA 52 has been removed. The Standards Council has revised the Scope of NFPA 52 and removed fueling of hydrogen-fuel cell electric vehicles. Related Public Inputs for This Document Related Input Public Input No. 42-NFPA 30A-2015 [Section No. 2.4] Relationship Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC Submittal Date: Wed Jul 01 17:23:05 EDT 2015

54 9 of /26/2015 7:46 AM Public Input No. 49-NFPA 30A-2015 [ Section No ] Means of Egress. In a repair garage, the required number, location, and construction of means of egress shall meet all applicable requirements for special purpose industrial occupancies, as set forth in NFPA 101, Life Safety Code. Preferred option. Occupancy classifications are assigned by the Building code adopted in a jurisdiction. The building code adopted by the jurisdiction will address egress. This section is not needed. If a jurisdiction uses NFPA 101 for egress, then the conflict between the IBC and NFPA 101 will be addressed in their adopting ordinances (typically by adopting NFPA 101 instead of IBC Ch 10. Either way, this section is not needed and creates conflict as is. Related Public Inputs for This Document Related Input Public Input No. 50-NFPA 30A-2015 [Section No ] Relationship Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC Submittal Date: Wed Jul 01 19:19:49 EDT 2015

55 0 of /26/2015 7:46 AM Public Input No. 50-NFPA 30A-2015 [ Section No ] Means of Egress. In a repair garage, the required number, location, and construction of means of egress shall meet all applicable requirements for special purpose industrial occupancies, as set forth in NFPA 101, Life Safety Code. Only needed if PI49 is rejected. Special-purpose industrial occupancies are intended for occupancies with uniquely low occupant load factors; not for occupancies that perform unique operations. Repair garages are rather common and do not experience uniquely low occupant loads. In addition, egress may be inadequate if classified as a special purpose industrial occupancy. Refer to definition in NFPA 101 below as evidence that this classification is not applicable to fuel dispensing facilities: Special-Purpose Industrial Occupancy. An industrial occupancy in which ordinary and low hazard industrial operations are conducted in buildings designed for, and suitable only for, particular types of operations, characterized by a relatively low density of employee population, with much of the area occupied by machinery or equipment. Related Public Inputs for This Document Related Input Public Input No. 49-NFPA 30A-2015 [Section No ] Relationship If PI49 is accepted then this one PI50 should be rejected - or vice versa. Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC Submittal Date: Wed Jul 01 19:22:47 EDT 2015

56 1 of /26/2015 7:46 AM Public Input No. 68-NFPA 30A-2015 [ Section No ] Means of Egress. In a repair garage, the required number, location, and construction of means of egress shall meet all applicable requirements for special purpose industrial occupancies, as set forth in NFPA 101, Life Safety Code. This section is not needed because occupancy classifications and "means of egress" are assigned by the building code adopted in a jurisdiction.if a jurisdiction uses NFPA 101 for egress, then the conflict between the IBC and NFPA 101 will be addressed in their adopting ordinances (typically by adopting NFPA 101 instead of IBC Ch 10. Either way, this section is not needed and creates conflict as is. Related Public Inputs for This Document Related Input Public Input No. 69-NFPA 30A-2015 [Section No ] Relationship Submitter Full Name: SPENCER QUONG Organization: QUONG ASSOCIATES INC Affilliation: TOYOTA Submittal Date: Mon Jul 06 14:05:49 EDT 2015

57 2 of /26/2015 7:46 AM Public Input No. 69-NFPA 30A-2015 [ Section No ] Means of Egress. In a repair garage, the required number, location, and construction of means of egress shall meet all applicable requirements for special purpose industrial occupancies, as set forth in NFPA 101, Life Safety Code. This PI should only be considered if PI68 is rejected. Special-purpose industrial occupancies are intended for occupancies with uniquely low occupant load factors; not for occupancies that perform unique operations. Repair garages do not experience uniquely low occupant loads. In addition, egress may be inadequate if classified as a special purpose industrial occupancy. Refer to definition in NFPA 101 below as evidence that this classification is not applicable to repair garages: Special- Purpose Industrial Occupancy. An industrial occupancy in which ordinary and low hazard industrial operations are conducted in buildings designed for, and suitable only for, particular types of operations, characterized by a relatively low density of employee population, with much of the area occupied by machinery or equipment Related Public Inputs for This Document Related Input Public Input No. 68-NFPA 30A-2015 [Section No ] Relationship PI69 should only be considered if PI68 is rejected Submitter Full Name: SPENCER QUONG Organization: QUONG ASSOCIATES INC Affilliation: TOYOTA Submittal Date: Mon Jul 06 14:12:14 EDT 2015

58 3 of /26/2015 7:46 AM Public Input No. 56-NFPA 30A-2015 [ Section No ] Drainage. In areas of repair garages used for repair or servicing of vehicles, floor assemblies shall be constructed of noncombustible materials or, if combustible materials are used in the assembly, they shall be surfaced with approved, nonabsorbent, noncombustible material. Exception: Slip-resistant, nonabsorbent, interior floor finishes having a critical radiant flux not more than 0.45 W/cm 2 (9.87 Btu/in. 2 ), as determined by NFPA 253, Standard Method of Test for Critical Radiant Flux of Floor Covering Systems Using a Radiant Heat Energy Source, shall be permitted, except as permitted by Floors shall be liquidtight to prevent the leakage or seepage of liquids and shall be sloped to facilitate the movement of water, fuel, or other liquids to floor drains In areas of repair garages where vehicles are serviced, any floor drains shall be properly trapped and shall discharge through an oil/water separator to the sewer or to an outside vented sump Slip-resistant, nonabsorbent, interior floor finishes having a critical radiant flux not more than 0.45 W/cm2 (9.87 Btu/in. 2 ), as determined by NFPA 253, Standard Method of Test for Critical Radiant Flux of Floor Covering Systems Using a Radiant Heat Energy Source or by ASTM E648,Standard Test Method for Critical Radiant Flux of Floor-Covering Systems Using a Radiant Heat Energy Source, shall be permitted. (Also ad ASTM E c into the list of referenced ASTM standards in Chpater 2). This public input does two things: (a) adds reference to ASTM E648, which is completely equivalent to NFPA 253 and is used more often and is referenced in most NFPA codes as an acceptable alternative to NFPA 253 and (b) makes the exception into full text language, thus eliminating exceptions wherever possible, as recommended by Standards Council and the Manual of Style. Submitter Full Name: MARCELO HIRSCHLER Organization: GBH INTERNATIONAL Submittal Date: Thu Jul 02 13:00:33 EDT 2015

59 4 of /26/2015 7:46 AM Public Input No. 51-NFPA 30A-2015 [ Section No ] In pits, belowgrade work areas, and subfloor work areas, the required number, location, and construction of means of egress shall meet the requirements for special purpose industrial occupancies in Chapter 40 of NFPA 101, Life Safety Code. Preferred option. Occupancy classifications are assigned by the Building code adopted in a jurisdiction. The building code adopted by the jurisdiction will address egress. This section is not needed. If a jurisdiction uses NFPA 101 for egress, then the conflict between the IBC and NFPA 101 will be addressed in their adopting ordinances (typically by adopting NFPA 101 instead of IBC Ch 10. Either way, this section is not needed and creates conflict as is. Related Public Inputs for This Document Related Input Public Input No. 52-NFPA 30A-2015 [Section No ] Relationship Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC Submittal Date: Wed Jul 01 19:29:02 EDT 2015

60 5 of /26/2015 7:46 AM Public Input No. 52-NFPA 30A-2015 [ Section No ] In pits, belowgrade work areas, and subfloor work areas, the required number, location, and construction of means of egress shall meet the requirements for special purpose industrial occupancies in Chapter 40 of NFPA 101, Life Safety Code. Special-purpose industrial occupancies are intended for occupancies with uniquely low occupant load factors; not for occupancies that perform unique operations. Repair garages are rather common and do not experience uniquely low occupant loads. In addition, egress may be inadequate if classified as a special purpose industrial occupancy. Refer to definition in NFPA 101 below as evidence that this classification is not applicable to fuel dispensing facilities: Special-Purpose Industrial Occupancy. An industrial occupancy in which ordinary and low hazard industrial operations are conducted in buildings designed for, and suitable only for, particular types of operations, characterized by a relatively low density of employee population, with much of the area occupied by machinery or equipment. Related Public Inputs for This Document Related Input Public Input No. 51-NFPA 30A-2015 [Section No ] Relationship If PI 51 is accepted then PI 52 should be rejected and vice versa. Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC Submittal Date: Wed Jul 01 19:30:52 EDT 2015

61 6 of /26/2015 7:46 AM Public Input No. 71-NFPA 30A-2015 [ Section No ] In pits, belowgrade work areas, and subfloor work areas, the required number, location, and construction of means of egress shall meet the requirements for special purpose industrial occupancies in Chapter 40 of NFPA 101, Life Safety Code. This section is not needed because occupancy classifications and "means of egress" are assigned by the Building code adopted in a jurisdiction.if a jurisdiction uses NFPA 101 for egress, then the conflict between the IBC and NFPA 101 will be addressed in their adopting ordinances (typically by adopting NFPA 101 instead of IBC Ch 10. Either way, this section is not needed and creates conflict as is. Related Public Inputs for This Document Related Input Public Input No. 72-NFPA 30A-2015 [Section No ] Relationship Submitter Full Name: SPENCER QUONG Organization: QUONG ASSOCIATES INC Affilliation: TOYOTA Submittal Date: Mon Jul 06 14:18:03 EDT 2015

62 7 of /26/2015 7:46 AM Public Input No. 72-NFPA 30A-2015 [ Section No ] In pits, belowgrade work areas, and subfloor work areas, the required number, location, and construction of means of egress shall meet the requirements for special purpose for industrial occupancies in Chapter 40 of NFPA 101, Life Safety Code. This PI should only be considered if PI71 is rejected. Special-purpose industrial occupancies are intended for occupancies with uniquely low occupant load factors; not for occupancies that perform unique operations. Repair garages do not experience uniquely low occupant loads. In addition, egress may be inadequate if classified as a special purpose industrial occupancy. Refer to definition in NFPA 101 below as evidence that this classification is not applicable to repair garages: Special- Purpose Industrial Occupancy. An industrial occupancy in which ordinary and low hazard industrial operations are conducted in buildings designed for, and suitable only for, particular types of operations, characterized by a relatively low density of employee population, with much of the area occupied by machinery or equipment. Related Public Inputs for This Document Related Input Public Input No. 71-NFPA 30A-2015 [Section No ] Relationship PI 72 should only be considered if PI71 is rejected Submitter Full Name: SPENCER QUONG Organization: QUONG ASSOCIATES INC Affilliation: TOYOTA Submittal Date: Mon Jul 06 14:20:22 EDT 2015

63 Public Input No. 16-NFPA 30A-2015 [ Section No ] Fixed Fire Protection. Automatic sprinkler protection installed in accordance with the requirements of NFPA 13, Standard for the Installation of Sprinkler Systems, shall be provided in major repair garages, as herein defined, when any of the following conditions exist: (1) The builidng housing the major repair garage is two or more stories in height levels, including basements, and any one of the floors exceeds 930 (2) The aggregate area of all levels combined exceeds 1115 m 2 ( 10 (3) 12,000 ft 2 ). (4) The major repair garage is one story (5) level and exceeds (6) exceed 1115 m 2 (12,000 ft 2 ). (7) The major repair garage is servicing vehicles parked in the basement of the building. Additional Proposed Changes File Name Description Approved 30A-PC1.pdf 30A PC #1. NOTE: The following Public Input appeared as "Reject but Hold" in Public Comment No. 1 of the A2014 Second Draft Report for NFPA 30A and per the Regs. at Subsection 1 should clarify that the requirement applies to the entire building; the entire building does not have to be used as a repair garage to utilize this requirement. The current language of section 1 would allow a large area without sprinkler protection. (Example: 3 story building, 9,000 ft² per floor would not require sprinkler protection) Submitter Full Name: TC ON AUV-AAA NFPA NFPA Technical Committee on Automotive and Marine Organization: Service Stations Submittal Date: Thu Mar 26 11:16:00 EDT of /26/2015 7:46 AM

64 of 2 3/26/2015 9:51 AM Public Comment No. 1-NFPA 30A-2013 [ Section No ] Fixed Fire Protection. Automatic sprinkler protection installed in accordance with the requirements of NFPA 13, Standard for the Installation of Sprinkler Systems, shall be provided in major repair garages, as herein defined, when any of the following conditions exist: (1) The building housing the major repair garage is two or more stories in height (1) levels, including basements, and any one of the floors exceeds 930 m 2 (10,000 ft 2 ) (1) the aggregate area of all levels combined exceeds ft2. (2) The major repair garage is one story (1) level and exceeds 1115 m 2 (12,000 ft 2 ). (2) The major repair garage is servicing vehicles parked in the basement of the building. Statement of Problem and Substantiation for Public Comment Subsection 1 should clarify that the requirement applies to the entire building; the entire building does not have to be used as a repair garage to utilize this requirement. The current language of section 1 would allow a large area without sprinkler protection. (Example: 3 story building, 9,000 ft² per floor would not require sprinkler protection) Submitter Full Name: Doug Hohbein Organization: Northcentral Fire Code Develop Submittal Date: Tue Apr 02 21:54:45 EDT 2013 Committee Statement Committee Action: Resolution: Rejected but held Public Comment No. 1 proposes a change to a paragraph in NFPA 30A that was not amended at the First Draft stage of this revision cycle. To accept this change would effect an amendment to the Code without its having undergone public review and comment. Therefore, in accordance with Paragraphs and of the Regulations Governing the Development of NFPA Standards, the Technical Committee has voted to reject Public Comment No. 1 and hold it for processing as a Public Input at the next document revision cycle. Copyright Assignment I, Doug Hohbein, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Doug Hohbein, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature

65 9 of /26/2015 7:46 AM Public Input No. 73-NFPA 30A-2015 [ Section No ] Gas Detection System. Repair garages used for repair of vehicle engine fuel systems fueled by non-odorized gases, with the exception of hydrogen, such as hydrogen and non-odorized LNG/CNG, shall be provided with an approved flammable gas detection system For repair garages used for the repair of hydrogen-fueled vehicles, the gas detection system shall be in accordance with NFPA 2, Hydrogen Technologies Code System Design. The flammable gas detection system shall be calibrated to the types of fuels or gases used by vehicles to be repaired. The gas detection system shall be designed to activate when the level of flammable gas exceeds 25 percent of the lower flammable limit (LFL). Gas detection shall also be provided in lubrication or chassis repair pits of repair garages used for repairing non-odorized LNG/CNG-fueled vehicles Operation. Activation of the gas detection system shall result in all of the following: (1) Initiation of distinct audible and visual alarm signals in the repair garage (2) Deactivation of all heating systems located in the repair garage (3) Activation of the mechanical ventilation system, when the system is interlocked with gas detection Failure of the Gas Detection System. Failure of the gas detection system shall result in the deactivation of the heating system and activation of the mechanical ventilation system and, where the ventilation system is interlocked with gas detection, shall cause a trouble signal to sound in an approved location The circuits of the detection system required by shall be monitored for integrity in accordance with NFPA 72, National Fire Alarm and Signaling Code. NFPA Standard Council has moved all hydrogen requirements from NFPA52 to NFPA2, including those for Motor Fueling Dispensing and Repair Garages. The 2011 version of the NFPA2 code had specific information on Dispensing, but not for Repair Garages (reserved). The 2016 version of NFPA2 will have specific requirements for Repair Garages and Gas Detection Systems. NFPA2 will be published prior to NFPA30A. In order to prevent conflicting requirements, the gas detection system requirements for hydrogen should reference NFPA2 Submitter Full Name: SPENCER QUONG Organization: QUONG ASSOCIATES INC Affilliation: TOYOTA Submittal Date: Mon Jul 06 14:25:31 EDT 2015

66 0 of /26/2015 7:46 AM Public Input No. 43-NFPA 30A-2015 [ Section No [Excluding any Sub-Sections] ] Repair garages used for repair of vehicle engine fuel systems fueled by non-odorized gases with the exception of hydrogen, such as hydrogen and non-odorized LNG/CNG, shall be provided with an approved flammable gas detection system. Special requirements for gas detection systems, including when these systems are required and how to install them, have already been developed in NFPA 2 for repair garages servicing hydrogen-fueled vehicles. A new pointer to NFPA 2 is proposed in new section Related Public Inputs for This Document Related Input Public Input No. 44-NFPA 30A-2015 [New Section after ] Relationship Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC Submittal Date: Wed Jul 01 18:20:32 EDT 2015

67 1 of /26/2015 7:46 AM Public Input No. 44-NFPA 30A-2015 [ New Section after ] New Section Renumber subsequent sections For repair garages used for the repair of hydrogen-fueled vehicles, the gas detection system shall be in accordance with NFPA 2, Hydrogen Technologies Code. Special requirements for gas detection systems, including when these systems are required and how to install them, have already been developed in NFPA 2. This new section points the user to those requirements. Related Public Inputs for This Document Related Input Public Input No. 43-NFPA 30A-2015 [Section No [Excluding any Sub-Sections]] Relationship adds pointer and makes NFPA 30A complete with the exclusion of hydrogen proposed in PI43. Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC Submittal Date: Wed Jul 01 18:23:52 EDT 2015

68 2 of /26/2015 7:46 AM Public Input No. 25-NFPA 30A-2015 [ Section No ] * In major repair garages where CNG vehicles are repaired or stored, the area within 455 mm (18 in.) of the ceiling shall be designated a Class I, Division 2 hazardous (classified) location. Exception: In major repair garages, where ventilation equal to not less than four air changes per hour is provided, this requirement shall not apply. The existing requirement as stated in was based on the assumption as noted in Annex A8.2.1 that the creditable release on natural gas from the vehicle would be 150% of the largest on board storage cylinder. The volume released assumption was based on the noted premature failures of thermally activated PRDs (TPRD) experienced in the 1990's. Those TPRDS have gone through at least three generations on new designs and there has not been a documented failure (premature release) from TPRDs since This stems for the phase out of the older designs for the 1990's and the excellent performance record of the new TPRD designs. With thirteen years of no recorded failures (premature releases) of TPRDs mounted on hundreds of thousands of cylinders indicates that the release hazard covered by no longer exists. A recent research paper (SAND ) from SANDIA National Laboratory and funded by the Clean Vehicle Education Foundation has determined that the expected creditable release for both CNG and LNG vehicles is of a much lower volume and dose not pose a hazard for a maintenance facility. The report includes gas dispersion modeling of the creditable releases showing the extent of the ignitable mixture. This modeling of the creditable mixtures indicate that the ignitable concentration is only within a narrow area no more than six feet from the point of release, also the limited volume of release does not allow for an increasing concentration in the ceiling area due to the dispersion of the gas.the full release as as noted in the 1990 assumption was also modeled for background information. The report also indicates that ventilation rates has little or no impact on the volume of ignitable mixture and the dispersion of the released gas.the report will be sent by separate cover as part of this proposal and an electronic copy is available to the TC as needed. The Annex A8.2.1 will need to be deleted and the TC should consider new annex material explaining the realities of creditable releases expected for contemporary facility designs, this information may be considered as Annex material for section concerning locations of ignitable mixtures. NOTE: SANDIA has proposed a Phase 2 project to refine the assumptions for facility designs and CFD modeling starting in 2016 and would consider input from the NFPA 52 TC together define and understand the potential hazards. Submitter Full Name: DOUGLAS HORNE Organization: DBHORNE LLC Submittal Date: Fri May 22 09:41:49 EDT 2015

69 3 of /26/2015 7:46 AM Public Input No. 27-NFPA 30A-2015 [ Section No ]

70 5 of /26/2015 7:46 AM Table shall be used to delineate and classify areas for the purposes of installing electrical wiring and electrical utilization equipment where Class I liquids are stored, handled, or dispensed. [See also Figure 8.3.2(a) and Figure 8.3.2(b).] Table Class I Locations Motor Fuel Dispensing Facilities Class I Location Division (Group D) Zone (Group IIA) Extent of Classified Location a Dispensing device (except overhead type) b,c Under dispenser containment 1 1 Entire space within and under dispenser pit or containment Dispenser 2 2 Within 450 mm (18 in.) of dispenser enclosure or that portion of dispenser enclosure containing liquid handling components, extending horizontally in all directions and down to grade level Outdoor 2 2 Up to 450 mm (18 in.) above grade level, extending 6 m (20 ft) horizontally in all directions from dispenser enclosure Indoor With mechanical ventilation 2 2 Up to 450 mm (18 in.) above floor level, extending 6 m (20 ft) horizontally in all directions from dispenser enclosure With gravity ventilation 2 2 Up to 450 mm (18 in.) above floor level, extending 7.5 m (25 ft) horizontally in all directions from dispenser enclosure Dispensing device (overhead type d ) Repair garage, major e (where Class I liquids or gaseous fuels are transferred or dispensed f ) (see and 8.3.1) 1 1 Space within dispenser enclosure and all electrical equipment integral with dispensing hose or nozzle 2 2 Within 450 mm (18 in.) of dispenser enclosure, extending horizontally in all directions and down to grade level 2 2 Up to 450 mm (18 in.) above grade level, extending 6 m (20 ft) horizontally in all directions from a point vertically below edge of dispenser enclosure 1 1 Entire space within any pit, belowgrade work area, or subfloor work area that is not ventilated 2 2 Entire space within any pit, belowgrade work area, or subfloor work area that is provided with ventilation of at least 0.3 m 3 /min/m 2 (1 ft 3 /min/ft 2 ) of floor area, with suction taken from a point within 300 mm (12 in.) of floor level (see ) 2 2 Up to 450 mm (18 in.) above floor level of the room, except as noted below, for entire floor area Unclassified Unclassified Up to 450 mm (18 in.) above floor level of the room where room is provided with ventilation of at least 0.3 m 3 /min/m 2 (1 ft 3 /min/ft 2 ) of floor area, with suction taken from a point within 300 mm (12 in.) of floor level

71 6 of /26/2015 7:46 AM Class I Location Specific areas adjacent to classified locations Repair garage, minor e (where Class I liquids or gaseous fuels are not transferred or dispensed f ) (see and 8.3.1) Specific areas adjacent to classified locations Repair garage, major e (where lighter-than-air gaseous fueled g vehicles are repaired or stored) (see ) Specific areas adjacent to classified locations Remote pump Division (Group D) Zone (Group IIA) Extent of Classified Location a 2 2 Within 0.9 m (3 ft) of any fill or dispensing point, extending in all directions Unclassified Unclassified Areas adjacent to classified locations where flammable vapors are not likely to be released, such as stock rooms, switchboard rooms, and other similar locations, where mechanically ventilated at a rate of four or more air changes per hour or designed with positive air pressure or where effectively cut off by walls or partitions 2 2 Entire space within any pit, belowgrade work area, or subfloor work area that is not ventilated 2 2 Up to 450 mm (18 in.) above floor level, extending 0.9 m (3 ft) horizontally in all directions from opening to any pit, belowgrade work area, or subfloor work area that is not ventilated Unclassified Unclassified Entire space within any pit, belowgrade work area, or subfloor work area that is provided with ventilation of at least 0.3 m 3 /min/m 2 (1 ft 3 /min/ft 2 ) of floor area, with suction taken from a point within 300 mm (12 in.) of floor level (see ) Unclassified Unclassified Areas adjacent to classified locations where flammable vapors are not likely to be released, such as stock rooms, switchboard rooms, and other similar locations, where mechanically ventilated at a rate of four or more air changes per hour or designed with positive air pressure, or where effectively cut off by walls or partitions 2 2 Within 450 mm (18 in.) of ceiling, except as noted below Unclassified Unclassified Within 450 mm (18 in.) of ceiling where ventilation of at least 0.3 m 3 /min/m 2 (1 ft 3 /min/ft 2 ) of floor area, with suction taken from a point within 450 mm (18 in.) of the highest point in the ceiling Unclassified Unclassified Areas adjacent to classified locations where flammable vapors are not likely to be released, such as stock rooms, switchboard rooms, and other similar locations, where mechanically ventilated at a rate of four or more air changes per hour or designed with positive air pressure, or where effectively cut off by walls or partitions

72 7 of /26/2015 7:46 AM Location Division (Group D) Class I Zone (Group IIA) Extent of Classified Location a Outdoor 1 1 Entire space within any pit or box below grade level, any part of which is within 3 m (10 ft) horizontally from any edge of pump 2 2 Within 900 mm (3 ft) of any edge of pump, extending horizontally in all directions 2 2 Up to 450 m (18 in.) above grade level, extending 3 m (10 ft) horizontally in all directions from any edge of pump Indoor 1 1 Entire space within any pit Sales, storage, rest rooms (including structures [such as the attendant s kiosk] on or adjacent to dispensers) Tank, aboveground (tanks not directly related to fueling as detailed in table 8.3.2b and section 4.3.2) 2 2 Within 1.5 m (5 ft) of any edge of pump, extending in all directions 2 2 Up to 900 mm (3 ft) above floor level, extending 7.5 m (25 ft) horizontally in all directions from any edge of pump Unclassified Unclassified Except as noted below 1 1 Entire volume, if there is any opening to room within the extent of a Division 1 or Zone 1 location 2 2 Entire volume, if there is any opening to room within the extent of a Division 2 or Zone 2 location Inside tank 1 0 Entire inside volume Shell, ends, roof, dike area 1 1 Entire space within dike, where dike height exceeds distance from tank shell to inside of dike wall for more than 50 percent of tank circumference 2 2 Entire space within dike, where dike height does not exceed distance from tank shell to inside of dike wall for more than 50 percent of tank circumference 2 2 Within 3 m (10 ft) of shell, ends, or roof of tank Vent 1 1 Within 1.5 m (5 ft) of open end of vent, extending in all directions Tank, underground 2 2 Between 1.5 m and 3 m (5 ft and 10 ft) from open end of vent, extending in all directions Inside tank 1 0 Entire inside volume Fill opening 1 1 Entire space within any pit or box below grade level, any part of which is within a Division 1 or Division 2 classified location or within a Zone 1 or Zone 2 classified location 2 2 Up to 450 mm (18 in.) above grade level, extending 1.5 m (5 ft) horizontally in all directions from any tight-fill connection and extending 3 m (10 ft)

73 8 of /26/2015 7:46 AM Location Division (Group D) Class I Zone (Group IIA) Extent of Classified Location a horizontally in all directions from any loose-fill connection Vent 1 1 Within 1.5 m (5 ft) of open end of vent, extending in all directions Vapor processing system 2 2 Between 1.5 m and 3 m (5 ft and 10 ft) from open end of vent, extending in all directions Pits 1 1 Entire space within any pit or box below grade level, any part of which: (1) is within a Division 1 or Division 2 classified location; (2) is within a Zone 1 or Zone 2 classified location; (3) houses any equipment used to transfer or process vapors Equipment in protective enclosures Equipment not within protective enclosure 2 2 Entire space within enclosure 2 2 Within 450 mm (18 in.) of equipment containing flammable vapors or liquid, extending horizontally in all directions and down to grade level 2 2 Up to 450 m (18 in.) above grade level within 3 m (10 ft) horizontally of the vapor processing equipment Equipment enclosure 1 1 Entire space within enclosure, if flammable vapor or liquid is present under normal operating conditions 2 2 Entire space within enclosure, if flammable vapor or liquid is not present under normal operating conditions Vacuum assist blower 2 2 Within 450 mm (18 in.) of blower, extending horizontally in all directions and down to grade level 2 2 Up to 450 mm (18 in.) above grade level, extending 3 m (10 ft) horizontally in all directions Vault 1 1 Entire interior space, if Class I liquids are stored within a For marine application, grade level means the surface of a pier, extending down to water level. b Refer to Figures 8.3.2(a) and 8.3.2(b) for illustrations of classified locations around dispensing devices. c Area classification inside the dispenser enclosure is covered in UL 87, Standard for Power-Operated Dispensing Devices for Petroleum Products. d Ceiling-mounted hose reel. e The terms repair garage, major and repair garage, minor are intended to correlate with Article of NFPA 70, National Electrical Code. For the purposes of application of this table, these terms do not include associated floor space used for offices, parking, or showrooms. f Includes draining of Class I liquids from vehicles. g Includes fuels such as hydrogen and natural gas, but not LPG. Figure 8.3.2(a) Classified Areas Adjacent to Dispensers.

74 9 of /26/2015 7:46 AM Figure 8.3.2(b) Classified Areas Adjacent to Dispenser Mounted on Aboveground Storage Tank. Exception: The extent of the classified area around a vacuum-assist blower shall be permitted to be reduced if the blower is specifically listed for such reduced distances. Table seems to conflict with the use of an AST in conjunction with a dispensing device when it comes to the definition of hazardous zones. Table 8.3.3(b) shows zones that are not near as large as those shown for ASTs in with no clear definition to the differences. The only clue is that in it refers to dikes around the tanks which would seem to indicate large storage tanks. This large zone around the tank can impact the hazardous classification required for the dispenser. Submitter Full Name: RANDY MOSES Organization: WAYNE FUELING SYSTEMS LLC

75 0 of /26/2015 7:46 AM Submittal Date: Tue Jun 30 11:17:20 EDT 2015

76 1 of /26/2015 7:46 AM Public Input No. 53-NFPA 30A-2015 [ Section No ]

77 3 of /26/2015 7:46 AM Table shall be used to delineate and classify areas for the purposes of installing electrical wiring and electrical utilization equipment where Class I liquids are stored, handled, or dispensed. [See also Figure 8.3.2(a) and Figure 8.3.2(b).] Table Class I Locations Motor Fuel Dispensing Facilities Location Dispensing device (except overhead type) b,c Under dispenser containment Division (Group D) Class I Zone (Group IIA) Extent of Classified Location a 1 1 Entire space within and under dispenser pit or containment Dispenser 2 2 Within 450 mm (18 in.) of dispenser enclosure or that portion of dispenser enclosure containing liquid handling components, extending horizontally in all directions and down to grade level Outdoor 2 2 Up to 450 mm (18 in.) above grade level, extending 6 m (20 ft) horizontally in all directions from dispenser enclosure Indoor With mechanical ventilation 2 2 Up to 450 mm (18 in.) above floor level, extending 6 m (20 ft) horizontally in all directions from dispenser enclosure With gravity ventilation 2 2 Up to 450 mm (18 in.) above floor level, extending 7.5 m (25 ft) horizontally in all directions from dispenser enclosure Dispensing device (overhead type d ) Repair garage, major e (where Class I liquids or gaseous fuels are transferred or dispensed f ) (see and 8.3.1) 1 1 Space within dispenser enclosure and all electrical equipment integral with dispensing hose or nozzle 2 2 Within 450 mm (18 in.) of dispenser enclosure, extending horizontally in all directions and down to grade level 2 2 Up to 450 mm (18 in.) above grade level, extending 6 m (20 ft) horizontally in all directions from a point vertically below edge of dispenser enclosure 1 1 Entire space within any pit, belowgrade work area, or subfloor work area that is not ventilated 2 2 Entire space within any pit, belowgrade work area, or subfloor work area that is provided with ventilation of at least 0.3 m 3 /min/m 2 (1 ft 3 /min/ft 2 ) of floor area, with suction taken from a point within 300 mm (12 in.) of floor level (see )

78 4 of /26/2015 7:46 AM Class I Location Specific areas adjacent to classified locations Repair garage, minor e (where Class I liquids or gaseous fuels are not transferred or dispensed f ) (see and 8.3.1) Specific areas adjacent to classified locations Repair garage, major e (where lighter-than-air Division Zone (Group D) (Group IIA) Extent of Classified Location a 2 2 Up to 450 mm (18 in.) above floor level of the room, except as noted below, for entire floor area Unclassified Unclassified Up to 450 mm (18 in.) above floor level of the room where room is provided with ventilation of at least 0.3 m 3 /min/m 2 (1 ft 3 /min/ft 2 ) of floor area, with suction taken from a point within 300 mm (12 in.) of floor level 2 2 Within 0.9 m (3 ft) of any fill or dispensing point, extending in all directions Unclassified Unclassified Areas adjacent to classified locations where flammable vapors are not likely to be released, such as stock rooms, switchboard rooms, and other similar locations, where mechanically ventilated at a rate of four or more air changes per hour or designed with positive air pressure or where effectively cut off by walls or partitions 2 2 Entire space within any pit, belowgrade work area, or subfloor work area that is not ventilated 2 2 Up to 450 mm (18 in.) above floor level, extending 0.9 m (3 ft) horizontally in all directions from opening to any pit, belowgrade work area, or subfloor work area that is not ventilated Unclassified Unclassified Entire space within any pit, belowgrade work area, or subfloor work area that is provided with ventilation of at least 0.3 m 3 /min/m 2 (1 ft 3 /min/ft 2 ) of floor area, with suction taken from a point within 300 mm (12 in.) of floor level (see ) Unclassified Unclassified Areas adjacent to classified locations where flammable vapors are not likely to be released, such as stock rooms, switchboard rooms, and other similar locations, where mechanically ventilated at a rate of four or more air changes per hour or designed with positive air pressure, or where effectively cut off by walls or partitions 2 2 Within 450 mm (18 in.) of ceiling, except as noted below

79 5 of /26/2015 7:46 AM Location gaseous fueled g vehicles are repaired or stored) (see ) Unclassified Division (Group D) Class I Zone (Group IIA) Unclassified Within 450 mm (18 in.) of ceiling where ventilation of at least 0.3 m 3 /min/m 2 (1 ft 3 /min/ft 2 ) of floor area, with suction taken from a point within 450 mm (18 in.) of the highest point in the ceiling Extent of Classified Location a Specific areas adjacent to classified locations Remote pump Unclassified Unclassified Areas adjacent to classified locations where flammable vapors are not likely to be released, such as stock rooms, switchboard rooms, and other similar locations, where mechanically ventilated at a rate of four or more air changes per hour or designed with positive air pressure, or where effectively cut off by walls or partitions Outdoor 1 1 Entire space within any pit or box below grade level, any part of which is within 3 m (10 ft) horizontally from any edge of pump 2 2 Within 900 mm (3 ft) of any edge of pump, extending horizontally in all directions 2 2 Up to 450 m (18 in.) above grade level, extending 3 m (10 ft) horizontally in all directions from any edge of pump Indoor 1 1 Entire space within any pit 2 2 Within 1.5 m (5 ft) of any edge of pump, extending in all directions 2 2 Up to 900 mm (3 ft) above floor level, extending 7.5 m (25 ft) horizontally in all directions from any edge of pump Sales, storage, rest rooms (including structures [such as the attendant s attendant s kiosk] on or adjacent to dispensers) Unclassified Unclassified Except as noted below 1 1 Entire volume, if there is any opening to room within the extent of a Division 1 or Zone 1 location 2 2 Entire volume, if there is any opening to room within the extent of a Division 2 or

80 6 of /26/2015 7:46 AM Class I Location Division (Group D) Zone (Group IIA) Extent of Classified Location a Zone 2 location Tank, aboveground Inside tank 1 0 Entire inside volume Shell, ends, roof, dike area 1 1 Entire space within dike, where dike height exceeds distance from tank shell to inside of dike wall for more than 50 percent of tank circumference 2 2 Entire space within dike, where dike height does not exceed distance from tank shell to inside of dike wall for more than 50 percent of tank circumference 2 2 Within 3 m (10 ft) of shell, ends, or roof of tank Vent 1 1 Within 1.5 m (5 ft) of open end of vent, extending in all directions 2 2 Between 1.5 m and 3 m (5 ft and 10 ft) from open end of vent, extending in all directions Tank, underground Inside tank 1 0 Entire inside volume Fill opening 1 1 Entire space within any pit or box below grade level, any part of which is within a Division 1 or Division 2 classified location or within a Zone 1 or Zone 2 classified location 2 2 Up to 450 mm (18 in.) above grade level, extending 1.5 m (5 ft) horizontally in all directions from any tight-fill connection and extending 3 m (10 ft) horizontally in all directions from any loose-fill connection Vent 1 1 Within 1.5 m (5 ft) of open end of vent, extending in all directions 2 2 Between 1.5 m and 3 m (5 ft and 10 ft) from open end of vent, extending in all directions Vapor processing system Pits 1 1 Entire space within any pit or box below grade level, any part of which: (1) is within a Division 1 or Division 2 classified location; (2) is within a Zone 1 or Zone 2 classified location; (3) houses any equipment used to transfer or process vapors Equipment in protective enclosures 2 2 Entire space within enclosure Equipment not within protective enclosure 2 2 Within 450 mm (18 in.) of equipment containing flammable vapors or liquid, extending horizontally in all directions

81 7 of /26/2015 7:46 AM Class I Location Division Zone (Group D) (Group IIA) Extent of Classified Location a and down to grade level 2 2 Up to 450 m (18 in.) above grade level within 3 m (10 ft) horizontally of the vapor processing equipment Equipment enclosure 1 1 Entire space within enclosure, if flammable vapor or liquid is present under normal operating conditions 2 2 Entire space within enclosure, if flammable vapor or liquid is not present under normal operating conditions Vacuum assist blower 2 2 Within 450 mm (18 in.) of blower, extending horizontally in all directions and down to grade level 2 2 Up to 450 mm (18 in.) above grade level, extending 3 m (10 ft) horizontally in all directions Vault 1 1 Entire interior space, if Class I liquids are stored within a For marine application, grade level means the surface of a pier, extending down to water level. b Refer to Figures 8.3.2(a) and 8.3.2(b) for illustrations of classified locations around dispensing devices. c Area classification inside the dispenser enclosure is covered in UL 87, Standard for Power-Operated Dispensing Devices for Petroleum Products. d Ceiling-mounted hose reel. e The terms repair garage, major and repair garage, minor are intended to correlate with Article of NFPA 70, National Electrical Code. For the purposes of application of this table, these terms do not include associated floor space used for offices, parking, or showrooms. f Includes draining of Class I liquids from vehicles. g Includes fuels such as hydrogen and natural gas, but not LPG. Figure 8.3.2(a) Classified Areas Adjacent to Dispensers.

82 8 of /26/2015 7:46 AM Figure 8.3.2(b) Classified Areas Adjacent to Dispenser Mounted on Aboveground Storage Tank. Exception: The extent of the classified area around a vacuum-assist blower shall be permitted to be reduced if the blower is specifically listed for such reduced distances. The intent here is to delete reference to gaseous fuels in Table Hope Terra shows that correctly. Section refers only to class I liquids not gaseous fuels so the table exceeds its charging statement (8.3.2) by including gaseaous fuels. Also the requirements for hydrogen are included in NFPA 2. Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC

83 9 of /26/2015 7:46 AM Submittal Date: Wed Jul 01 19:35:43 EDT 2015

84 0 of /26/2015 7:46 AM Public Input No. 74-NFPA 30A-2015 [ Section No ]

85 2 of /26/2015 7:46 AM Table shall be used to delineate and classify areas for the purposes of installing electrical wiring and electrical utilization equipment where Class I liquids are stored, handled, or dispensed. [See also Figure 8.3.2(a) and Figure 8.3.2(b).] Table Class I Locations Motor Fuel Dispensing Facilities Location Dispensing device (except overhead type) b,c Under dispenser containment Division (Group D) Class I Zone (Group IIA) Extent of Classified Location a 1 1 Entire space within and under dispenser pit or containment Dispenser 2 2 Within 450 mm (18 in.) of dispenser enclosure or that portion of dispenser enclosure containing liquid handling components, extending horizontally in all directions and down to grade level Outdoor 2 2 Up to 450 mm (18 in.) above grade level, extending 6 m (20 ft) horizontally in all directions from dispenser enclosure Indoor With mechanical ventilation 2 2 Up to 450 mm (18 in.) above floor level, extending 6 m (20 ft) horizontally in all directions from dispenser enclosure With gravity ventilation 2 2 Up to 450 mm (18 in.) above floor level, extending 7.5 m (25 ft) horizontally in all directions from dispenser enclosure Dispensing device (overhead type d ) Repair garage, major e (where Class I liquids or gaseous fuels are transferred or dispensed f ) (see and 8.3.1) 1 1 Space within dispenser enclosure and all electrical equipment integral with dispensing hose or nozzle 2 2 Within 450 mm (18 in.) of dispenser enclosure, extending horizontally in all directions and down to grade level 2 2 Up to 450 mm (18 in.) above grade level, extending 6 m (20 ft) horizontally in all directions from a point vertically below edge of dispenser enclosure 1 1 Entire space within any pit, belowgrade work area, or subfloor work area that is not ventilated 2 2 Entire space within any pit, belowgrade work area, or subfloor work area that is provided with ventilation of at least 0.3 m 3 /min/m 2 (1 ft 3 /min/ft 2 ) of floor area, with suction taken from a point within 300 mm (12 in.) of floor level (see ) 2 2 Up to 450 mm (18 in.) above floor level of the room, except as noted below, for entire floor area Unclassified Unclassified Up to 450 mm (18 in.) above floor level of the room where room is provided with ventilation of at least 0.3 m 3 /min/m 2 (1 ft 3 /min/ft 2 ) of floor area, with suction taken from a point within 300 mm (12 in.) of floor level

86 3 of /26/2015 7:46 AM Class I Location Specific areas adjacent to classified locations Repair garage, minor e (where Class I liquids or gaseous fuels are not transferred or dispensed f ) (see and 8.3.1) Specific areas adjacent to classified locations Repair garage, major e (where lighter-than-air gaseous fueled g vehicles are repaired or stored) (see ) Specific areas adjacent to classified locations Remote pump Division (Group D) Zone (Group IIA) Extent of Classified Location a 2 2 Within 0.9 m (3 ft) of any fill or dispensing point, extending in all directions Unclassified Unclassified Areas adjacent to classified locations where flammable vapors are not likely to be released, such as stock rooms, switchboard rooms, and other similar locations, where mechanically ventilated at a rate of four or more air changes per hour or designed with positive air pressure or where effectively cut off by walls or partitions 2 2 Entire space within any pit, belowgrade work area, or subfloor work area that is not ventilated 2 2 Up to 450 mm (18 in.) above floor level, extending 0.9 m (3 ft) horizontally in all directions from opening to any pit, belowgrade work area, or subfloor work area that is not ventilated Unclassified Unclassified Entire space within any pit, belowgrade work area, or subfloor work area that is provided with ventilation of at least 0.3 m 3 /min/m 2 (1 ft 3 /min/ft 2 ) of floor area, with suction taken from a point within 300 mm (12 in.) of floor level (see ) Unclassified Unclassified Areas adjacent to classified locations where flammable vapors are not likely to be released, such as stock rooms, switchboard rooms, and other similar locations, where mechanically ventilated at a rate of four or more air changes per hour or designed with positive air pressure, or where effectively cut off by walls or partitions 2 2 Within 450 mm (18 in.) of ceiling, except as noted below Unclassified Unclassified Within 450 mm (18 in.) of ceiling where ventilation of at least 0.3 m 3 /min/m 2 (1 ft 3 /min/ft 2 ) of floor area, with suction taken from a point within 450 mm (18 in.) of the highest point in the ceiling Unclassified Unclassified Areas adjacent to classified locations where flammable vapors are not likely to be released, such as stock rooms, switchboard rooms, and other similar locations, where mechanically ventilated at a rate of four or more air changes per hour or designed with positive air pressure, or where effectively cut off by walls or partitions Outdoor 1 1 Entire space within any pit or box below grade level, any part of which is within 3 m (10 ft) horizontally from any edge of pump

87 4 of /26/2015 7:46 AM Location Division (Group D) Class I Zone (Group IIA) Extent of Classified Location a 2 2 Within 900 mm (3 ft) of any edge of pump, extending horizontally in all directions 2 2 Up to 450 m (18 in.) above grade level, extending 3 m (10 ft) horizontally in all directions from any edge of pump Indoor 1 1 Entire space within any pit 2 2 Within 1.5 m (5 ft) of any edge of pump, extending in all directions 2 2 Up to 900 mm (3 ft) above floor level, extending 7.5 m (25 ft) horizontally in all directions from any edge of pump Sales, storage, rest rooms Unclassified Unclassified Except as noted below (including structures [such as the attendant s kiosk] on or adjacent to dispensers) Tank, aboveground 1 1 Entire volume, if there is any opening to room within the extent of a Division 1 or Zone 1 location 2 2 Entire volume, if there is any opening to room within the extent of a Division 2 or Zone 2 location Inside tank 1 0 Entire inside volume Shell, ends, roof, dike area 1 1 Entire space within dike, where dike height exceeds distance from tank shell to inside of dike wall for more than 50 percent of tank circumference 2 2 Entire space within dike, where dike height does not exceed distance from tank shell to inside of dike wall for more than 50 percent of tank circumference 2 2 Within 3 m (10 ft) of shell, ends, or roof of tank Vent 1 1 Within 1.5 m (5 ft) of open end of vent, extending in all directions 2 2 Between 1.5 m and 3 m (5 ft and 10 ft) from open end of vent, extending in all directions Tank, underground Inside tank 1 0 Entire inside volume Fill opening 1 1 Entire space within any pit or box below grade level, any part of which is within a Division 1 or Division 2 classified location or within a Zone 1 or Zone 2 classified location 2 2 Up to 450 mm (18 in.) above grade level, extending 1.5 m (5 ft) horizontally in all directions from any tight-fill connection and extending 3 m (10 ft) horizontally in all directions from any loose-fill connection Vent 1 1 Within 1.5 m (5 ft) of open end of vent, extending in all directions 2 2 Between 1.5 m and 3 m (5 ft and 10 ft) from open end of vent, extending in all directions

88 5 of /26/2015 7:46 AM Location Division (Group D) Class I Zone (Group IIA) Extent of Classified Location a Vapor processing system Pits 1 1 Entire space within any pit or box below grade level, any part of which: (1) is within a Division 1 or Division 2 classified location; (2) is within a Zone 1 or Zone 2 classified location; (3) houses any equipment used to transfer or process vapors Equipment in protective enclosures 2 2 Entire space within enclosure Equipment not within protective enclosure 2 2 Within 450 mm (18 in.) of equipment containing flammable vapors or liquid, extending horizontally in all directions and down to grade level 2 2 Up to 450 m (18 in.) above grade level within 3 m (10 ft) horizontally of the vapor processing equipment Equipment enclosure 1 1 Entire space within enclosure, if flammable vapor or liquid is present under normal operating conditions 2 2 Entire space within enclosure, if flammable vapor or liquid is not present under normal operating conditions Vacuum assist blower 2 2 Within 450 mm (18 in.) of blower, extending horizontally in all directions and down to grade level 2 2 Up to 450 mm (18 in.) above grade level, extending 3 m (10 ft) horizontally in all directions Vault 1 1 Entire interior space, if Class I liquids are stored within a For marine application, grade level means the surface of a pier, extending down to water level. b Refer to Figures 8.3.2(a) and 8.3.2(b) for illustrations of classified locations around dispensing devices. c Area classification inside the dispenser enclosure is covered in UL 87, Standard for Power-Operated Dispensing Devices for Petroleum Products. d Ceiling-mounted hose reel. e The terms repair garage, major and repair garage, minor are intended to correlate with Article of NFPA 70, National Electrical Code. For the purposes of application of this table, these terms do not include associated floor space used for offices, parking, or showrooms. f Includes draining of Class I liquids from vehicles. g Includes fuels such as hydrogen and natural gas, but not LPG. Figure 8.3.2(a) Classified Areas Adjacent to Dispensers.

89 6 of /26/2015 7:46 AM Figure 8.3.2(b) Classified Areas Adjacent to Dispenser Mounted on Aboveground Storage Tank. Exception: The extent of the classified area around a vacuum-assist blower shall be permitted to be reduced if the blower is specifically listed for such reduced distances. The start of 8.3.2, clearly states that Table "where Class I liquids are stored, handled, or dispensed." Therefore, all references to gaseous fuels should be deleted. The electrical classification requirements for gaseous fuels are listed in NFPA52 (CNG) and NFPA2 (Hydrogen) and the requirements for gaseous fuels in creates a conflict Submitter Full Name: SPENCER QUONG Organization: QUONG ASSOCIATES INC Affilliation: TOYOTA

90 7 of /26/2015 7:46 AM Submittal Date: Mon Jul 06 14:31:43 EDT 2015

91 8 of /26/2015 7:46 AM Public Input No. 33-NFPA 30A-2015 [ New Section after ] Separation of delivery vehicle from tank can be through the use of a protected tank, remote fill or barrier wall to meet separtion distance from storage tank. Fire safety. Need to keep vehicle away from tank. As written, is not enforceable. The "honor" system does not work. Submitter Full Name: MARCIA POXSON Organization: MICHIGAN BUREAU OF FIRE SERVIC Submittal Date: Tue Jun 30 14:15:04 EDT 2015

92 9 of /26/2015 7:46 AM Public Input No. 17-NFPA 30A-2015 [ New Section after ] * Display of Materials. The storage or placement for display or sale of combustibles shall be prohibited within 20 feet of a fuel dispenser. Additional Proposed Changes File Name Description Approved 30A-PC2.pdf 30A Public Comment 2. NOTE: The following Public Input appeared as "Reject but Hold" in Public Comment No. 2 of the A2014 Second Draft Report for NFPA 30A and per the Regs. at Display material obstructs the view of the attendant and adds a fuel load that is not needed in the area of the fuel dispensers. Submitter Full TC ON AUV-AAA Name: NFPA Technical Committee on Automotive and Marine Service Organization: Stations Submittal Date: Thu Mar 26 11:25:23 EDT 2015

93 of 1 3/26/2015 9:52 AM Public Comment No. 2-NFPA 30A-2013 [ New Section after ] * Display of Materials. The storage or placement for display or sale of combustibles shall be prohibited within 20 feet of a fuel dispenser. Statement of Problem and Substantiation for Public Comment Display material obstructs the view of the attendant and adds a fuel load that is not needed in the area of the fuel dispensers. Submitter Full Name: Doug Hohbein Organization: Northcentral Fire Code Develop Submittal Date: Tue Apr 02 21:58:08 EDT 2013 Committee Statement Committee Rejected but held Action: Resolution: Public Comment No. 2 proposes a change to a paragraph in NFPA 30A that was not amended at the First Draft stage of this revision cycle. To accept this change would effect an amendment to the Code without its having undergone public review and comment. Therefore, in accordance with Paragraphs and of the Regulations Governing the Development of NFPA Standards, the Technical Committee has voted to reject Public Comment No. 2 and hold it for processing as a Public Input at the next document revision cycle. Copyright Assignment I, Doug Hohbein, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Doug Hohbein, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature

94 0 of /26/2015 7:46 AM Public Input No. 32-NFPA 30A-2015 [ New Section after 9.3 ] Fuel Pad Fuel pad must be an impervious surface. The addition of this requirement, impervious fuel pad, would eliminate most contamination incidents, and fire hazards associated with motor fueling. Submitter Full Name: MARCIA POXSON Organization: MICHIGAN BUREAU OF FIRE SERVIC Submittal Date: Tue Jun 30 14:10:55 EDT 2015

95 1 of /26/2015 7:46 AM Public Input No. 37-NFPA 30A-2015 [ Section No ] There shall be at least one attendant on duty while the self-service facility is open for business. The attendant s primary function shall be to supervise, observe, and control the dispensing of Class I liquids while said liquids are being dispensed. the attendant must monitor ALL dispensing at a facility, not just Class I dispensing. If the intent was to not have attendant monitor diesel fueling, the reason escapes this fire marshal division. Submitter Full Name: MARCIA POXSON Organization: MICHIGAN BUREAU OF FIRE SERVIC Submittal Date: Tue Jun 30 14:30:38 EDT 2015

96 2 of /26/2015 7:46 AM Public Input No. 85-NFPA 30A-2015 [ Section No ] Hose nozzle valves used on vapor recovery systems shall be listed for the purpose in accordance with ANSI/UL 2586, Standard for Hose Nozzle Valve or ANSI/UL 2586A Standard for Hose Nozzle Valves for Gasoline and Gasoline/Ethanol Blends with Nominal Ethanol Concentrations Up to 85 Percent (E0 - E85). for the purpose.. This proposal clarifies the standards used to list hose nozzle valves. Submitter Full Name: HOWARD HOPPER Organization: UL LLC Submittal Date: Mon Jul 06 16:51:26 EDT 2015

97 3 of /26/2015 7:46 AM Public Input No. 86-NFPA 30A-2015 [ Section No ] All hose shall be listed in accordance with ANSI/UL 330, Standard for Hose and Hose Assemblies for Dispensing Flammable Liquids or UL 330A Outline for Hose and Hose Assemblies for Use With Dispensing Devices Dispensing Gasoline and Gasoline/Ethanol Blends With Nominal Ethanol Concentrations Up To 85 Percent (E0 - E85). Where hose length exceeds 5.5 m (18 ft), the hose shall be secured so as to protect it from damage. This identifies the standards used to list hose. Submitter Full Name: HOWARD HOPPER Organization: UL LLC Submittal Date: Mon Jul 06 16:54:29 EDT 2015

98 4 of /26/2015 7:46 AM Public Input No. 87-NFPA 30A-2015 [ Section No ] The dispensing nozzle shall be a listed, Dispensing nozzles shall be of the automatic-closing type without a latch-open device and shall be listed in accordance with ANSI/UL 2586, Standard for Hose Nozzle Valves or UL 2586A Standard for Hose Nozzle Valves for Gasoline and Gasoline/Ethanol Blends with Nominal Ethanol Concentrations Up to 85 Percent (E0 - E85). This identifies the standards used to list dispensing nozzles. Submitter Full Name: HOWARD HOPPER Organization: UL LLC Submittal Date: Mon Jul 06 16:56:17 EDT 2015

99 5 of /26/2015 7:46 AM Public Input No. 23-NFPA 30A-2015 [ Section No ] Dispensing devices for CNG, LNG, hydrogen, and LP-Gas shall be listed. Section excludes LPG, LNG, and CNG from the scope of NFPA30A. This section conflicts with the scope exclusion and should be deleted. Related Public Inputs for This Document Related Input Public Input No. 5-NFPA 30A-2015 [Section No ] Public Input No. 75-NFPA 30A-2015 [Section No ] Relationship PI 5 excludes hydrogen from NFPA30A Submitter Full Name: SPENCER QUONG Organization: QUONG ASSOCIATES INC Affilliation: TOYOTA Submittal Date: Fri May 15 03:19:29 EDT 2015

100 6 of /26/2015 7:46 AM Public Input No. 75-NFPA 30A-2015 [ Section No ] Dispensing devices for CNG, LNG, hydrogen, and LP-Gas shall be listed or approved. This proposal should only be considered if PI23 is rejected. Due to the limited number of suppliers and products, many of the components used on hydrogen dispensing are not listed. These components have been tested to ensure they meet industry standards, but have not gone through the certification process. The "approval" option is key to ensure that approved components can be used when a listed one is not available. Related Public Inputs for This Document Related Input Public Input No. 23-NFPA 30A-2015 [Section No ] Relationship PI75 should only be considered if PI23 is rejected Submitter Full Name: SPENCER QUONG Organization: QUONG ASSOCIATES INC Affilliation: TOYOTA Submittal Date: Mon Jul 06 14:47:55 EDT 2015

101 7 of /26/2015 7:46 AM Public Input No. 24-NFPA 30A-2015 [ Section No ] Listed or approved hose assemblies shall be used to dispense fuel. Hose length at automotive motor fuel dispensing facilities shall not exceed 5.5 m (18 ft). Due to the limited number of suppliers and products, many of the components used on hydrogen dispensing are not listed. These components have been tested to ensure they meet industry standards, but have not gone through the certification process. The "approval" option is key to ensure that approved components can be used when a listed one is not available. Submitter Full Name: SPENCER QUONG Organization: QUONG ASSOCIATES INC Affilliation: TOYOTA Submittal Date: Fri May 15 03:29:32 EDT 2015

102 8 of /26/2015 7:46 AM Public Input No. 54-NFPA 30A-2015 [ Section No ] Listed or approved hose assemblies shall be used to dispense fuel. Hose length at automotive motor fuel dispensing facilities shall not exceed 5.5 m (18 ft). Due to the limited number of suppliers and products, many of the components used on hydrogen dispensing are not listed. These components have been tested to ensure they are safe, but have not gone through the certification process. The "approval" option is key to ensure that safe, approved components can be used when a listed one is not available. Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC Submittal Date: Wed Jul 01 19:49:25 EDT 2015

103 9 of /26/2015 7:46 AM Public Input No. 55-NFPA 30A-2015 [ Section No ] Listed or approved hose assemblies shall be used to dispense fuel. Hose length at automotive motor fuel dispensing facilities shall not exceed 5.5 m (18 ft). Due to the limited number of suppliers and products, many of the components used on hydrogen dispensing are not listed. These components have been tested to ensure they are safe, but have not gone through the certification process. The "approval" option is key to ensure that safe, approved components can be used when a listed one is not available. Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC Submittal Date: Thu Jul 02 12:36:26 EDT 2015

104 0 of /26/2015 7:46 AM Public Input No. 20-NFPA 30A-2015 [ Section No ] * Table shall be used to delineate and classify areas for the purpose of installation of electrical wiring and electrical utilization equipment. Table Electrical Equipment Classified Areas for Dispensing Devices Dispensing Device Compressed natural gas (CNG) Liquefied natural gas (LNG) Liquefied petroleum gas (LP-Gas) Class I, Division 1 Entire space within the dispenser enclosure Entire space within the dispenser enclosure Extent of Classified Area Entire space within the dispenser enclosure; 46 cm (18 in.) from the exterior surface of the dispenser enclosure to an elevation of 1.22 m (4 ft) above the base of the dispenser; the entire pit or open space beneath the dispenser and within 6 m (20 ft) horizontally from any edge of the dispenser when the pit or trench is not mechanically ventilated Class I, Division m (5 ft) in all directions from dispenser enclosure 3 m (10 ft) in all directions from the dispenser enclosure Up to 46 cm (18 in.) above ground and within 6 m (20 ft) horizontally from any edge of the dispenser enclosure, including pits or trenches within this area when provided with adequate mechanical ventilation Additional Proposed Changes File Name Description Approved 30A_TIA_15-1.pdf TIA Issue Date: March 14, 2014 This public input originates from Tentative Interim Amendment 15-1 (Log #1126) issued by the Standards Council on March 14, 2014 and per the NFPA Regs., needs to be reconsidered by the Technical Committee for the next edition of the Document. TIA Submitter s Substantiation: Chapter 12 of NFPA 30A provides certain provisions for alternative vehicle fuels, including compressed natural gas (CNG), liquefied natural gas (LNG), hydrogen H2, and liquefied petroleum gas (LPG). As part of these provisions, Chapter 12 mandates compliance with NFPA 52, Vehicular Gaseous Fuel Systems Code, NFPA 58, Liquefied Petroleum Gas Code, and NFPA 2, Hydrogen Technologies Code, except as modified by the chapter to accommodate dispensing of traditional liquid fuels (gasoline, diesel fuel). At the First Draft stage for the 2015 edition of NFPA 30A, Public Input No. 21 proposed the above amendment in order to make the information specific to LNG consistent with NFPA 52. The resolution of this public input was to establish a Task Group to review Chapter 12 of NFPA 30A to confirm that existing requirements did not conflict with the other documents and to identify appropriate new requirements to address any provisions that were not consistent. The Task Group was asked to review several Public Inputs to Chapter 12, in addition to No. 21. At the Second Draft stage, Second Revision No. 4 proposed amending Table so that the Class I, Division 1 classification applied only to the interior of an LNG dispenser and the Class I, Division 2 classification applied outside the dispenser enclosure, out to a distance of 3 m (10 ft). During the transcription process, the text under the column heading Class I, Division 1 that was supposed to have been deleted was not deleted. Consequently, the entry for LNG applies both Class I, Division 1 and Class I, Division 2 designations to the area within 1.5 m (5 ft)

105 1 of /26/2015 7:46 AM of the dispenser enclosure. Emergency Nature: If this error is not corrected, then Table will apply conflicting area classification designations to the zone between the dispenser enclosure out to a distance of 1.5 m (5 ft). Electrical inspectors will be in a quandary as to which designation truly applies. Designers and installers will be faced with the same problem. Also, a potential conflict will exist between Table and NFPA 52, as the latter classifies only the interior of the dispenser enclosure as Class I, Division 1. Acceptance of this Tentative Interim Amendment will allow the 2015 edition of NFPA 30A to be published correctly. This Tentative Interim Amendment is submitted in accordance with Section 5.3, Evaluation of Emergency Nature, Sub-Paragraph (a): NFPA standard contains an error or omission that was overlooked during a regular revision process. Submitter Full Name: TC on AUV-AAA Organization: NFPA Submittal Date: Thu Apr 09 11:41:05 EDT 2015

106 Reference: Table TIA 15-1 (SC /TIA Log #1126) Tentative Interim Amendment NFPA 30A Code for Motor Fuel Dispensing Facilities and Repair Garages 2015 Edition Note: Text of the TIA issued and incorporated into the text of Table , therefore no separate publication is necessary. 1. In Table , amend the electrical area classification provisions for liquefied natural gas (LNG) as follows: Table Electrical Equipment Classified Areas for Dispensing Devices Dispensing Device Compressed natural gas (CNG) Liquefied natural gas (LNG) Liquefied petroleum gas (LP-Gas) Class I, Division 1 Extent of Classified Area Class I, Division 2 Entire space within the dispenser enclosure 1.5 m (5 ft) in all directions from dispenser enclosure Entire space within the dispenser enclosure 3 m (10 ft) in all directions from the dispenser enclosure Entire space within the dispenser enclosure; 46 cm (18 in.) from the exterior surface of the dispenser enclosure to an elevation of 1.22 m (4 ft) above the base of the dispenser; the entire pit or open space beneath the dispenser and within 6 m (20 ft) horizontally from any edge of the dispenser when the pit or trench is not mechanically ventilated Up to 46 cm (18 in.) above ground and within 6 m (20 ft) horizontally from any edge of the dispenser enclosure, including pits or trenches within this area when provided with adequate mechanical ventilation Issue Date: March 14, 2014 Effective Date: March 29, 2014 (Note: For further information on NFPA Codes and Standards, please see Copyright 2014 All Rights Reserved NATIONAL FIRE PROTECTION ASSOCIATION

107 2 of /26/2015 7:46 AM Public Input No. 34-NFPA 30A-2015 [ Section No ] Tanks shall be located outside and at least 12 m (40 ft) from any important building and property line. Tanks shall also be located so that any vehicle, equipment, or container that is filled directly from the tanks is at least 12 m (40 ft) from any important building. confusion as to locating storage system on property. Previous version of 30A spelled out distance from building and property line. Submitter Full Name: MARCIA POXSON Organization: MICHIGAN BUREAU OF FIRE SERVIC Submittal Date: Tue Jun 30 14:22:25 EDT 2015

108 3 of /26/2015 7:46 AM Public Input No. 19-NFPA 30A-2015 [ Section No ] Tanks that have top openings only shall be mounted and equipped as follows: (1) * Stationary tanks shall be mounted on concrete, steel, or masonry supports at least 150 mm (6 in.) in height so as to protect the bottom of the tank from corrosion due to contact with the ground and to maintain the tank in a stable position. (2) Movable tanks shall be equipped with attached metal legs that rest on shoes or runners designed so that the tank is supported in a stable position and so that the tank and its supports can be moved as a single unit. (3) Tanks shall be equipped with a tightly and permanently attached approved pumping device having an approved hose and nozzle. (4) Each component of dispensing systems for Class I liquids shall be listed. (5) The dispenser nozzle and hose shall be designed so they can be padlocked to the hanger to prevent tampering. (6) The pump discharge shall be equipped with an effective anti-siphoning device, or the discharge hose shall be equipped with an approved self-closing nozzle. (7) Siphons or internal pressure discharge devices shall be prohibited. (8) Tanks shall have non-porous containment protection = 1/2 of the total volume of the tank. Additional Proposed Changes File Name Description Approved 30A-PC5.pdf Public Comment #5. NOTE: The following Public Input appeared as "Reject but Hold" in Public Comment No. 5 of the A2014 Second Draft Report for NFPA 30A and per the Regs. at Due to the lack of local enforcement on farms and remote areas, the requirement for capture of flammable liquids must be required to contain and prevent potential fires to humans, grass, equipment, buildings, and out structures that may be located adjacent to such tanks. Protection of the surrounding area and ground water from flammable liquids will increase overall safety. Submitter Full Name: TC ON AUV-AAA Organization: NFPA Submittal Date: Thu Apr 09 10:56:13 EDT 2015

109 of 2 4/9/2015 9:25 AM Public Comment No. 5-NFPA 30A-2013 [ Section No ] Tanks that have top openings only shall be mounted and equipped as follows: (1) * Stationary tanks shall be mounted on concrete, steel, or masonry supports at least 150 mm (6 in.) in height so as to protect the bottom of the tank from corrosion due to contact with the ground and to maintain the tank in a stable position. (2) Movable tanks shall be equipped with attached metal legs that rest on shoes or runners designed so that the tank is supported in a stable position and so that the tank and its supports can be moved as a single unit. (3) Tanks shall be equipped with a tightly and permanently attached approved pumping device having an approved hose and nozzle. (4) Each component of dispensing systems for Class I liquids shall be listed. (5) The dispenser nozzle and hose shall be designed so they can be padlocked to the hanger to prevent tampering. (6) The pump discharge shall be equipped with an effective anti-siphoning device, or the discharge hose shall be equipped with an approved self-closing nozzle. (7) Siphons or internal pressure discharge devices shall be prohibited. (8) Tanks shall have non-porous containment protection equal ½ of the total volume of the tank. Statement of Problem and Substantiation for Public Comment Due to the lack of local enforcement on farms and remote areas, the requirement for capture of flammable liquids must be required to contain and prevent potential fires to humans, grass, equipment, buildings, and out structures that may be located adjacent to such tanks. Protection of the surrounding area and ground water from flammable liquids will increase overall safety. Submitter Full Name: Doug Hohbein Organization: Northcentral Fire Code Develop Submittal Date: Tue Apr 02 22:03:05 EDT 2013 Committee Statement Committee Action: Resolution: Rejected but held Public Comment No. 5 proposes a change to a paragraph in NFPA 30A that was not amended at the First Draft stage of this revision cycle. To accept this change would effect an amendment to the Code without its having undergone public review and comment. Therefore, in accordance with Paragraphs and of the Regulations Governing the Development of NFPA Standards, the Technical Committee has voted to reject Public Comment No. 5 and hold it for processing as a Public Input at the next document revision cycle.

110 of 2 4/9/2015 9:25 AM Copyright Assignment I, Doug Hohbein, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Doug Hohbein, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature

111 4 of /26/2015 7:46 AM Public Input No. 88-NFPA 30A-2015 [ Section No ] Tanks that have top openings only shall be mounted and equipped as follows: (1) * Stationary tanks shall be mounted on concrete, steel, or masonry supports at least 150 mm (6 in.) in height so as to protect the bottom of the tank from corrosion due to contact with the ground and to maintain the tank in a stable position. (2) Movable tanks shall be equipped with attached metal legs that rest on shoes or runners designed so that the tank is supported in a stable position and so that the tank and its supports can be moved as a single unit. (3) Tanks shall be equipped with a tightly and permanently attached approved pumping device having an approved hose and nozzle. (4) Each component of dispensing systems for Class I liquids shall be listed in accordance with ANSI/UL 79, Standard for Power-Operated Pumps for Petroleum Dispensing Products, UL 87, Standard for Power-Operated Pumps for Petroleum Dispensing Products or UL Subject 87A, Outline of Investigation for Power-Operated Dispensing Devices for Gasoline and Gasoline/Ethanol Blends with Nominal Ethanol Concentrations Up to 85 Percent (E0-E85). (5) The dispenser nozzle and hose shall be designed so they can be padlocked to the hanger to prevent tampering. (6) The pump discharge shall be equipped with an effective anti-siphoning device, or the discharge hose shall be equipped with an approved self-closing nozzle. (7) Siphons or internal pressure discharge devices shall be prohibited. This proposal identifies the standards used to list the dispensing devices that can be utilized in this application. Submitter Full Name: HOWARD HOPPER Organization: UL LLC Submittal Date: Mon Jul 06 16:59:36 EDT 2015

112 5 of /26/2015 7:46 AM Public Input No. 40-NFPA 30A-2015 [ Section No. A ] A See NFPA 2, Hydrogen Technologies Code, NFPA 52, Vehicular Gaseous Fuel Systems Code, and NFPA 58, Liquefied Petroleum Gas Code, for requirements for facilities where only these fuels are dispensed.for facilities where multiple fuel types are dispensed, the requirements of each applicable code shall apply. NFPA 2, Hydrogen Technologies Code, is not currently recognized in Chapter 1 Administration yet NFPA 2 contains two chapters on hydrogen fueling facilities (i.e. - Chapter 10 GH2 Vehicle Fueling Facilities; and Chapter 11 LH2 Fueling Facilities) as well as a chapter on repair garages servicing hydrogen-fueled vehicles (i.e. - Chapter 18 Repair Garages). These requirements are contained only in NFPA 2 and nowhere else. Previous text in NFPA 52 has been removed. The Standards Council has revised the Scope of NFPA 52 and removed fueling of hydrogen-fuel cell vehicles (FCV). Also, new text has been added to clarify that the application of multiple codes is required when multiple fuel types are utilized. Related Public Inputs for This Document Related Input Public Input No. 39-NFPA 30A-2015 [Section No ] Relationship This is Annex text for the text in the related PI-39. Submitter Full Name: MARTIN GRESHO Organization: FP2 FIRE INC Submittal Date: Wed Jul 01 17:55:19 EDT 2015

113 6 of /26/2015 7:46 AM Public Input No. 76-NFPA 30A-2015 [ Section No. A ] A See NFPA NFPA 2, Hydrogen Technologies Code, NFPA 52, Vehicular Gaseous Fuel Systems Code, and NFPA 58, Liquefied Petroleum Gas Code, for requirements for facilities where only these fuels are dispensed. For facilities where multiple fuel types are dispensed, the requirements of each applicable code shall apply. NFPA 2, Hydrogen Technologies Code, is not currently recognized in Chapter 1 Administration yet NFPA 2 contains two chapters on hydrogen fueling facilities (i.e. - Chapter 10 GH2 Vehicle Fueling Facilities; and Chapter 11 LH2 Fueling Facilities) as well as a chapter on repair garages servicing hydrogen-fueled vehicles (i.e. - Chapter 18 Repair Garages). These requirements are contained only in NFPA 2 and nowhere else. Previous text in NFPA 52 has been removed. The Standards Council has revised the Scope of NFPA 52 and removed fueling of hydrogen-fuel cell vehicles (FCV). Also, new text has been added to clarify that the application of multiple codes is required when multiple fuel types are utilized. Related Public Inputs for This Document Related Input Relationship Public Input No. 5-NFPA 30A-2015 [Section No ] Appendix material for Section Submitter Full Name: SPENCER QUONG Organization: QUONG ASSOCIATES INC Affilliation: TOYOTA Submittal Date: Mon Jul 06 14:52:01 EDT 2015

114 7 of /26/2015 7:46 AM Public Input No. 18-NFPA 30A-2015 [ New Section after A ] A Many self-service stations display items such as wood, bagged ground cover, cartons of consumable products and other combustibles that create vision obstructions, excessive fire load and other hazards in and around dispensing islands and pumps. Additional Proposed Changes File Name Description Approved 30A-PC3.pdf NFPA 30A Public Comment 3. NOTE: The following Public Input appeared as "Reject but Hold" in Public Comment No. 3 of the A2014 Second Draft Report for NFPA 30A and per the Regs. at Display material obstructs the view of the attendant and adds a fuel load that is not needed in the area of the fuel dispensers. Submitter Full TC ON AUV-AAA Name: NFPA NFPA Technical Committee on Automotive and Marine Organization: Service Stations Submittal Date: Thu Mar 26 11:30:58 EDT 2015

115 of 1 3/26/2015 9:53 AM Public Comment No. 3-NFPA 30A-2013 [ New Section after A ] A Many self-service stations display items such as wood, bagged ground cover, cartons of consumable products and other combustibles that create vision obstructions, excessive fire load and other hazards in and around dispensing islands and pumps. Statement of Problem and Substantiation for Public Comment Display material obstructs the view of the attendant and adds a fuel load that is not needed in the area of the fuel dispensers. Submitter Full Name: Doug Hohbein Organization: Northcentral Fire Code Develop Submittal Date: Tue Apr 02 21:59:28 EDT 2013 Committee Statement Committee Rejected but held Action: Resolution: Public Comment No. 3 proposes a change to a paragraph in NFPA 30A that was not amended at the First Draft stage of this revision cycle. To accept this change would effect an amendment to the Code without its having undergone public review and comment. Therefore, in accordance with Paragraphs and of the Regulations Governing the Development of NFPA Standards, the Technical Committee has voted to reject Public Comment No. 3 and hold it for processing as a Public Input at the next document revision cycle. The Technical Committee also points out that, as submitted, this Public Comment would add an annex statement to a paragraph that does not exist. The Technical Committee suggests that the submitter resubmit this change as a Public Input during the next document revision cycle and to either resubmit it in the form a code requirement or identify an appropriate code section to which the annex statement can be connected. Copyright Assignment I, Doug Hohbein, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Doug Hohbein, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature

116 8 of /26/2015 7:46 AM Public Input No. 4-NFPA 30A-2015 [ Section No. D.1.2 ] D.1.2 Other Publications. D ANSI Publications. American National Standards Institute, Inc., 25 West 43rd Street, 4th Floor, New York, NY ANSI Z400.1/ Z129.1, Hazardous Industrial Chemicals Precautionary Labeling, 2005 Workplace Chemicals - Hazard Evaluation Safety Data Sheet and Precautionary Labelling Preparation, D API Publications. American Petroleum Institute, 1220 L Street, N.W., Washington, DC API RP 1621, Recommended Practice for Bulk Liquid Stock Control at Retail Outlets, 1993, reaffirmed D PEI Publications. Petroleum Equipment Institute, P.O. Box 2380, Tulsa, OK PEI RP200, Recommended Practices for Installation of Aboveground Storage Systems for Motor Vehicle Fueling, PEI RP500, Recommended Practices for Inspection and Maintenance of Motor Fuel Dispensing Equipment, D STI/SPFA Publications. Steel Tank Institute/Steel Plate Fabricators Association, 944 Donata Court, Lake Zurich, IL STI RP 01-69, Recommended Practice for SP0169, Control of External Corrosion of Underground or Submerged Metallic Piping Systems. (This is a NACE document) STI RP , Recommended Practice for Corrosion Protection of Underground Piping Networks Associated with Liquid Storage and Dispensing Systems, STI RP 1632, Cathodic Protection of Underground Petroleum Storage Tanks and Piping Systems. (This is an API recommended Practice) D SwRI Publications. Southwest Research Institute, 6220 Culebra Road, P.O. Drawer 28510, San Antonio, TX SwRI 93, Testing Requirements for Protected Aboveground Flammable Liquid Fuel Storage Tanks, 2001 edition.

117 9 of /26/2015 7:46 AM D UL Publications. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL ANSI/ UL 79, Standard for Power-Operated Pumps for Petroleum Dispensing Products, 2005, Revised UL 87, Standard for Power-Operated Pumps for Petroleum Dispensing Products, , Revised UL Subject 87A Outline, Outline of Investigation for Power-Operated Dispensing Devices for Gasoline and Gasoline/Ethanol Blends with Nominal Ethanol Concentrations Up to 85 Percent (E0-E85), ANSI/ UL 330, Standard for Hose and Hose Assemblies for Dispensing Flammable Liquids, 2009, Revised ANSI/ UL 567, Standard for Emergency Breakaway Fittings, Swivel Connectors and Pipe-Connection Fittings for Petroleum Products and LP-Gas, 2003, Revised ANSI/ UL 842, Standard for Valves for Flammable Fluids, 2007, Revised ANSI/ UL 2085, Standard for Protected Aboveground Tanks for Flammable and Combustible Liquids, 1997, Revised ANSI/ UL 2586, Standard for Hose Nozzle Valves, 2011, Revised D U.S. Government Publications. U.S. Government Printing Government Publishing Office, Washington, DC DOT HM-181, Basis Hazmat Employee Training Program. Title 29, Code of Federal Regulations, Part Title 49, Code of Federal Regulations, Parts 171 and 173. Referenced current SDO standard numbers, names, and years. Related Public Inputs for This Document Related Input Public Input No. 3-NFPA 30A-2015 [Section No. 2.3] Public Input No. 2-NFPA 30A-2015 [Global Input] Relationship Referenced current SDO addresses, standard numbers, names, and years. Submitter Full Name: Aaron Adamczyk Organization: [ Not Specified ] Submittal Date: Sat Feb 07 00:10:38 EST 2015

118 00 of /26/2015 7:46 AM Public Input No. 60-NFPA 30A-2015 [ Section No. D ] D API Publications. American Petroleum Institute, 1220 L Street, N.W., Washington, DC API RP 1621, Recommended Practice for Bulk Liquid Stock Control at Retail Outlets, 5th Edition (Reaffirmed 2012) provides correct title and edition Submitter Full Name: RICHARD KRAUS Organization: APIPETROLEUM SAFETY CONSULTAN Submittal Date: Thu Jul 02 15:51:41 EDT 2015

119 Proposed TIA to NFPA 30A-2008: 1. Add a new definition of alcohol blended motor fuel to read: 3.3.X* Alcohol Blended Motor Fuel. Motor fuel consisting of a blend of alcohol, such as ethanol, and gasoline with an alcohol concentration greater than 10 percent by volume, including those with nominally 85-percent ethanol / 15-percent unleaded gasoline (E85). 2. Add a new Subsection and accompanying annex item to read: "6.2.3* Fuel-dDispensing systems devices and related dispensing equipment, including dispensers, hoses, nozzles, breakaway fittings, swivels, flexible connectors, dispenser emergency shutoff valves, and vapor recovery systems and pumps that are used for alcohol blended motor fuels shall be listed or approved for the specific purpose. A The majority of existing dispensers and related dispensing equipment are listed by UL for fuels up to E10 (i.e., 10% alcohol/90% gasoline blend). More recently, UL has begun listing dispensing devices for alcohol blended fuels up to E25 (i.e., 25% alcohol/75% gasoline blend) and E-85 (i.e., 85% alcohol/15% gasoline blend) (See UL SU87A, Outline for Power-Operated Dispensing Devices for Gasoline and Gasoline/Ethanol Blends with Nominal Concentrations up to 85 percent). While the existing dispensing devices and related dispensing equipment currently in service at motor fuel dispensing facilities are listed for use with fuels up to E-10, they are not listed for use with alcohol blended motor fuels (i.e., greater than 10% alcohol/90% gasoline blend). A significant consideration for approval of existing equipment for mid-level alcohol blended fuels such as E-15 (i.e., 15% alcohol/85% gasoline blend) is that mid-level alcohol blended fuels, if approved by USEPA, may likely become a replacement for current motor fuels either through state or federal mandates or supply chain restrictions. The availability of dispensing devices and related dispensing equipment listed for alcohol blended motor fuel is currently limited and listing for alcohol blended fuels will not be retroactive to existing dispensing devices and related dispensing equipment. In order to maintain the supply of motor fuel, this may require the sale of this fuel through existing dispensing devices and related dispensing equipment. To address this issue, the authority having jurisdiction is provided with the ability to approve dispensing devices and related dispensing equipment currently listed for use with E-10 for midlevel alcohol blended motor fuels service (e.g. E-15). When approving a dispensing device or related dispensing equipment for use with alcohol blended motor fuels, the authority having jurisdiction may take into account other factors including, but not be limited to, actual field experience, more frequent inspection of the equipment, information from the manufacturer of the equipment, or evidence of compatibility and/or functionality by government agencies, trade associations, testing laboratories. 3. Add a new entry to Table B.1, Typical Flammable and Combustible Liquids Found at Motor Fuel Dispensing Facilities, to read: : Alcohol Blended Motor Fuel / -40 F 55 F / Class IB / varies / Submitter s Reason: The purpose of the Tentative Interim Amendment is to incorporate into the 2008 edition of NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages, a

120 new provision, one that is being simultaneously proposed by the Technical Committee on Automotive and Marine Service Stations in the upcoming 2012 edition of NFPA 30A, that This will allow the application of the provision in jurisdictions that are currently and might be in the near future still subject to the 2008 edition of the Code. Technical Validity: The proposal in question provides a means for the authority having jurisdiction to approve equipment for so called mid-level ethanol-blended fuel service (i.e., above 10 percent ethanol) dispensing equipment that is not currently listed for such use, as is required by the 2008 edition of NFPA 30A. Recognize that this equipment is currently listed for use with ethanol/gasoline blends containing up to 10 percent ethanol (E10). It is left to the authority having jurisdiction to determine the factors to be considered in approving this equipment for use with higher (>10%) percentages of ethanol. The proposed annex provides guidance for the authority having jurisdiction. This guidance along with the leak detection requirements required under NFPA 30 and NFPA 30A and the USEPA underground storage tank regulations provide a level of assurance that potential issues associated with this equipment will be identified and resolved without incidentthese may include, but not be limited to, actual field experience, certification by the manufacturer of the equipment, additional equipment and controls, more frequent inspection of the equipment, or evidence of compatibility and/or functionality by government agencies, trade associations, testing laboratories, or any combination of these. Emergency Nature: It is the submitter s position that this TIA meets the criterion of Section 5.2(e) of the NFPA Regulations Governing Committee Projects for emergency nature. The U. S. Environmental Protection Agency has already approved the use of E85 in flex-fuel vehicles. It is anticipated that they will approve the use of mid-level ethanol blends (>10% but <85%) by midsummer This leaves an even greater gap in the coverage of this equipment by NFPA 30A without this TIA. In addition, authorities having jurisdiction might be under legislative pressure to unilaterally approve equipment to store, meter, and dispense mid-level ethanol blends into vehicles based on the fact that the U. S. Environmental Protection Agency has approved such blends for use in most of the nation s vehicles. The intent is to provide the means for the authority having jurisdiction to grant equivalency or an alternative, while still being protective of human health and the environment.

121 LL #75 Tank-nically Speaking by Marcel Moreau Are Two Poppets Better Than One? Crash valves installed at the base of dispensers are supposed to stop the flow of fuel from the submersible pump when a vehicle hits the dispenser. Yet In New York State this past July (2014), a driver, suffering from a medical condition, plowed into a dispenser at a high rate of speed. A substantial fire erupted immediately

122 and was beginning to engulf the passenger compartment of the car when an off duty policeman, who was filling up nearby, bravely pulled the unconscious driver to safety (and then ran back to retrieve the ammunition in the trunk of his car before his vehicle was engulfed in flames.) But for the courage of the bystander, the driver would have been toast. (To view surveillance camera footage of this incident, go to: x=51) In Washington State (2012), a driver maneuvering at a gas station backed into a dispenser and knocked it over. Flames erupted as the driver drove away. The fire continued to burn for some time. (To view surveillance camera footage of this accident go to: x=40) In Maine (2004), the inebriated driver of a pickup truck crashed into a dispenser, which immediately erupted into flames. The driver backed up and drove away. A couple fueling their car at a nearby dispenser ran for safety. An automatic fire suppression system eventually put the fire out, but not before the flexible piping in the sump beneath the dispenser had been substantially damaged by the heat. If an alert operator had not activated the emergency stop switch to shut down the submersible pumps, the fire could have been catastrophic. (To watch the video go to: 4E45) In each of these incidents, the single-poppet crash valves functioned as designed. Flow from the submersible pump was stopped and no geysers of gasoline erupted from the dispenser islands. But there were still serious fires that could have resulted in serious injuries or death. How come? Alas, the Single-Poppet Crash Valve When a single-poppet crash valve shears, the valve mechanism in the bottom half of the crash valve closes and stops the flow of fuel from the submersible pump. But the fuel already in the

123 dispenser can flow out into the environment because the top part of the crash valve contains no valve mechanism. How much fuel can be released? It depends on the dispenser design, but for dispensers with three products on each side, there could be as many as six filters, six meters, six hoses, plus tens of feet of tubing connecting all these components, potentially releasing several gallons of gasoline. When the vapor from the spilled gasoline encounters broken electrical wires, sparks from scraping metal, or hot components of the vehicle engine, the likelihood of a fire is high. The result? Serious fires that cause significant damage and sometimes kill or severely injure people. Is There a Better Way? A quarter century ago, at the request of oil companies seeking to limit the damage resulting from vehicle/dispenser crashes, petroleum equipment manufacturers introduced the double-poppet crash valve. The bottom half of the valve is identical to the single-poppet version of the crash valve. The difference is in the upper half. In the double-poppet design, the upper portion of the crash valve contains another valve mechanism that remains open as long as the crash valve remains intact. When the crash valve activates in an accident, the upper poppet closes and the gasoline in the dispenser components is contained. Using double-poppet crash valves seems like a no-brainer in terms of safety. The additional cost seems easily justifiable as well, because the cost of repairing extensive fire damage from even one event will pay for the extra cost of a lot of double-poppet crash valves. Despite the apparent advantages, fire codes and industry recommended practices (with one exception) are silent on the advantages of double-poppet crash valves: American Petroleum Institute Recommended Practice 1615, Installation of Petroleum Storage Systems, states, Double poppet or secondarily contained double poppet impact (shear) valves should be considered for additional safety. (API 1615 sixth edition, April 2011, p. 41). PEI RP 100, Recommended Practices for Installation of Underground Liquid Storage Systems, is silent on the matter. (PEI RP , p. 25).

124 The International Fire Code also does not indicate a preference for either single- or double-poppet crash valves (IFC 2009, Section ). NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages, (the code that has required the installation of crash valves since 1966) is also silent as to which type of crash valve to use (NFPA 30A, 2012 edition, Section 6.3.9). The NFPA Flammable and Combustible Liquids Code Handbook, which provides background information and additional commentary concerning the code requirements, explains that the NFPA Technical Committee does not recommend double-poppet crash valves because some members of the Committee believe that these valves pose a hazard to emergency response personnel. According to the Handbook, the concern is that if there is a fire surrounding the dispenser, the fuel trapped inside the dispenser could forcefully rupture, endangering emergency response personnel who might be working to control the fire (Flammable and Combustible Liquids Code Handbook, 2012 Edition, p. 515). This has been the position of the NFPA Technical Committee since at least the 1996 edition of the NFPA Handbook (Flammable and Combustible Liquids Code Handbook, 1996 Edition, p. 404). But is the scenario envisioned by the NFPA Technical Committee realistic? In other words, do dispensers equipped with double-poppet crash valves commonly blow up when they are hit and a fire results? Because a large number of double-poppet crash valves have been in service for many years now, we should be able to answer this question. What has been the experience of people who have used double-poppet crash valves as standard equipment for many years? To help answer this question, I sought the help of my colleague Ben Thomas of????, who has a vast network of contacts in the UST world. Here s what we found. Larry Gregory, who was responsible for Exxon s gas stations on a global scale until a few years ago, reports that he specified double-poppet valves immediately after they were introduced. He is a firm believer in their ability to reduce fires when dispensers are hit and reports that he has never heard of an incident where a dispenser equipped with a double-poppet crash valve blew up.

125 An east coast petroleum marketer with well over a 1,000 stations has also equipped his facilities with double-poppet crash valves for many years. He reports that on average he sees a dispenser accident about once a week, but despite hundreds of dispenser impacts in recent years, he has not had any fires that resulted from these incidents. Another east coast petroleum marketer with several hundred gas stations uses doublepoppet crash valves exclusively and has thousands in service. These stations typically experience one or two dispenser accidents a month, but in the past 18 years, there have only been four fires. In one incident that resulted in a fire, the fire chief s report concluded that the fuel that ignited came from the vehicle and not the dispenser. This company has never experienced a dispenser explosion. John Albert, who administers Missouri s tank program, reports that dispensers in Missouri with non-metallic product piping must either have double-poppet crash valves or fire extinguishers installed in a sump beneath the dispenser. The rules reflect John s experience that double-poppet crash valves greatly limit the potential for fires when dispensers are hit. We ve had many dispensers get hit over the past 25 years, but very few fires, says John. He is aware of the differing points of view among fire officials but has never had a dispenser explode because of a double-poppet crash valve. My experience is that the soft seals in the meter and filter are the first things to fail in a fire scenario. This results in a slow release of product, but no explosion. OPW is a major manufacturer of both single- and double-poppet crash valves for use not only in North America but also throughout the world. Glenn Eckart of OPW told us that the OPW double-poppet shear valve has incorporated a pressure relief feature since it was first introduced in the late 1980s. Since they were first manufactured in the late 1980s, no one at OPW can recall ever receiving a report of a dispenser equipped with a doublepoppet crash valve exploding. These anecdotal reports from a variety of knowledgeable people clearly point to the advantages of double-poppet crash valves and provide no support for the NFPA position that these valves

126 pose a threat to emergency response personnel. We ed Robert Benedetti, Principal Flammable Liquids Engineer at NFPA, to ask whether they knew of any incidents where the forceful rupture of a dispenser equipped with a double-poppet crash valve had actually occurred. Mr. Benedetti replied, This issue of single versus double poppet valves came up several editions of the code ago. At the time, the Technical Committee discussed this issue with respect to fire suppression activities. As I recall, the fire service representatives on the Technical Committee were leery of a fire beneath a dispenser whose components contained liquid that was locked in. This issue has never been brought up since. If experience shows otherwise, then all that needs to be done is for someone to submit a proposal to amend NFPA 30A to allow the double poppet design. Bottom Line? You guessed it. We believe that double-poppet crash valves have clear safety advantages over the single-poppet versions and their use should be at least a recommended practice if not an outright requirement. While some well-informed petroleum marketers are already using doublepoppet crash valves, many marketers who are not aware of the added safety provided by doublepoppet valves continue to specify the single-poppet versions. This substantially increases the risk that fires will result when dispensers are hit and people will get seriously hurt. Our goal in writing this article is to educate the UST community about this issue and to encourage UST owners to seriously consider double-poppet shear valves as a means to limiting liability, limiting damage, and ultimately, saving lives. Oh, and we do plan to submit a comment to amend the next edition of NFPA 30A. If you have a shear valve story you d like to share showing how single- or double-poppet shear valves did or did not save the day, we d love to hear from you. Contact Ben Thomas at ben@usttraining.com or Marcel Moreau at marcel.moreau@juno.com.

127 sidebar You Say Crash, I Say Shear The crash valves in this article are called different names around the country. What do YOU call them? Crash valve Shear valve Fire valve Impact valve Emergency shutoff valve Earthquake valve sidebar Crash Valve Musts While crash valves are the wallflowers of the UST world, waiting patiently for their turn to save the day, they must not be ignored. Crash valves are critical pieces of UST safety equipment that must be properly installed and maintained if they are to do their job. Here are some basics: They must be rigidly anchored to the island and properly fastened to the dispenser They must be installed at the proper height relative to the dispenser island They should be tested for operation annually Fittings tightness testers install in the test plug opening of the valves must NOT be left in place when the tightness test is completed.

128 Benedetti, Bob From: Sent: To: Subject: Benedetti, Bob Monday, December 01, :09 PM Benedetti, Bob NFPA 30A Agenda - Double-Poppet Crash Valves From: Wayne Geyer [mailto:wgeyer@steeltank.com] Sent: Monday, August 18, :31 AM To: Benedetti, Bob Subject: FW: Do Double Poppet Crash Valves Work? Interesting! Wayne From: UST Training [mailto:ben.thomas=usttraining.com@mail3.wdc03.rsgsv.net] On Behalf Of UST Training Sent: Monday, August 18, :59 AM To: Wayne Geyer Subject: Do Double-Poppet Crash Valves Work? View this in your browser Calling all customers and friends: We are conducting a survey about UST safety and need your help! As you may know, traditional, crash (or shear) valves installed at the base of fuel dispensers have a single poppet that closes when the dispenser is subjected to a significant impact like the picture above. This stops the flow of fuel from the 1

129 submersible pump, but still allows the fuel in the filters, meters, and piping inside the dispenser cabinet to drain out. The fuel in the dispenser could amount to several gallons and can cause a significant fire if it drains out and ignites. Double-poppet crash valves were introduced about 25 years ago to contain the fuel in the dispenser in hopes of greatly reducing the amount of fuel released in a dispenser crash and so preventing major fires from occurring. So do double-poppet crash valves prevent fires? Do you know of an incident where: 1. A dispenser was hit; 2. There was/was not a fire as a result of the impact; 3. You know what type of crash valve (single or double poppet) was installed. If so please contact us: we d like to hear from you! Marcel Moreau and I are working on an article for publication in LUSTline that documents the effectiveness (or not) of double-poppet crash valves. If you have a story or general information to share about this issue, me at ben@usttraining.com; or call me at Thanks for your help! Ben Thomas Copyright 2014 UST Training, All rights reserved. You are receiving this because of your relationship with UST Training. Our mailing address is: UST Training PO Box 1591 Langley, WA Add us to your address book 2

130 Benedetti, Bob Subject: FW: NFPA Technical Question Response [ ref:_00d5077vx._50050ygqo3:ref ] Based on this inquiry, AUV needs to revise NFPA 30A, 6.7 to state the same as NEC Art (A). From: Benedetti, Bob Sent: Wednesday, January 07, :03 PM To: office@sparkmanelectricllc.com Subject: RE: NFPA Technical Question Response [ ref:_00d5077vx._50050ygqo3:ref ] Good afternoon, Mr. Sparkman: I m not sure if I can give a definitive answer here, since your questions relate to Article of NFPA 70, National Electrical Code. I have no responsibilities with this Code; my responsibility is striuctly with NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages. Nevertheless, I will provide my own informal non-binding opinions. NFPA 30a, in Section 6.7, requires that every fuel dispensing system have an electrical disconnect and that this disconnect must cut power to the dispenser, the fuel pump, and any related circuit elements. Beyond that, it does not specify. Article (A) of the NEC appears to me to be more specific. It states:... to disconnect simultaneously from the source of supply, all conductors of the circuits, including the grounded conductor, if any. The following is from the commentary on Article (A), as published in the National Electrical Code Handbook: The intent is that no energized conductors are in the dispenser vicinity during maintenance or alteration. In the case of accidental reversal of the polarities of conductors at panelboards, the grounded conductor must be able to be switched to the open or off position. I believe herein lies your answer, but you might want to submit this same inquiry to our Electrical Code Department via the NFPA 70 DocInfo page on our web site. Please understand that this response is a personal opinion and does not constitute a Formal Interpretation of the National Fire Protection Association, as noted below and as described in Section 6 of NFPA s Regulations Governing Committee Projects. It is not to be relied upon to definitively determine compliance with any laws, ordinances, rules, or regulations. To determine legal compliance, you should refer to the appropriate authority having jurisdiction or seek legal advice. It is not intended, nor should it be relied upon, to provide professional consultation or services. To determine the adequacy or safety of any device or installation, you should consult with an appropriate professional. I hope this response is helpful. If you have a follow-up question related to this inquiry, please reply to this . If you have another question on a separate topic or a different document, please return to the document information pages and submit your new question(s) by clicking on the Technical Questions tab. R. P. Benedetti 1

131 cc 30A/IFI Robert P. Benedetti, CSP, PE, FSFPE Principal Flammable Liquids Engineer National Fire Protection Association 1 Batterymarch Park Quincy, MA (FAX) (CELL) bbenedetti@nfpa.org IMPORTANT NOTICE: Any opinion expressed is the personal opinion of the author and does not necessarily represent the official position of the NFPA or its Technical Committees. In addition, this correspondence is neither intended, nor should it be relied upon, to provide professional consultation or services. From: office@sparkmanelectricllc.com [mailto:office@sparkmanelectricllc.com] Sent: Tuesday, December 23, :23 PM To: Benedetti, Bob Subject: RE: NFPA Technical Question Response [ ref:_00d5077vx._50050ygqo3:ref ] Importance: High Bob, Thank you for your response. If this facility happens to be designated as an unattended fueling facility, is it intention of the code that the emergency shut off to shunt trip all ungrounded legs and the grounded leg (neutral)? Is the neutral wire to be broken with the hot wires? Thank you, Allan Sparkman President Sparkman Electric, LLC

132 Original Message Subject: NFPA Technical Question Response [ ref:_00d5077vx._50050ygqo3:ref ] From: "Bob Benedetti" <bbenedetti@nfpa.org> Date: 12/23/14 2:13 pm To: "office@sparkmanelectricllc.com" <office@sparkmanelectricllc.com> <center > Good afternoon, Mr. Sparkman: As we discussed during our earlier conversation, it is my opinion that the installation you describe is not an unattended motor fuel dispensing facility, as this term is defined by NFPA 30A. Such a facility is characterized by there being "no attendant or employee on duty". In contrast, the facility you describe involves fueling ONLY by employees of the facility. The facility is more correctly characterized as an attended fleet vehicle fuel dispensing facility. Please understand that this response is a personal opinion and does not constitute a Formal Interpretation of NFPA, as noted below and as described in Section 6 of NFPA s Regulations Governing Committee Projects. It is not to be relied upon to definitively determine compliance with any laws, ordinances, rules, or regulations. To determine legal compliance, you should refer to the appropriate authority having jurisdiction or seek legal advice. It is not intended, nor should it be relied upon, to provide professional consultation or services. To determine the adequacy or safety of any device or installation, you should consult with an appropriate professional. I hope this response is helpful. If you have a follow-up question related to this inquiry, please reply to this . If you have another question on a separate topic or on a different NFPA document, please return to the document information pages and submit your new question(s) by clicking on the Technical Questions tab of the appropriate NFPA document page. R P Benedetti Principal Flammable Liquids Engineer National Fire Protection Association 1 Batterymarch Park Quincy, MA bbenedetti@nfpa.org Important Notice: Any opinion expressed is the personal opinion of the author and does not necessarily represent the official position of the NFPA or its Technical Committees. In addition, this correspondence is neither intended, nor should it be relied upon, to provide professional consultation or services Create Date: 12/19/2014 Contact: ALLAN SPARKMAN Subject: ATTN: Bob Benedetti Question for NFPA: I am installing a fuel system at a multi-rental car facility located at an airport parking garage. In regards to NEC (a,b, and c): I am requesting clarification as to whether this is an unattended or attended facility as paid employees that their job description is to fuel the cars and clean them are the only ones filling the vehicles. If this is an unattended self-service motor fueling facility as described in (c), is it intention of the code that the emergency shut off to shunt trip all ungrounded legs and the grounded leg (neutral)? Is the neutral wire to be broken with the hot wires? Please send me clarification so I can submit to the engineers and the general contractor. Please contact me at if you have any questions. 3

133 6.7 Emergency Electrical Disconnects. Fuel dispensing systems shall be provided with one or more clearly identified emergency shutoff devices or electrical disconnects. Resetting from an emergency shutoff condition shall require manual intervention and the manner of resetting shall be approved by the authority having jurisdiction. Exception: Intrinsically safe electrical equipment need not meet these requirements Emergency shutoff devices or electrical disconnects shall be installed in accordance with (1) (4): (1) Located in approved locations (2) Located not more than 30 m (100 ft) from the fuel dispensing devices that they serve (3) Disconnect power to all dispensing devices; to all remote pumps serving the dispensing devices; to all associated power, control, and signal circuits; and to all other electrical equipment in the hazardous (classified) locations surrounding the fuel dispensing devices (4) Interconnected when more than one emergency shutoff device or electrical disconnect is provided At attended motor fuel dispensing facilities, the shutoff devices or disconnects shall be readily accessible to the attendant At unattended motor fuel dispensing facilities, the shutoff devices or disconnects shall be readily accessible to patrons The shutoff devices or disconnect(s) required by 6.7 shall not be located not less than 6 m (20 ft) from the dispensing devices they serve At least one additional shutoff device or disconnect to those required by 6.7 shall be readily accessible to each group of dispensing devices on an individual island.

134 From: Benedetti, Bob To: "Bausch, Eric L NWO" Cc: Gunkelman, Robert L NWO Subject: RE: NFPA 30 & 30A Truck Offload Separation from Tanks Date: Wednesday, March 09, :56:00 PM Gentlemen: Thank you for sending me the photos and the summary of your dilemma. In thinking about this, I realize that the 25-foot and 15-foot separation distances in NFPA 30, Flammable and Combustible Liquids Code, originate with bulk plants and established a minimum separation between a storage tank and the loading rack that was supplied by that storage tank. In earlier editions of NFPA 30, there used to be a separate chapter on bulk plants and that is where this requirement originated. It had nothing to do with service stations or fleet refueling because, at that time, aboveground storage tanks were not allowed at either. So, we need to look at this in a different light. I tend to agree with you, as we discussed in Orlando, that laying 25 feet of hose to the loading box is a greater hazard than is the one purportedly being addressed, namely a fire originating at the delivery vehicle being a threat to the tank. It seems to me that the chances of having such a fire are aggravated by the length of the hose. In any event, this will be placed on the Agenda for the next meeting of the Technical Committee on Automotive and Marine Service Stations. Best Regards, Bob Benedetti cc Robert P. Benedetti, CSP, PE Principal Flammable Liquids Engineer National Fire Protection Association 1 Batterymarch Park Quincy, MA (FAX) (CELL) bbenedetti@nfpa.org -----Original Message----- From: Bausch, Eric L NWO [mailto:eric.l.bausch@usace.army.mil] Sent: Friday, March 04, :26 AM To: Benedetti, Bob Cc: Gunkelman, Robert L NWO Subject: RE: NFPA 30 & 30A Truck Offload Separation from Tanks Mr. Benedetti, As you requested, I'm attaching a couple photos of typical 2080/2085 tanks we find installed with the dispenser and fillbox located on the tank skid. Thank you, Eric Bausch, PE Civil Engineer - POL-DX Corps of Engineers, Omaha District

135 -----Original Message----- From: Gunkelman, Robert L NWO Sent: Thursday, March 03, :19 PM To: bbenedetti@nfpa.org Cc: Bausch, Eric L NWO Subject: NFPA 30 & 30A Truck Offload Separation from Tanks Mr Benedetti, Thank you for your time at the NISTM conference on Monday. This is a follow on our discussion of the requirement to have fuel delivery trucks be separated from fuel tanks by 15/25 feet. My difficulty has been to located 2085 tanks for land vehicle fueling on military bases (fleet facilities) and safely maintaining the truck to tank separation distance. Some sites have resulted in parking the delivery trucks on a concrete hardstand 25 ft from a tank with the fillbox attached to the tank structure. This results in the delivery trucks having to lay the offload hoses across the pavement and (hopefully) blocking traffic next to the tank and tank mounted dispenser. My concern is that this creates much more of a safety hazard than having the truck pull-up next to the fillbox to offload fuel. I have been able to safely located the truck away from the tank on other projects, but this has been costly as general spill containment/concrete pavement is required at both the dispensing areas (next to the tank) and truck offload area. I request that this issue be looked at for, at least, fleet facilities. Thank you, Robert L Gunkelman, PE Civil Engineer - POL-DX Corps of Engineers - Omaha District (W) (M)

136 -----Original Message----- From: Sent: Wednesday, November 17, :58 PM To: Wayne Geyer Subject: Re: FW: Admiral UST explosion Wayne - I have no problem whatsoever with your sharing my response with anyone/everyone who might be able to add to industry knowledge about such events. I honestly believe the industry should pursue this and related items like mandatory electrical grounding of any/all risers or vents that have access to tank inventories that are flammable or combustible. This latter subject is now far more of a concern in my mind since secondary containment, exterior coatings, and the use of dielectric materials have removed much UST system hardware from traditional grounding paths. Unfortunately, with most majors now spinning off their direct market assets, this will probably prove to be much more difficult. Glen Marshall -----Original Message----- From: rmc@suddenlink.net [mailto:rmc@suddenlink.net] Sent: Tuesday, November 16, :08 PM To: Wayne Geyer Subject: Fwd: RE: Lightning Ignites UST Wayne - I really appreciate your continued efforts on this. VERY unusual explanation as it initially seems at odds with physics. The "earth ground" may have been the fill ring set in concrete in physical contact with the backfill soil. The "ground" structure may also have included a tank riser which may have been an uncontained/unprotected steel pipe. If the ground/soil were wet, that's another factor supporting grounding. The fill tube was inside a dielectric containment (tank), so it had no access to earth ground other than the above structure. The tank ullage should still have been too rich to support ignition. However, this lack of adequate oxygen would change drastically as you travel up the fill towards the connection point at grade. The opposite is true for the fuel vapors which will lean out as we come up towards grade since the vapors are heavier than air. Nevertheless, somewhere in that scenario, the electrical energy apparently arced in an area where the fuel vapors were still rich enough and finally had access to sufficient oxygen to light off. As for the woman smoking a cigarette in her truck while parked over the tank field, I suspect she was a nonfactor that simply happened to be in the wrong place at the wrong time. Probably the last time she'll ever be in that position again due simply to fear and superstition. I think the same results would have occurred regardless of which fuel grade the lightning chose to strike. Gasoline is more volatile (easier to ignite) and diesel contains more btu's of energy than gasoline. Either way, no tank, regardless of construction material or numbers of walls, is going to successfully resist the explosive pressures applied. I have long been a proponent of electrically grounding any/all tank risers that have access to stored fuel/fuel vapors in the tank. This is aimed at reducing static ignition arcing during connection/disconnetion of fuel delivery hoses (hook up ground first and last in said process). However, I doubt grounding would have had any significant affect whatsoever on the possible scenario discussed above. It may also be that at the massively elevated energy and temperature levels of a lightning strike, ordinary electrical theory just doesn't work as we expect. Finally, no, I've never heard of or dealt with any lightning strikes on UST systems. But then, engineering is not the exact science that most people assume it to be. There's still a tremendous amount of information and physical phenomena that we just do not understand. Again, thanks for your efforts to chase this down.

137 From: To: Subject: Date: Robert Renkes Benedetti, Bob Questions for 30A Committee Monday, August 19, :24:55 AM Bob As you know, I had intended to attend the meeting on Thursday but circumstances (granddaughter care) prevent me from making the trip. Guy has to do what he has to do. If I was there, I would have discussed the coordination of 30A and 52 with the committee. In drafting PEI s new recommended practice on CNG dispensing systems, the committee has run into several problems concerning E-stops that I d hope the 30A committee could resolve. Here is how I understand the codes and the queries from our CNG committee: Specifically, 30A is applicable to CNG facilities only when booth gasoline/diesel and CNG are dispensed from the same motor fuel dispensing facility (1.1.2). I assume that means the entire property on which the station is located. I think I m correct on this. If a CNG dispenser is on the same island (either under the same canopy or an adjacent canopy) as a gasoline dispenser, then how far is the E-Stop to be located from the dispenser? 30A says not less than 20 feet or more than 100 feet from the fuel dispensing devices that they serve (6.7). 52 says within 10 feet and also greater than 25 feet from the dispensing area ). Which code are they under? Same scenario as above. Should the CNG E-Stop cut off power to the liquid dispensers as well? And should the liquid E-Stop cut off power to the CNG dispenser? Does that answer change if the dispensing is done a distance away from each other i.e., the other side of the building or so many feet away in a separate, stand-alone island? In that case the station can use the two different distances without much problem but what is required to be shut off in that case, I think 30A controls but I am not sure. Do you have the answers and/or do you mind posing the questions to the committee? Thanks. Bob Bob Renkes Executive Vice President/General Counsel PEI P. O. Box 2380, Tulsa, OK Follow me on Twitter!

138 NFPA 30A Technical Committee August 7, Batterymarch Park, Quincy, MA Attention: Alfredo Ramirez Chairman, and Robert Benedetti NFPA Staff Liaison FlexStation FlexStation USA, LLC 3535 Hiawatha Ave. Suite 304 Miami, FL SUBJECT: NFPA 1 st Draft TC Meeting Agenda Item for Introduction of New Fueling Station Concept and Request for Feedback on Code Compliance Dear Sirs, It is with this letter that I would like to formally request a brief presentation of our innovative FlexStation fueling station concept at the NFPA 30A First Draft TC Meeting this fall, followed by a discussion of key Code compliance issues and Certification plans. Our company designs, manufactures, installs and will service these factory made, modular fuel stations for attended or unattended fuel dispensing in public commercial and private fleet businesses, or for quick deployment in emergency and temporary use applications. We believe this technical exchange will be mutually beneficial to inform committee members of this new product, and allow us to obtain important information on Code compliance and construction/performance requirements. The new and innovative FlexStation concept is for individual pre fabricated modules (Gas/Diesel, LPG, CNG, GH2, EV) to be installed on site with minimal excavation and assembly. Each module has a similar base construction (fuel tanks in structural canopy integrated with a dispensing island) and similar systems (fire resistance & protection, power distribution, component options) but has variations for the different fuel types. Please see our presentation draft on the following page. The key Code compliance issues we are seeking committee member input on are informal interpretations and potential gaps, which may result in development of proposals to act on within this Code cycle. These were identified in a New & Innovative project conducted by UL last year, along with the basic Standard requirements for major components within these systems. Please see Basic Concept and Appendix A for details. Our goal is to collaborate with the 30A, and other NFPA TCs as necessary, to ensure the next Code editions will address the installation and use of this new product. On behalf of FlexStation, I would like to thank you in advance for your time and consideration. Sincerely, Arturo Cajiga Vice President & Co founder FlexStation USA, LLC acajiga@mac.com +1(305)

139 Basic Flex Station Concept The FlexStation will first be available in traditional gasoline & diesel fuel versions, with plans for addition of alternative fuel versions for LPG & CNG (near future), plus quick charging for electric vehicles and hydrogen for fuel cells (far future). In addition to operational electrical power supplied by traditional grid sources, power supply options include emergency generators (diesel, LPG or CNG) integrated into the design, and photovoltaic systems for supply of low voltage lighting & control components. Each modular unit is transported from the factory on a mobile trailer and unloaded at the end use location in single stand alone or multiple connected unit configurations. The system is intended to be installed on existing site pads (concrete or asphalt) with minimal excavation, so is also capable of local relocation and add ons. All initial mechanical & electrical field installations, periodic inspection, plus any maintenance will only be conducted FlexStation trained & authorized contractors. Remote monitoring of operational (such as fuel levels) and safety (such as emergency signals) are also available from FlexStation as service options. BASIC CONCEPT 2 CONNECTED MODULES BASIC CONCEPT 1 EXPANDED VIEW MODULE Besides the pre fabricated modular concept, the most unique features are the elevated fuel tanks for either traditional liquids or alternate gaseous, plus a variety of optional equipment and systems within the same structural canopy, such as an automatic fire suppression system. All refueling of integral tanks are intended to be done using existing industry practices for the specific fuel types. FlexStation Basic Design Structural Design Electric Power Canopy Options Fuel Tanks & Pipes Fuel Dispensers Fire Resistance Fire Protection Primary NFPA Codes Diesel Gasoline LPG CNG GH2 EV 3 Module Sizes All have integrated dispensing island with structural canopy for fuel tank, standard systems and optional components, and can be connected for individual configurations. Same structural columns with bollard protection and canopy frame with lightning protection. Engineered for high wind loads, vehicle impact, and seismic events. Standard grid connection with emergency power options (generator & PV) for electric supply & distribution to each system in various panels in the canopy. All components are UL Listed. All have options for UL Listed equipment in canopy or on island for a) backup power generator, b) solar panels & battery, c) vehicle air & fluid units, and d) operating system sensors & monitors Separate structural compartments for fuel tanks are all in the canopy, with fill & EV power withdraw piping routed in column plenums & under island. from grid One UL Listed dispenser/island. Traditional fuel units have multi blend/dual EV charger w hose options & sump. Gaseous fuel units have different pressure/nozzle options. V/A options All modules have UL 1 2 hr fire resistant coatings on structural steel members, Except no gaseous fuel tanks and all fuel pipes. Traditional fuel tanks are UL2085 2hr rated. tank & pipe All have UL Listed a) dry chemical extinguishing system for fueling area, with b) EV module alarm & signal options, and c) hand held extinguishers suitable for each fuel. option NFPA 30A NFPA 30A 30A Ch 12 & 30A Ch 12 & 30A Ch 12 & NFPA 70 NFPA 58 NFPA 52 NFPA 2

140 Appendix A NFPA 30A Gap Analysis Action Items or Questions to Resolve: Scope The 30A Code is not applicable to dispensing facilities for only LPG, LNG, CNG, so need to: a) clarify if only applies to Gas/Diesel vs others noted, or each alternate fuel, such as a combined LPG & CNG facility. If dual Code(s) apply, does 30A take the lead? b) add GH2 to list and NFPA 2 to 2.2 list of referenced publications? UL Publications Add UL87A, UL87B, UL87C, UL142, UL142A, UL2039, UL2583, and others to list if needed to support the Flex-Station and establish applicable Safety requirements for the system components? Also needed for current fueling stations? 3.3 General Definitions Add a new definition to describe the Flex-Station product and concept of factory built modular units for different fuels with elevated tanks that are installed and serviced in a non-traditional way? Aboveground Tanks Add new subsection to ref applicable tank Standards for LPG, CNG & GH2, the different pressures they operate at, allow elevated use and clarify: a) if individual (12k gal) and aggregate (48k gal) and for fleet values, applies to only traditional liquid fuels (gas, kero, diesel) or also alternate gaseous fuels (LPG, CNG, GH2), and b) if the corresponding minimum separation distances of Table for UL2085 tanks includes elevated use, and if other tanks also includes alternate gaseous fuels (LPG, CNG, GH2) Piping Components Do requirements for low melt point materials include valve seats/gaskets, and if so, must they be 2 hr fire rated? Flex Connectors Ref UL2039 as the requirements for all Listed flexible connectors. See separate UL agenda item Tank Vents Does the min 5 vent pipe above the height projection of the canopy apply to the perimeter, components or accessories? & Fuel Dispensers Ref UL87A & UL87B as requirements for all Listed fuel dispensing systems (gas, kero, diesel). See separate UL agenda item Dispenser Island Propose revision to include metal (vs concrete) as a suitable island support for dispensers Emergency Disconnects Can the 2 nd electrical disconnect be located on a standalone post or adjacent island? & Fire Protection Would combination of fire resistance, fire detection and portable/fixed extinguishers meet the highest level of AHJ requirements? 7.6 Heating Appliances Would Flex-Station options (generator, compressor, PV collectors, batteries) be considered heat producing appliances, and would 7.6 apply to the canopy top since not in a building (implied)? & Delivery & Control Are alternate fuels intended to meet NFPA 385 bulk delivery and inventory control requirements, or different ones? & Warning Placards Are other items specific to the Flex-Station needed on warning placards? Ch 8 & 12 - See separate Classified Areas Assessment for Flex Station Modules with Different Fuels for additional gap analysis and questions specific to these chapters.

141 CLASSIFIED AREAS ASSESSMENT for FLEX-STATION MODULES with DIFFERENT FUELS NFPA 30A references NEC 70 for electrical wiring & equipment, and uses the Article 500 System to classify location ratings (Class, Division, Group): Class I = Electrical equipment use in hazardous areas where flammable or explosive vapors may exist; Div 1 = Hazard is present in normal conditions Div 2 = Hazard is present in abnormal conditions Group A = N/A (acetylene) Group B = Processed gasses >=30% H2 (includes GH2) Group C = MESG >0.45 to <=0.75 mm and MIC Ratio >0.4 to <=0.80 mm Group D = MESG >0.75 mm and MIC Ratio >0.80 (includes Gasoline, LPG & CNG) Please ref the (AAIZ) Guide for additional information on Hazardous Locations. With respect to NFPA 30A identification of classified locations & installation requirements for electrical wiring & equipment, there are general references to NFPA 58 (LPG), NFPA 52 (CNG), NFPA 2 (GH2) and NFPA 70, (all fuel types). However specific requirements in Ch 8 for traditional liquid fuels (Class I gasoline & gasoline blends) and Ch 12 for alterative gaseous fuels (LPG, CNG, but not specifically GH2) are applicable if dispensed in a mixed fueling facility. The following summary of these requirements applies to the Flex Station modular design: Par & (for traditional liquid fuels) Class I (Gasoline) and use Table & Fig to determine if a Div 1 or 2 area. Par (for alternate gaseous fuels) Class I (LPG & CNG) and use Table (revised by TIA) to determine if a Div 1 or Div 2 area. Note 1 - Although GH2 is identified as a Class I, Div 1 or Div 2, Group B fuel, it is not specifically covered by NFPA 30A Ch 12. NFPA 2 Ch 10 has better information on GH2 fueling stations. Note 2 - Class II (Diesel) fuels are unclassified locations, except if within a hazardous location of adjacent Class I fuel. However, UL Listed dispensers assume, and are rated for installation next to gasoline dispensers. Potential Problems we see with the Flex Station modular design to locate fuel tanks and electrical equipment in the canopy, which if connected to adjacent canopies with different fuels, as intended. This would not comply with minimum separation distances per Where, the minimum 20 separation distance applies between tanks and/or dispensers of different fuels. However, it may be possible to apply exceptions for sealed enclosures per or exceptions in Table where effectively cut off by walls or partitions, to reduce either: a) Classified locations (hazardous to unclassified), or b) Division ratings (Div 1 to Div 2), or c) Distances related to the above ratings. Therefore, the above questions, and fundamental question of - were the aboveground requirements developed only for at grade tanks, or can they also apply to elevated tanks should be submitted to the NFPA 30A TC for a response.

142 Classified Areas Assessment for Flex Station Modules with Different Fuels per NFPA 30A Table & Table or Others as Noted All Fuels Class I Fuel Fill Pipe & SCD Dispenser Unit Dispenser Sump Underneath Canopy or Enclosure Fuel Tank Vent Outlet Fuel Tank in Canopy Fuel Tank Containment In Canopy Equipment Boxes in/on & under Canopy Gasoline (Gas) Group D 30A T8.3.2 Div all areas in spill container (SCD) & <=18 from SCD enclosure or <=18 H (*) Div all areas within enclosure Div <=20 from <=18 H (*) Div all sump areas under dispenser & within island cavity unless vapor tight Unclassified unless canopy tank dike or containment box has bottom/side openings (?) Div <=5.0 from vent pipe ends/openings Div >5.0 to <10 from vent pipe ends Div 1 in tank & <= 10 from tank perimeter Div > 10 from tank outer surface perimeter Same as Sump if dike or enclosure under tank is sealed, or, Fuel Tank rules apply LPG Group D 30A T Same as dispenser if tanks use similar fill pipe/adapter on canopy column in dispenser area Div all areas within enclosure, Div <=18 from enclosure 4.0 above base Div 2 <=20 from <=18 H (*) No Sumps Used, but same as Gas if sump or island cavity can trap heavy vapors <=20 from dispenser (%) Same a Gas assuming LPG is heavier than air & similar to gas vapor properties (?) No 30A Specs but assume similar to GH2 tank relief valve, except heavy gas sinks. (58&30A may vary) No 30A Specs but assume same as Sump if tank/pipe leaks gas. See Sump & Tank Containment No 30A Specs but Div 2 may apply to dike & containment box if bottom/side are sealed (?) CNG Group D 30A T Same as dispenser if tanks use similar fill pipe/adapter on canopy column in dispenser area Div all areas within enclosure, Div 5.0 from any height No Sumps Used, but see areas Under Canopy & Enclosure for info. Note island could trap light gas leak. Uncertain if areas under enclosure & canopy are Div 1, 2 or unclassified if design prevents trapped vapors (?) No 30A Specs but assume similar to GH2 tank relief valve with light gas rising. (52&30A may vary) No 30A Specs but assume same as Sump if tank/pipe leaks gas. See Under Canopy/Enc & Tank Containment No 30A Specs but Div 2 may apply to dike & containment box if top/side are sealed (?) GH2 Group B NFPA 2 T Same as dispenser if tanks use similar fill pipe/adapter on canopy column in dispenser area Div all areas within enclosure, Div <=5 from enclosure except Div <=15 from compression & ancillary equip in dispenser No Sumps Used, but see areas Under Canopy & Enclosure for info. Note island could trap light gas leak. Uncertain if areas under enclosure & canopy are Div 1, 2 or unclassified if design prevents trapped vapors (?) Div <=5 from relief valve and Div <=15 in 15 deg of valve discharge (?), so point vent upward No Specs in 2 but see vent outlet Div <=15 from compression & ancillary equip if in canopy Containment NA but assume area above tanks/pipes won t trap leaked gas. See T for separations. Optional Electrical Accessories or Systems either a) in adjacent canopy boxes (such as power panels, generators, batteries & wiring), b) on the canopy/cover (such as PV panels & lightning protection) or under the canopy (such as lights & sensors) must be rated for the hazardous location. Note if CNG compressor units are used, they will be separate from the Flex Station. (?) Consideration must be given to different gas/vapor properties that may collect within/under or escape from various dikes or enclosures. ($) It is also unknown at this time if barriers intended to eliminate or reduce hazardous locations are applicable to the canopy box design.

143 (*) = Measured in any direction from grade. Note the hazardous location is measured from the enclosure, and not from the extended dispenser hose nozzle attached from the dispensing unit per Figures. (#) Par Div 1 for LPG dispensers allowed <= 5.0 from other Class I dispenser where a) <=1.0 oz is released upon disconnect and b) fixed liquid level gauge is closed during filling process. (%) Tab Div 1 LPG areas where vapors can collect under dispenser extends <=20 horizontally from dispenser edge where not mechanically ventilated. Div 2 <=20 <=18 H if mechanically ventilated. (?) With respect to different gas/vapor properties, we are unsure if areas under/above enclosures or the canopy are Div 1, Div 2 or unclassified, since design dependent, equipment unknowns and relative distances of components: Gas & LPG (heavier than air) If vapors/gasses that could potentially fill up the canopy containment enclosure and sink over the edge around the fueling area, or, are they dissipated by distance? (Not in 12.5) CNG & GH2 (lighter than air) If vapor/gasses that could potentially escape by design around perimeters of the canopy underside (from dispenser) or canopy cover (from tanks), or, are they dissipated by distance? (Not in 12.4) NFPA 2 T If compression/ancillary equipment is in the canopy, unsure if the Div 2 <=15 distance is mitigated by canopy or other barriers. Also unsure if the tank relief device Div <=5 and Div <=15 within 15 deg of discharge is mitigated by canopy or other barriers. NFPA 2 T See separation distances from different GH2 components & operations when considering the site location. ($) It may be possible to apply exceptions for sealed enclosures per or exceptions in Table where effectively cut off by walls or partitions, to reduce either: a) Classified locations (hazardous to unclassified), or b) Division ratings (Div 1 to Div 2), or c) Distances related to the above ratings. The tank/pipe pressure relief device & design should consider a resulting fire, where the outlet position must point upwards, or otherwise in directions that will prevent a) flame contact on adjacent tanks, equipment, buildings and properties, & b) gas collection or extended hazard zones for different heavier vs lighter than air types.

144