Committee on M E M O R A N D U M TO: FROM: NFPA Technical Committee on Industrial and Medical Gases Patti Mucci, Administrative Assistant DATE: May 6, 2010 SUBJECT: ROC Letter Ballot The ROC letter ballot for is attached. The ballot is for formally voting on whether or not you concur with the committee s actions on the comments. Reasons must accompany all negative and abstention ballots. Please do not vote negatively because of editorial errors. However, please bring such errors to my attention for action. Please complete and return your ballot as soon as possible, but no later than Thursday, May 20, 2010. As noted on the ballot form, please return the ballot to Patti Mucci either via e-mail to pmucci@nfpa.org or via fax to 617-984-7110. You may also mail your ballot to the attention of Patti Mucci at NFPA, 1 Batterymarch Park, Quincy, MA 02169. The return of ballots is required by the Regulations Governing Committee Projects. Attachment: Comments
51A-1 Log #1 Charles B. Henrici, Elk Grove Village Fire Dept. 51A-1, 51A-9 Revised text to read as follows: High hazard contents [shall] include materials defined as "hazardous materials" in [Chapter 3] [NFPA 1], whether stored, used or handled. [,6.3.2.4.1.1] High hazard Level 2 contents [shall] include materials that present a deflagration hazard or a hazard from accelerated burning including, but not limited to, the following: (1) Class I, Class II, or Class III-A flammable or combustible liquids that are used or stored in normally open containers or systems, or in closed containers or systems at gauge pressures of more than 15 psi (103.3 kpa) (2) Combustible dusts stored, used, or generated in a manner creating a severe fire or explosion hazard (3) Flammable gases and flammable cryogenic liquids (4) Class I organic peroxides (5) Class 3 solid or liquid oxidizers that are used or stored in normally open containers or systems, or in closed containers or systems at gauge pressures of more than 15 psi (103.3 kpa) (6) Nondetonable pyrophoric materials (7) Class 3 nondetonable unstable (reactive) materials (8) Class 3 water-reactive materials [, 6.3.2.4.3] High hazard Level 3 contents [shall] include materials that readily support combustion or present a physical hazard including, but not limited to, the following: (1) Level 2 and Level 3 aerosols (2) Class I, Class II, or Class III-A flammable or combustible liquids that are used or stored in normally closed containers or systems at gauge pressures of less than 15 psi (103.4 kpa) (3) Classification 1.4G consumer fireworks (4) Flammable solids, other than dusts classified as high hazard Level 2, stored, used, or generated in a manner creating a high fire hazard (5) Class II and Class III organic peroxides (6) Class 2 solid or liquid oxidizers (7) Class 3 solid or liquid oxidizers that are used or stored in normally closed containers or systems at gauge pressures of less than 15 psi (103.4 kpa). (8) Oxidizing gases and oxidizing cryogenic liquids (9) Class 2 unstable (reactive) materials (10) Class 2 water-reactive materials [, 6.3.2.4.4] High hazard Level 4 contents [shall] include materials that are acute health hazards including, but not limited to, the following: (1) Corrosives (2) Highly toxic materials (3) Toxic materials [, 6.3.2.4.5] The text as proposed was extracted into NFPA 1 from NFPA 5000 so the extract should be from 5000. The modification of the extract from NFPA 5000 as proposed makes this definition harder to read. The form in NFPA 5000 is easier to read. A numbered list is easier for an AHJ to work with. The revised proposal reflects the extraction in the format as shown in NFPA 5000 and puts it in a format that meets the requirements of the Manual of Style for extractions. 3.3.7 High Hazard Contents. High hazard contents include materials defined as hazardous materials in NFPA 400 1, whether stored, used or handled. The Technical Committee updated the parent definition for "High Hazard Contents" to reflect that NFPA 400 is the source document for hazardous material definitions. The remaining sub-definitions are retained as extracts from NFPA 1 because the NFPA 400 corresponding paragraphs are stylistically mandatory text, and not worded properly for definitions. 1
51A-2 Log #2 Charles B. Henrici, Elk Grove Village Fire Dept. 51A-1 Revise text to read as follows: Buildings, and portions thereof, containing quantities of hazardous materials exceeding the maximum allowable quantities of high hazard Level 2 contents permitted in control areas shall and comply complying with applicable regulations for Protection Level 2, as set forth in the Building Code. [, 2006 2009] The change as proposed is written as a requirement which does not meet the requirements of the Manual of Style. The revised text clarifies the wording and recognizes the Building Code adopted by the jurisdiction and is not a true extraction from NFPA 5000. 3.3.12 Protection Level 2. Buildings, and portions thereof, containing quantities of hazardous materials exceeding the maximum allowable quantities of high hazard Level 2 contents permitted in control areas shall comply with applicable regulations for Protection Level 2, as set forth in NFPA 5000. [5000, 2009] 3.3.13 Protection Level 3. Buildings, and portions thereof, containing quantities of hazardous materials exceeding the maximum allowable quantities of high hazard Level 3 contents permitted in control areas shall comply with applicable regulations for Protection Level 3, as set forth in NFPA 5000. [5000, 2009] 3.3.14 Protection Level 4. Buildings, and portions thereof, containing quantities of hazardous materials exceeding the maximum allowable quantities of high hazard Level 4 contents permitted in control areas shall comply with applicable regulations for Protection Level 4, as set forth in NFPA 5000.[5000, 2006 2009] A.3.3.11 Protection Level. NFPA uses the concept of protection levels in a manner that is analogous to Group H occupancies in other model codes. Although NFPA 1 and NFPA 5000 do not have unique occupancy classifications for occupancies containing hazardous materials, Protection Levels 1 to 5 in NFPA codes and standards reflect increased building safety requirements that are applicable to occupancies containing hazardous materials, which generally correlate to the Group H, Division 1 to 5 occupancy classifications in other codes. [5000, 2009] In NFPA model codes and standards, when the quantity of hazardous materials in a control area exceeds the Maximum Allowable Quantity per Control Area (MAQ) Protection Level controls are required. Unlike the approach used by other model codes where the occupancy reverts to Group H, the occupancy of the area remains classified based on its use as determined by the building code and Protection Level controls suitable for the types of materials (high hazard contents) contained are required. Such controls may include a reduction in the allowable heights and areas, degree of fire-resistive construction, exiting and the application of construction, engineering and administrative controls applicable to the materials contained. Refer to the definitions of High Hazard Contents as found in 3.3.7.1 through 3.3.7.3 and the related annex notes A.3.3.1 an A.3.3.2 for additional information regarding the application of Protection Level based on the hazard classification of materials. 4.1 Portions of plants housing acetylene generation and charging and acetylene cylinder storage operations where Protection Level controls are provided classified as Protection Level 2, 3, or 4 shall be located in accordance with the requirements of the building code. 4.3.3 Exits shall be provided for areas with Protection Level controls in accordance with the building code, as required Protection Level 2, 3, or 4 occupancies as applicable. 5.2.7.1 Rooms or areas where the quantity of calcium carbide exceeds the maximum allowable quantity per control area shall be provided with Protection Level 3 and 4 controls. 11.2.1 Buildings or portions thereof required to comply with Protection Levels 1 through 4 controls shall be protected by an approved automatic sprinkler system complying with NFPA 13, Standard for the Installation of Sprinkler Systems. The Technical Committee deleted the definitions for protection levels 2-4 because they do not meet the requirements of the NFPA Manual of Style. The TC added clarification to the annex material for the generic definition of "Protection Level" to instruct the user as to the application of protection level controls. In addition, the TC modified relevant paragraphs to reflect the more general usage of "protection level controls" to make it universally applicable to any model code set. 2
51A-3 Log #3 Charles B. Henrici, Elk Grove Village Fire Dept. 51A-1 Revise text to read as follows: Buildings, and portions thereof; containing quantities of hazardous materials exceeding the maximum allowable quantities of high hazard Level 3 contents permitted in control areas shall and comply complying with applicable regulations for Protection Level 3, as set forth in the Building Code. [ 2006 2009] The change as proposed is written as a requirement which does not meet the requirements of the Manual of Style. The revised text clarifies the wording and recognizes the Building Code adopted by the jurisdiction. See Committee Action on 51A-2 (Log #2). 51A-4 Log #4 Charles B. Henrici, Elk Grove Village Fire Dept. 51A-1 Revise text to read as follows: Buildings, and portions thereof, containing quantities of hazardous materials exceeding the maximum allowable quantities of high hazard Level 4 contents permitted in control areas shall and comply complying with applicable regulations for Protection Level 4, as set forth in the Building Code. [ 2006 2009] The change as proposed is written as a requirement which does not meet the requirements of the Manual of Style. The revised text clarifies the wording and recognizes the Building Code adopted by the jurisdiction. See Committee Action on 51A-2 (Log #2). 3
51A-5 Log #6 Bob Eugene, Underwriters Laboratories Inc. 51A-16 Revise text as follows: Rooms in which acetylene operations are conducted shall be provided with a listed or approved flammable gas detection system. A listing standard for gas detection and sensing systems is published by Underwriter s Laboratories as ANSI/UL 2075. Gas detection systems shall not be required for structures equipped with fixed natural ventilation and constructed as weather protection in accordance with the requirements of NFPA 55,. The flammable gas detection system shall be listed or approved for use with acetylene and any other flammable gases used in the room. Add the following informational reference to Annex B under a new section for Underwriter s Laboratories (UL): ANSI/UL 2075, UL Standard for Safety Gas and Vapor Detectors and Sensors, 2004, Revised 2007. Add the following referenced publication to Section 2.2: NFPA 55,, 2009. Add ANSI approval designation to ANSI/UL 2075. Include a reference to the most recent revisions to the UL standards. A listing standard for gas detection and sensing systems is published by Underwriter s Laboratories as ANSI/UL 2075. B.1.2.2 UL Publications. Underwriters Laboratories Inc., 333 Pfingston Rd., Northbrook, IL 60062-2096 ANSI/UL 2075, Standard for Safety Gas and Vapor Detectors and Sensors, 2004, Revised 2007. NFPA 55,, 2010 2009. The TC accepts the updated reference for UL 2075 as an ANSI-accredited document, but editorially corrects the edition date for NFPA 55 as reflected in the Report on Proposals Log 51A-1. 4
51A-6 Log #7 Bob Eugene, Underwriters Laboratories Inc. 51A-17 Revise text as follows: 4.6.1.1* Electric heaters listed in accordance with ANSI/UL 823 for installation in hazardous locations shall be allowed to be used in operating areas regulated by 4.7.2 when installed and used in accordance with the manufacturer s instructions and the listing. A.4.6.1.1 The autoignition temperature for acetylene as listed in NFPA 497 is 305 C (581 F). Acetylene is the only material listed as being in Group A at the present time. Electrical equipment is required to comply with the requirements of NFPA 70, based on Class and Group designations determined by conditions as well as the material present. 4.6.2 Boilers, water heaters and other heating equipment containing one or more of the following potential hazards employing flames, or capable of creating sparks shall be located in a separate building or room not directly communicating with areas devoted to acetylene operations. (1) Open flames. (2) Release of sparks or spark generation during operation. (3) Exposed surface temperatures exceeding the lowest auto-ignition temperature of any of the materials present. Also add ANSI/UL 823 Standard for Electric Heaters for use in Hazardous (classified) Locations to Appendix B Section 2.3.xx. Introduces ANSI/UL 823 into the body of the standard rather than just in an informational annex. ANSI/UL 823 is a consensus based standard that covers explosion-proof, dust-ignition-proof and dust-tight portable and fixed electric heaters for installation and use in hazardous (classified) locations, Class I, Divisions 1 and 2, Groups A, B, C, and D; Class II, Division 1, Groups E, F, and G; Class II, Division 2, Groups F and G; and Class III, Divisions 1 and 2, in accordance with the National Electrical Code, NFPA 70. A.4.6.1.1 The autoignition temperature for acetylene as listed in NFPA 497 is 305 C (581 F). Acetylene is the only material listed as being in Group A at the present time. Electrical equipment is required to comply with the requirements of NFPA 70, based on Class and Group designations determined by conditions as well as the material present. ANSI/UL 823 is a consensus based standard that covers explosion-proof, dust-ignition-proof and dust-tight portable and fixed electric heaters for installation and use in hazardous (classified) locations, Class I, Divisions 1 and 2, Groups A, B, C, and D; Class II, Division 1, Groups E, F, and G; Class II, Division 2, Groups F and G; and Class III, Divisions 1 and 2, in accordance with the National Electrical Code, NFPA 70. B.1.2.2 UL Publications. Underwriters Laboratories Inc., 333 Pfingston Rd., Northbrook, IL 60062-2096 ANSI/UL 823 Standard for Electric Heaters for use in Hazardous (classified) Locations, 2006, Revised 2007 ANSI/UL 2075, Standard for Safety Gas and Vapor Detectors and Sensors, 2004, Revised 2007 The TC did not add the ANSI/UL 823 reference to the mandatory text because the TC doesn't want to restrict the use of other standards in existence or that may be developed to provide safety requirements for the construction and installation of electric heaters for hazardous locations. However, the TC added information on ANSI/UL 823 to the annex material to provide guidance for users of the standard. 5
51A-7 Log #5 Charles B. Henrici, Elk Grove Village Fire Dept. 51A-26 Revise text to read as follows: Forp Pipe of nominal size 6 in. (152 mm) and less ( 152 mm), all pipe shall be a minimum of Schedule 40, and all pipe fittings shall have a minimum rating of a gauge pressure of 125 psi (861 kpa). The way the section is proposed it creates a conflict. The section is requiring 6 in. and less pipes to be Schedule 40 and not all pipes. Forp Pipe of nominal size 6 in. (152 mm) and less ( 152 mm), all pipe shall be a minimum of Schedule 40, and all pipe fittings shall have a minimum rating of a gauge pressure of 125 psi (861 kpa). The TC accepts the comment with a minor editorial change to remove the "less than or equal to" metric conversion as it is redundant. 6
51A-8 Log #9 Larry L. Fluer, Fluer, Inc. / Rep. Compressed Gas Association 51A-31 Revise text as follows: In addition to the general requirements of MATS filling and discharge stations located at acetylene charging plants shall be in accordance with 10.6. The mobile acetylene trailer, including fill connections, shall be located a minimum distance of: (1) 25 ft (7.6 m) from property lines. (2) 50 feet (15.2 m) from buildings of combustible construction. (3) 15 ft (4.6 m) from buildings of noncombustible construction not associated with the filling or discharging of the mobile acetylene trailer. (4) 15 ft (7.6 m) horizontal distance from the vertical plane below the nearest overhead electrical utility power lines. (5) 15 ft (4.6 m) horizontal distance from the vertical plane below overhead piping containing flammable liquids, flammable gases or oxidizing materials. (6) 50 ft (15.2 m) from air intakes. The minimum required distances, except for air intake openings, shall not apply when fire barriers without openings or penetrations having a minimum fire resistance rating of 2 hours interrupt the line of sight between the discharge and the exposure. Provisions shall be made for a cylinder cooling water spray system and water run-off where needed for removing the heat of solution of acetylene, as determined by ambient temperature and cylinder charging rates Protection from vehicular damage shall be provided in accordance with NFPA 55. Flexible transfer hoses used for charging of MATS shall have a minimum burst pressure of 10,000 psig (69,000 kpa). The charging site shall be posted with a sign with the following or equivalent wording: ACETYLENE FLAMMABLE GAS NO SMOKING NO OPEN FLAMES Electrical equipment shall be in accordance with NFPA 70 An electrical grounding system for the acetylene piping shall be provided in accordance with the NFPA 70 The trailer chassis shall be connected to the grounding system before connections are made to the piping system. The MATS discharge station shall be in accordance with 10.6.1 except that 10.6.1.2 shall not apply. Acetylene meters, where used, shall be designed for acetylene service and shall operate at a pressure not to exceed 15 psig (103 kpa). Flexible transfer hosed used for withdrawal of acetylene shall be pressure rated as follows: (1) For pressures greater than 15 psig hoses shall have a minimum burst pressure of 10,000 psig (69,000 kpa). (2) For pressures of 15 psig (103 kpa) or less hoses shall be rated for a minimum working pressure of 125 psig (860 kpa) and a minimum burst pressure of 500 psig (3450 kpa). Fire protection systems shall be provided in accordance with 11.2.1.3 At mobile acetylene charging plants a deluge fire sprinkler system having a minimum water density of 0.3 gpm (1.14 L/min) per square foot for an area of 2500 ft 2 (232 m 2 ) or less shall be installed in the areas occupied by trailers in charging or discharging stations. The minimum water density requirement decreases linearly to 0.2 gpm (0.76 L/min) per square foot for areas greater that 5000 ft 2 (464.52 m2). The fire protection system shall be able to be activated automatically and also by manual actuator. The fire protection control system shall be located so that it is visible and accessible in an emergency. Existing charging and discharging MATS shall be protected by a deluge fire sprinkler system in accordance with 11.2.1.3 by January 1, 2015. Where the public water is not sufficient to meet the requirements for water flow or capacity, the supply shall be subject to approval by the AHJ. At least one portable fire extinguisher shall be mounted on each trailer and a second extinguisher on the tractor when attached. The minimum size of the fire extinguisher for the mobile acetylene trailers shall have a UL rating of 20 B:C. The minimum size of the fire extinguisher for the tractor shall be as required by the 7
Item 51A-31 was a submittal by the Compressed Gas Association highlighting the need to include fire protection requirements for Mobile Acetylene Trailer Systems (MATS) for MATS charging facilities attendant to acetylene charging plants. Existing Section 10.6 was reserved to address the subject of MATS generally. Recent fires involving MATS at user sites during unloading operations were the subject of a report by the National Transportation Safety Board (NTSB) that was considered by the technical committee during the ROP phase. Since that time CGA has modified CGA G-1.6 describing safeguards to be employed in both charging and discharging this equipment. The recommendations include requirements for fire protection systems for indoor or outdoor trailer stations which were a subject of interest to the committee during the ROP meeting. In addition, a minimum set of safeguards are recommended for the transfer stations whenever filling or discharge occurs. Section 10.6. The approach is consistent with that used by Sections 6.1 and 6.2 of CGA G-1.6. Section 11.2.1.3. The fire protection requirements specified in Section 11.2.1.3 for deluge systems have been limited to mobile acetylene trailer charging plants. Other than the limiting statement which has been added to fit within the scope of, the provisions have been extracted verbatim from CGA G-1.6. Section 11.2.1.3.1 The concept has been extracted from G-1.6 with minor modification to address the NFPA Manual of Style. Section 11.2.1.3.2. Requires the retroactive application of Section 11.2.1.3 requiring that all acetylene charging plants which utilize mobile acetylene charging and discharging stations be equipped with fire protection systems by January 1, 2015. The five year limit is coordinated with CGA G-1.6. Section 11.2.1.3.3. The concept is in concert with CGA G-1.6. Section 11.2.1.3.3. The concept is in concert with CGA G-1.6 The mobile acetylene trailer, including fill connections, shall be located a minimum distance of: (1) 25 ft (7.6 m) from property lines. (2) 50 feet (15.2 m) from buildings of combustible construction. (3) 15 ft (4.6 m) from buildings of noncombustible construction not associated with the filling or discharging of the mobile acetylene trailer. (4) 15 ft (7.6 m) horizontal distance from the vertical plane below the nearest overhead electrical utility power lines. (5) 15 ft (4.6 m) horizontal distance from the vertical plane below overhead piping containing flammable liquids, flammable gases or oxidizing materials. (6) 50 ft (15.2 m) from air intakes. The minimum required distances, except for air intake openings, shall not apply when fire barriers without openings or penetrations having a minimum fire resistance rating of 2 hours interrupt the line of sight between the discharge and the exposure. Where process needs require removing the heat of solution of acetylene as determined by ambient temperature and cylinder charging rates, provisions shall be made for a cylinder cooling process water spray system and water run-off. Protection from vehicular damage shall be provided in accordance with NFPA 55. Flexible transfer hoses used for charging of MATS shall have a minimum burst pressure of 10,000 psig (69,000 kpa). The charging site shall be posted with a sign with the following or equivalent wording: ACETYLENE FLAMMABLE GAS NO SMOKING NO OPEN FLAMES Electrical equipment shall be in accordance with NFPA 70 An electrical grounding system for the acetylene piping shall be provided in accordance with the NFPA 70 The trailer chassis shall be connected to the grounding system before connections are made to the piping system. The MATS discharge station shall be in accordance with 10.6.1 except that 10.6.1.2 shall not apply. Acetylene meters, where used, shall be designed for acetylene service and shall operate at a pressure not to exceed 15 psig (103 kpa). Flexible transfer hosesd used for withdrawal of acetylene shall be pressure rated as follows: (1)* For pressures greater than 15 psig hoses shall have a minimum burst pressure of 10,000 psig (69,000 kpa). (2) For pressures of 15 psig (103 kpa) or less hoses shall be rated for a minimum working pressure of 125 psig (860 8
kpa) and a minimum burst pressure of 500 psig (3450 kpa). A.10.6.2.3(1) A 10,000 psi burst pressure for charging leads integral to Section 10.6.2.3 has been used to withstand a decomposition reaction of acetylene in the charging lead. The TC notes that the separation distances in section 10.6.1.1 are drawn from other sources as shown in the table. **Insert Include_51A (Log #9) Committee Statement.doc Here ** The TC added the annex note to 10.6.2.3(1) to explain the higher burst pressure requirement for acetylene at pressures greater than 15 psig. The TC chose to address the fire protection requirements in a separate committee comment instead of as part of this comment. 51A-9 Log #CC2 Technical Committee on Industrial and Medical Gases, 51A-31 Add new text as follows: Fire protection systems shall be provided in accordance with 11.2.1.3 At mobile acetylene charging plants a fire sprinkler system in accordance with NFPA 13, extra hazard group 1 shall be installed in the areas occupied by trailers in charging or discharging stations. Where the public water is not sufficient to meet the requirements for water flow or capacity, the supply shall be subject to approval by the AHJ. At least one portable fire extinguisher rated in accordance with NFPA 10,, at not less than 20 B:C shall be mounted on each trailer. Mobile Acetylene Trailer Systems fire protection requirements apply to charging or discharging stations located indoors or outdoors. The TC added fire protection requirements for Mobile Acetylene Trailer Systems to address Item 51A-31 submitted by the Compressed Gas Association highlighting the need to include fire protection requirements for Mobile Acetylene Trailer Systems (MATS) for MATS charging facilities attendant to acetylene charging plants. Recent fires involving MATS at user sites during unloading operations were the subject of a report by the National Transportation Safety Board (NTSB) that was considered by the technical committee during the ROP phase. Since that time CGA has modified CGA G-1.6 describing safeguards to be employed in both charging and discharging this equipment. The TC considered the existing fire protection requirements for indoor locations, section 6.9.2.2 of NFPA 55-2010 and existing section 11.2.1.2 of the 2006 edition of, and concluded that the hazard related to MATS is comparable to indoor cylinder charging locations. 9
Distance Rationale (1) 25 ft from property lines CGA G-1.6 Section 6.1 has been used as the basis to establish the minimum distance from MATS to property lines. In addition, the following elements of NFPA 55 have been considered. NFPA 55 Section 7.6.2.5 requires a separation between non-bulk systems of flammable gases in quantities from 84,501 cf to 200,000 cubic feet to be located a minimum distance of 25 ft from lot lines, public streets and public ways. It is recognized that an MATS system is other than non-bulk, however, comparability has been drawn with the use of ignition sources as used in Section 7.6.3.2 as the minimum distance prohibiting smoking or the use of open flames. Smoking and the use of ignition sources could occur at the property line, therefore the distance to property lines has been established accordingly. The distance from ignition sources has also been accepted into 8.1.1.1.1 as a point where separation from drain line discharge is allowed (See ROP Item 51A-22). (2) 50 ft from buildings of CGA G-1.6 Section 6.1 has been used as the basis for combustible construction establishing the minimum distance of 50 feet from buildings (3) 15 ft from buildings of noncombustible construction not associated with the filling or discharge of the mobile acetylene trailer (4) 15 ft horizontal distance from the vertical plane below the nearest overhead electrical utility power lines (5) 15 ft horizontal distance from the vertical plane below of combustible construction. CGA G-1.6 Section 6.1 has been used as the basis for establishing the minimum distance of 15 feet from buildings of non-combustible construction. In addition, the following elements of NFPA 55 have been considered. NFPA 55 Table 10.3.2.2.1(a) row (3) >15 to <250 psi as triggered by 55:7.6.2.2 has been considered in the establishment of the separation distance from noncombustible construction. Footnote e of the table establishes the parameters for the distance involved. The distance of 15 feet was felt to be a conservative distance given the fact that the tabular value is based on pipe diameters of 2.067 inches ID. CGA G-1.6 section 6.1 has been used as the basis to recognize the need for separation between exposed overhead or nearby electric power distribution lines. NFPA 55 Table 10.3.2.2.1(a) row (8) >15 to <250 psi as triggered by 55:7.6.2.2 has also been considered in the establishment of the horizontal offset from overhead utilities. The distance has been established for hydrogen by the use of the greater of combustible heat flux or the visible flame length as indicated in footnote d to the table. The prescriptive distance of 15 feet was felt to be a conservative distance given the fact that the tabular value is based on pipe diameters of 2.067 inches ID. CGA G-1.6 Section 6.1 has been used as the basis to establish the need for a horizontal separation distance from exposed 51A_L9_Committee Statement F2010 ROC 1
overhead piping containing flammable liquids, flammable gases or oxidizing materials flammable liquid lines, flammable gas lines, or lines carrying oxidizing materials. NFPA 55 Table 10.3.2.2.1(a) row (8) >15 to <250 psi as triggered by 55:7.6.2.2 has been considered in the establishment of the horizontal offset for piping containing the fluids of concern. The distance has been established for hydrogen by the use of the greater of combustible heat flux or the visible flame length as indicated in footnote d to the table. The distance of 15 feet was felt to be a conservative distance given the fact that the tabular value is based on pipe diameters of 2.067 inches ID. 50 ft from air intakes NFPA 55 Section 7.6.2.4 has been used to determine the distance from air intakes. Comparable provisions have been adopted into Section 8.1.1.1.1 for locating the point of discharge from drain lines from high pressure acetylene systems, oil separators, condensate traps, and driers. 51A_L9_Committee Statement F2010 ROC 2
51A-10 Log #CC1 Technical Committee on Industrial and Medical Gases, 51A-9 Revise text to read as follows: A.3.3.5.17.1 High Hazard Contents, Level 2. When acetylene is produced in a gaseous undissolved, or unstabilized state, it is classified as a non-liquefied flammable, unstable reactive Class 3 (non-detonable) gas in accordance with the requirements of NFPA 704, Standard System for the Identification of the Hazards of Materials for Emergency Response. 3.3.7.2* A.3.3.5.2 High Hazard Contents, Level 3. Acetylene is stabilized when it is packaged for shipment or storage by dissolving the gas in a solvent authorized by the Department of Transportation and absorbing the resultant solution in a porous filler material that fills the inside of the acetylene cylinder. Stabilized acetylene is classified as a non-liquefied flammable gas and a Class 2 unstable reactive gas. In either case acetylene is a flammable gas. In the unstabilized state the classification is as a flammable, unstable reactive Class 3 (non-detonable) gas. In the stabilized state the classification is as a flammable, unstable reactive Class 2 gas. Users should be aware that once the gas has been removed from the container it is no longer in the stabilized state and each use should be evaluated. The most common use of acetylene is as a fuel gas where it is consumed immediately after being discharged from the cylinder. In cases where the gas is piped to remote use points where it may be utilized in process operations gas pressure at the point of use as well as the quantity to be employed should be considered. The annex note as it is configured is misleading in that it implies that stabilized acetylene in quantities exceeding MAQ could be required to be in accordance with Protection Level 3 requirements. While this level of hazard classification is accurate with respect to the Unstable Reactive Class 2 nature of the material, the classification of flammable gas represents the greater potential hazard. As a result the appropriate Protection Level applied would be Protection Level 2. Deletion of the annex note reference and integrating the text from A.3.3.7.2 into the text for A.3.3.7.1 solves the problem. An additional paragraph has been added to alert the user to the fact that classification in the stabilized state may not be consistent with the classification at the point of use. 51A-11 Log #10 Larry L. Fluer, Fluer, Inc. / Rep. Compressed Gas Association 51A-23 Insert a new annex note to A.7.4 as follows: A.7.4 Refer to Figure A.7.4 for a typical drain arrangement. Figure A.7.4 ***Insert Figure A.7.4 here*** The enclosed figure is submitted to illustrate the typical drain connection that is the subject of Section 7.4. Section 7.4 was relocated from Chapter 8 during the ROP. A separate public comment has been issued to include a figure in the Annex for the drain noted in 8.1.1.1.2. The addition of a graphic figure provides the user with a picture that portrays the intent of the provisions as described by Section 7.4. A.7.4 Refer to Figure A.7.4 for an example of a drain arrangement. (accept diagram as submitted) The TC modified the wording of the annex item to be consistent with 51A-13 (Log #12). 10
51A-12 Log #11 Larry L. Fluer, Fluer, Inc. / Rep. Compressed Gas Association 51A-23 Insert an new annex note to 8.1.1.1.2 as follows: A.8.1.1.1.2 Refer to Figure A.8.1.1.1.2 for a typical valve arrangement. Figure A.8.1.1.1.2 ***Insert Figure A.8.1.1.1.2 here*** The enclosed figure is submitted to illustrate the arrangement of a drain line under the requirements of 8.1.1.1.2. Although this paragraph was not the subject of a proposed change the relocation of Section 8.1.1.2 to Section 7.4 under ROP 51A-23 called attention to section 8.1.1.1.2. A separate public comment has been issued to provide a figure in the Annex for Section 7.4 as well. In this way both cases will be illustrated thereby providing the users of the document with a graphical representation of the arrangement prescribed by the Standard. A.8.1.1.1.2 Refer to Figure A.8.1.1.1.2 for an example of a valve arrangement. (accept diagram as submitted) The TC modified the wording of the annex item to be consistent with 51A-13 (Log #12). 51A-13 Log #12 Larry L. Fluer, Fluer, Inc. / Rep. Compressed Gas Association 51A-35 Insert a new annex note to A.8.2.5 as follows: A.8.2.5 Refer to Figure A.8.2.5 for an example of pressure relief vent piping. Figure A.8.2.5 ***Insert Figure A.8.2.5 here*** The enclosed figure is submitted in response to the request from the technical committee. The figure illustrates the piping and vent system required. 11
51A-14 Log #13 Larry L. Fluer, Fluer, Inc. / Rep. Compressed Gas Association 51A-36 Add an asterisk to 10.1 General, and insert the following in response to ROP 51A-36 (Log #CP10): A.10.1 Refer to Figure A.10.1 for a graphic representation of the various requirements found within Section 10.1 Figure A.10.1 ***Insert Figure A.10.1 here*** The enclosed figure is submitted in response to the request from the technical committee. The figure illustrates the piping and vent system required along with other components that have been identified in Section 10.1. A.10.1 Refer to Figure A.10.1 for an example of a system meeting the requirements found within Section 10.1. ****Insert (diagram with addition of "Drain Valve" label shown on Modified) Here**** The TC modified the language of the annex item to be consistent with 51A-13 (Log #12) and added a label for the drain valve on the diagram. 51A-15 Log #14 Larry L. Fluer, Fluer, Inc. / Rep. Compressed Gas Association 51A-1, 51A-37 1. In Annex B.1.2.1 revise the reference to CGA G-1.6 from 2008 to 2010. CGA-1.6, 2008, 2010. 2. In Annex B.2 revise the reference to CGA G-1 from 2003 to 2008. CGA G-1,, 2003 2008. The 2010 Edition is the current edition of CGA G-1.6. The 2008 Edition is the current edition of CGA G-1. 1. In Annex B.1.2.1 revise the reference to CGA G-1.6 from 2008 to 2010. CGA-1.6, 2008. 2. In Annex B.2 revise the reference to CGA G-1 from 2003 to 2008. CGA G-1,, 2003 2009. The TC updated the reference to CGA G-1,noting that the current edition date is 2009. The TC rejected the update to CGA-G1.6 because the standard has not been published. 12
51A-16 Log #8 Bob Eugene, Underwriters Laboratories Inc. 51A-1 Revise text as follows: Underwriters Laboratories Inc., 333 Pfingston Rd., Northbrook, IL 60062-2096 ANSI/UL 2075, Standard for Safety Gas and Vapor Detectors and Sensors, 2004, Revised 2007. U.S. Government Publications. U.S. Government Printing Office, Washington, DC 20402. Title 29, Code of Federal Regulations, Part 1910.38, Emergency Action Plans. Title 29, Code of Federal Regulations, Part 1910.165, Employee Alarm Systems. 2.3.xx Underwriters Laboratories Inc., 333 Pfingston Rd., Northbrook, IL 60062-2096 ANSI/UL 823, Standard for Electric Heaters for use in Hazardous (classified) Locations, 2006, Revised 2007. Separate the U.S. Government Publications from the UL publications. Add ANSI approval designation to UL standards as applicable. Include a reference to the most recent revisions to the UL standards. Move reference to ANSI/UL to 2.3.xx subject to the Comment on 51A-17 being accepted. The TC has already addressed the submitter's correction to the UL 2075 citation in 51A-5 (Log #6). The TC rejected the addition of ANSI/UL 823 to the mandatory text in 51A-6 (Log #7), but has added it to Annex B in accordance with action on 51A-6 (Log #7). Correction to the CGA revision date for G1.8 was made in the ROP, proposal 51A-1. 13