If you plan to attend the NFPA 30 Second Draft meeting remotely, please use the following:

Dear Committee, If you plan to attend the NFPA 30 Second Draft meeting remotely, please use the following: Audio NOTE: For audio you MUST dial in on your phone. I will not be enabling the use of computer microphones, as this often causes feedback problems. Conference Number: US (Toll Free): 1-877-860-3058 Participant Code: 556009 URL to additional access numbers: https://www.mymeetingroom.com/cnums.asp?bwebid=8369444&ppc=556009&num=1-719-867-1571 Visual To join the meeting: http://nfpa.adobeconnect.com/jshapiro/ ---------------- If you have never attended an Adobe Connect meeting before: Test your connection: http://nfpa.adobeconnect.com/common/help/en/support/meeting_test.htm Get a quick overview: http://www.adobe.com/go/connectpro_overview Adobe, the Adobe logo and Adobe Connect are either registered trademarks or trademarks of Adobe Systems Incorporated in the United States and/or other countries. Best regards, Janna Shapiro Associate Engineer National Fire Protection Association jshapiro@nfpa.org Office: (617)-984-7136 Cell: (617)-990-2827

FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE COMMITTEE MEMORANDUM TO: FROM: NFPA 30 Technical Committee on Tank Storage and Piping Systems R. P. Benedetti DATE: June 9, 2016 SUBJECT: Agenda for NFPA 30 Second Draft Meeting Thursday June 23, 2016 8:00 AM to 5:00 PM Ladies and Gentlemen: Attached is the Agenda for the NFPA 30, Flammable and Combustible Liquids Code, Second Draft meeting of the NFPA 30 Technical Committee on Tank Storage and Piping Systems, to be held 8:00 AM to 5:00 PM, Thursday, June 23, 2016, at the Marriott Hotel, Charleston SC. This Agenda will also be posted to the NFPA 30 Document Information Page at http://www.nfpa.org/30 If you have additional items for the Agenda, please bring them with you to the meeting. P.S. The last page of the Agenda is a summary of the motions and actions that can be taken on Public Comments at the Second Draft Meeting. rpb/ cc FLCC Meeting Folder FLCTAN/NM FLCTAN.2016-06 Agenda.doc

FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE COMMITTEE AGENDA NFPA 30 Second Draft Meeting NFPA 30 Technical Committee on Tank Storage and Piping Systems Marriott Hotel, Charleston SC Thursday, June 23, 2016, 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. (September, 2015, Austin TX) [Attachment A2] 4. Report of Committee Chair. 5. Report of Staff Liaison. Staff Presentation Technical Committee Membership Status. [Attachment A3] Document Revision Schedule for Annual 2014 Cycle. [Attachment A4] 6. Member Reports on Current Issues. [As Necessary] 7. Review and Act on Public Comments to the First Draft Report for the 2018 edition of NFPA 30. Encl.: Public Comments - Chapters 21 27 & Annexes B & C [Attachment A5] Additional Task Group Comments [Attachment A5a] First Revisions & Committee Inputs [Attachment A6] 8. Global Comment: Definitions of Container and Intermediate Bulk Container. Deletion of term portable tank in certain chapters. [Attachment A7] 9. Planning for Next Edition of NFPA 30: Annual 2020 Revision Cycle / NFPA 30-2021. [Public Input Closing Date is June 27, 2018] 10. Old Business. [NONE] 11. New Business. [NONE] 12. Schedule Next Meeting(s). 13. Adjournment. FLCTAN.2016-06 Agenda.doc

Address List No Phone Tank Storage and Piping Systems Flammable and Combustible Liquids Stephen W. Haines Chair Haines Fire & Risk Consulting Corp. 1 Linda Lane, Suite B Southampton, NJ 08088 Alternate: Anthony M. Ordile SE 08/09/2012 Steven P. Allwein Principal Morrison Brothers Company 255 Hemingway Lane Severna Park, MD 21146-2142 04/27/2016 Robert P. Benedetti M 7/16/2003 John H. Bagnall Principal Burns & McDonnell Engineering Company 9400 Ward Parkway PO Box 419173 Kansas City, MO 64141-6173 SE 1/15/2004 Tim D. Blackford Principal Chevron Energy Technology Company 1200 Smith Street, Room 31050 Houston, TX 77002 American Petroleum Institute Alternate: Richard S. Kraus U 3/1/2011 John V. Cignatta Principal Datanet Engineering, Inc. 11416 Reisterstown Road Owings Mills, MD 21117 SE 8/2/2010 Sullivan D. Curran Principal Fiberglass Tank & Pipe Institute 14323 Heatherfield Houston, TX 77079-7407 M 1/1/1994 Charles A. Davis Principal AECOM/URS Corporation 7650 West Courtney Campbell Causeway Tampa, FL 33607-1462 Alternate: Michael D. Butler SE 10/1/1996 Claire V. De Taeye Principal Travelers Insurance Company 75 Town Centre Drive Rochester, NY 14623 Alternate: Timothy S. Murphy I 3/1/2011 John J. Foley Principal JENSEN HUGHES 3500 Piedmont Road, Suite 750 Atlanta, GA 30305-1559 Alternate: Alwin A Kelly SE 1/1/1996 Wayne B. Geyer Principal Steel Tank Institute 944 Donata Court Lake Zurich, IL 60047-5025 Alternate: Jeffrey M. Shapiro M 1/1/1986 Dwight H. Havens Principal Bechtel Marine Propulsion Corporation 20 Bellflower Road Malta, NY 12020-4431 U 7/24/1997 David C. Kirby Principal Baker Engineering & Risk Consultants, Inc. 1560 Clearview Heights Charleston, WV 25312-5948 Alternate: Duane L. Rehmeyer SE 1/1/1991 Gregory D. Kirby Principal Cytec Solvay Group 1 Heilman Avenue Willow Island, WV 26134 U 1/17/1997 Thomas S. Lentz Principal Aon Risk Services, Inc. 8940 Benoy Court Lakewood, IL 60014-6809 I 3/2/2010 1

Address List No Phone Tank Storage and Piping Systems Flammable and Combustible Liquids Philip Myers Principal Pemy Consulting LLC 122 Starlyn Drive Pleasant Hill, CA 94523 SE 04/08/2015 David P. Nugent Principal Global Risk Consultants 2037 Clover Road Northbrook, IL 60062-6422 04/27/2016 Robert P. Benedetti SE 03/21/2006 Marcia Jo Poxson Principal Michigan Bureau of Fire Service PO Box 30033 Lansing, MI 48909-7926 Alternate: R. Jeff Tanner E 10/29/2012 Niall Ramsden Principal Resource Protection International Walker House George Street Aylesbury, Bucks, HP20 2HU United Kingdom SE 10/29/2012 Robert N. Renkes Principal Petroleum Equipment Institute 6514 East 69th Street Tulsa, OK 74133 Alternate: Robert H. Young M 1/1/1984 John W. Richmond, Sr. Principal Eastman Chemical Company PO Box 511 (B-54) Kingsport, TN 37662 U 4/14/2005 Roland A. Riegel Principal UL LLC 1285 Walt Whitman Road Melville, NY 11747-3085 Alternate: Alfredo M. Ramirez RT 4/15/2004 James R. Rocco Principal Sage Risk Solutions, LLC 360 Heritage Road Aurora, OH 44202 Petroleum Marketers Association of America Alternate: Charles R. Plummer U 3/21/2006 Tim G. Schroeder Principal Husky Corporation 2325 Husky Way Pacific, MO 63069 M 10/18/2011 Clark D. Shepard Principal ExxonMobil Corporation Research & Engineering 3225 Gallows Road, Room 3A2111 Fairfax, VA 22037 Alternate: David W. Owen U 1/12/2000 David B. Wechsler Principal Consultant 27706 Dalton Bluff Court Katy, TX 77494-2729 American Chemistry Council U 10/27/2009 Peter J. Willse Principal Global Asset Protection Services 100 Constitution Plaza, 12th Floor Hartford, CT 06103 Alternate: Luis F. Arango I 3/21/2006 John P. Woycheese U 08/11/2014 Principal Saudi Aramco Engineer I 712 Nasiriyah Street P.O. Box 13933 Eastern Province, Dhahran, 31311 Saudi Arabia Luis F. Arango Alternate Global Asset Protection Services 21707 Shallow Glen Lane Katy, TX 77450-5489 Principal: Peter J. Willse I 7/16/2003 2

Address List No Phone Tank Storage and Piping Systems Flammable and Combustible Liquids Michael D. Butler Alternate AECOM/URS Corporation 7650 West Courtney Campbell Causeway Tampa, FL 33607-1462 Principal: Charles A. Davis SE 08/11/2014 Alwin A Kelly Alternate JENSEN HUGHES 3610 Commerce Dr Ste 817 Baltimore, MD 21227 Principal: John J. Foley 04/27/2016 Robert P. Benedetti SE 08/11/2014 Richard S. Kraus Alternate API/Petroleum Safety Consultants 210 East Fairfax Street, Apt. 600 Falls Church, VA 22046-2909 American Petroleum Institute Principal: Tim D. Blackford U 4/5/2001 Timothy S. Murphy Alternate Travelers Insurance Company 1000 Windward Concourse Alpharetta, GA 30005-2052 Principal: Claire V. De Taeye I 03/03/2014 Anthony M. Ordile Alternate Haines Fire & Risk Consulting Corporation 1 Linda Lane, Suite B Southampton, NJ 08088 Principal: Stephen W. Haines SE 10/1/1993 David W. Owen Alternate ExxonMobil Corporation Research and Engineering 2800 Decker Drive MOB 541 Baytown, TX 77520 Principal: Clark D. Shepard U 7/12/2001 Charles R. Plummer Alternate PPM Consultants, Inc. 1600 Lamy Lane Monroe, LA 71201-3736 Petroleum Marketers Association of America Principal: James R. Rocco U 4/14/2005 Alfredo M. Ramirez Alternate UL LLC 333 Pfingsten Road Northbrook, IL 60062-2096 Principal: Roland A. Riegel RT 4/15/2004 Duane L. Rehmeyer Alternate Baker Engineering & Risk Consultants, Inc. 709 Highspire Road Glenmore, PA 19343 Principal: David C. Kirby SE 8/2/2010 Jeffrey M. Shapiro Alternate International Code Consultants 8207 Asmara Drive Austin, TX 78750 Steel Tank Institute/Steel Plate Fabricators Association Principal: Wayne B. Geyer M 10/10/1997 R. Jeff Tanner Alternate Michigan Department of Environmental Quality PO Box 30426 Lansing, MI 48909-7926 Principal: Marcia Jo Poxson E 10/29/2012 Robert H. Young Alternate Petroleum Equipment Institute PO Box 2380 Tulsa, OK 74101-2380 Principal: Robert N. Renkes M 12/08/2015 3

Address List No Phone Tank Storage and Piping Systems Flammable and Combustible Liquids Jeffrey J. Wanko Nonvoting Member US Department of Labor Occupational Safety & Health Administration 200 Constitution Ave. NW, Room N3119 Washington, DC 20210 E 03/05/2012 David L. Blomquist Member Emeritus 114 Golden Ridge Road Alamo, CA 94507-2869 04/27/2016 Robert P. Benedetti 10/1/1993 Orville M. Slye, Jr. Member Emeritus Loss Control Associates, Inc. 1382 Newtown-Yardley Road Apartment C101 Newtown, PA 18940 1/1/1988 Brooke B. Smith, Jr. Member Emeritus 1324 Longs Point Woodland Park, CO 80863-5306 SE 1/1/1982 Jack Woycheese Member Emeritus 1649 Constable Street Prescott, AZ 86301 SE 1/1/1996 Robert P. Benedetti Staff Liaison National Fire Protection Association 1 Batterymarch Park Quincy, MA 02169-7471 4

FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE COMMITTEE I. Participation Minutes of NFPA 30 First Draft Meeting NFPA 30 Technical Committee on Tank Storage and Piping Systems Crowne Plaza Hotel, Austin TX Friday, September 11, 2015, 8:00 AM to 5:00 PM S. P. Allwein, Morrison Brothers Company J. H. Bagnall, Burns & McDonnell Engineering Company T. D. Blackford, Chevron Energy Technology Company (Rep. American Petroleum Institute) J. V. Cignatta, Datanet Engineering Inc. S. D. Curran, Fiberglass Tank & Pipe Institute (via web conference) C. A. Davis, AECOM/URS Corporation C. V. De Taeye, Travelers Insurance Company (via web conference) J. J. Foley, JENSEN HUGHES W. B. Geyer, Steel Tank Institute (STA/SPFA) S. W. Haines, Haines Fire & Risk Consulting Corp., CHAIR D. H. Havens, Bechtel Marine Propulsion Corporation A. A. Kelly, JENSEN HUGHES (Alternate to J. J. Foley) G. D. Kirby, Cytec Solvay Group R. S. Kraus, Petroleum Safety Consultants (Alternate to T. D. Blackford - Rep. American Petroleum Institute) T. S. Lentz, Aon Risk Services, Inc. T. S. Murphy, Travelers Insurance Company (Alternate to C. V. De Taeye) P. Myers, Pemy Consulting LLC D. P. Nugent, Global Risk Consultants C. R. Plummer, PPM Consultants, Inc. (Alternate to J. R. Rocco - Rep. Petroleum Marketers Association of America) A. M. Ramirez, UL LLC (Alternate to R. A. Riegel) R. N. Renkes, Petroleum Equipment Institute J. W. Richmond Sr., Eastman Chemical Company R. A. Riegel, UL LLC J. R. Rocco, Sage Risk Solutions, LLC (Rep. Petroleum Marketers Association of America) J. M. Shapiro, International Code Consultants (Alternate to W. B. Geyer - Rep. Steel Tank Institute (STI/SPFA)) R. J. Tanner, Michigan Department of Environmental Quality (Alternate to M. J. Poxson) J. J. Wanko, U. S. Occupational Safety and Health Administration D. B. Wechsler, Katy TX (Rep. American Chemistry Council) J. P. Woycheese, Saudi Aramco (via web conference) R. P. Benedetti, National Fire Protection Association, STAFF LIAISON J. Shapiro, National Fire Protection Association, STAFF LIAISON GUESTS: J. R. Barber, RCP Incorporated A. R. Cole, Aman Fire Engineering J. J. Jablonski, HSB PLC B. Stoner, Roth Industries

R. Young, Petroleum Equipment Institute Members Unable to Attend L. F. Arango, Global Asset Protection Services (Alternate to P. J. Willse) M. D. Butler, AECOM/URS Corporation (Alternate to C. A. Davis) D. C. Kirby, Baker Engineering & Risk Consultants, Inc. A. M. Ordile, Haines Fire & Risk Consulting Corp. (Alternate to S. W. Haines) D. W. Owen, ExxonMobil Corporation (Alternate to C. D. Shepard) M. J. Poxson, Michigan Bureau of Fire Services N. Ramsden, Resource Protection International D. L. Rehmeyer, Baker Engineering & Risk Consultants, Inc. (Alternate to D. C. Kirby) T. G. Schroeder, Husky Corporation C. D. Shepard, ExxonMobil Corporation P. J. Willse, Global Asset Protection Services II. Minutes 1. The meeting was called to order at 8:00 PM on September 11, 2015 by Technical Committee Chair Steve Haines. 2. Attendees introduced themselves. The Technical Committee roster was corrected as needed. 3. The Minutes of the last meeting (June 2013, San Antonio TX) were unanimously approved as submitted. 4. Technical Committee Chair briefly reviewed the Agenda. 5. The Staff Liaison reported on the following: Scopes of Technical Correlating Committee and Technical Committees. The proposed amendments to the Committee scope statement were agreed upon. The Staff Liaison was directed to ballot the new scope statement. Membership Status. The Staff Liaison reported on recent changes to committee membership and on the balance of interests on the committees. Document Revision Schedule for NFPA 30-2018. The Staff Liaison reviewed the revision schedule for the Annual 2017 revision schedule. 6. There were no current issues to report to the Technical Correlating Committee. 7. The Technical Committee reviewed and took action on all public inputs to amend those chapters of the 2015 edition of NFPA 30 that are under this Technical Committee s jurisdiction. These included Public Inputs to Chapters 21, 22, 27, and Annex C, as well as two Global Inputs (low pressure dispensing containers; referenced standards). These resulted in 14 First Revisions and 10 Committee Inputs. With respect to the Global Input on low pressure dispensing containers, the Technical Committee determined that these were beyond its purview and deferred to the opinions of the other Technical Committees. The Staff Liaison was directed to proceed with the First Draft ballot. 8. There was no recent correspondence requiring the Technical Correlating Committee s attention. 9. Under Old Business : - The Technical Committee revisited the recommendation by the U. S. Chemical Safety and Hazard Investigation Board on isolated storage tanks. After an extended discussion the Technical Committee concluded that no action should be taken, pending better input from the Board with

respect to desired changes. - The Technical Committee reviewed the draft report of the U. S. Chemical Safety and Hazard Investigation Board on the CAPECO (Puerto Rico) fire. The Technical Committee took no action,as this was a draft report that the Board had yet to vote to release. - The subject of clarification of pressure limitations for storage tanks was discussed, but there was no interest in amending Chapter 21, unless further interest is expressed after the First Draft report is released. - The Technical Committee discussed re-evaluation of storage tank separation distances. It was concluded this is a project to be undertaken after completion of the Second Draft report. At that time, a Task Group will be established to work with the Fire Protection Research Foundation to develop a project proposal. 10. Under New Business, the Technical Committee established a Task Group to study the issue of listing of tank accessories and appurtenances, with the objective of dealing with the issue in the next (2021) edition of NFPA 30. The Task Group is to be chaired by Jim Rocco and will include Steve Allwein and Bob Renkes. 11. The Technical Committee deferred to the Correlating Committee on scheduling the 2nd Draft Meeting. 12. The meeting adjourned at 3:00 PM.

FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE COMMITTEE COMMITTEE MEMBERSHIP BALANCE TCC on Flammable & Combustible Liquids - FLC-AAC Principals: 12 M: 2 (17%)* U: 4 (33%) Voting Alternates: 0 I/M: 0 L/C: 0 Alternates: 4 R/T: 1 (8%) E: 0 Non-Voting: 5 I: 1 (8%) SE: 4 (33%) Emeritus: 3 Task Group: 0 Hold List: 1 Balance: OK *(containers: 0 liquids: 2) T/C on Fundamentals of Flammable & Combustible Liquids - FLC-FUN Principals: 27 M: 6 (22%)* U: 6 (22%)** Voting Alternates: 0 I/M: 0 L/C: 0 Alternates: 8 R/T: 1 (4%) E: 1 (4%) Non-Voting: 1 I: 6 (22%) SE: 7 (26%) Emeritus: 1 Task Group: 0 Hold List: 6 Balance: OK *(containers: 1 fire suppression equipment: 1 liquids: 4 tanks: 0) **(end user: 3 warehousing: 1) T/C on Operations - FLC-OPS Principals: 30 M: 8 (27%)* U: 8 (27%) Voting Alternates: 0 I/M: 0 L/C: 0 Alternates: 15 R/T: 1 (3%) E: 0 Non-Voting: 1 I: 7 (23%) SE: 6 (20%) Emeritus: 1 Task Group: 0 Hold List: 5 Balance: OK *(liquid handling equipment: 1 liquids: 7) FLCC Scope Statements & Member Balance.doc - 5/3/2016

T/C on Storage & Warehousing of Containers & Portable Tanks - FLC-SWC Principals: 29 M: 6 (21%)* U: 7 (25%) Voting Alternates: 0 I/M: 2 (4%)** L/C: 0 Alternates: 14 R/T: 1 (4%) E: 0 Non-Voting: 0 I: 7 (25%) SE: 6 (21%) Emeritus: 1 Task Group: 0 Hold List: 4 Balance: OK *(containers: 1 fire suppression systems: 1 liquids: 3 safety cabinets & cans: 1) **(fire suppression systems: 2) T/C on Tank Storage & Piping Systems - Principals: 27 M: 5 (18%)* U: 8 (30%) Voting Alternates: 0 I/M: 0 L/C: 0 Alternates: 13 R/T: 1 (4%) E: 1 (4%) Non-Voting: 1 I: 3 (11%) SE: 9 (33%) Emeritus: 4 Task Group: 0 Hold List: 4 Balance: OK *(fire suppression systems: 0 liquid handling equipment: 2 tanks: 2 tank appurtenances: 1) FLCC Scope Statements & Member Balance.doc - 5/3/2016

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 www.nfpa.org/document # (i.e. www.nfpa.org/101) 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

61 of 176 6/13/2016 1:09 AM Public Comment No. 15-NFPA 30-2016 [ New Section after 21.4.2.1.1 ] TITLE OF NEW CONTENT Type your content here... API Specification 12P for Fiberglass Reinforced Plastic Tanks, Fourth Edition, February 2016 Statement of Problem and Substantiation for Public Comment Statement of Substantiation: 1. API Specification 12P is referenced in the IFC and such tanks are preferred in the Petroleum Exploration and Production industry to separate water from oil well produced water. The produced water is contaminated with sulfur and other corrosive material that is best processed in fiberglass tanks. 2. API 12P (2016) has been upgraded to include the requirements for (a) electrostatic hazards that may accumulated on both the inside and outside of the tank wall (i.e. static protection) and (b) lightning protection grounding, both of which are required to prevent such fire occurrences that have occurred in the past. 3. API 12P (2016) formalized their API Monogram quality control warranty program to License manufacturers and includes manufacturing site inspections. Related Item Public Input No. 58-NFPA 30-2015 [Section No. 21.4.2.1.1] Submitter Information Verification Submitter Full Name: Sullivan Curran Organization: Fiberglass Tank & Pipe Pipe Institute Affilliation: L F Manufacturing Inc.,Containment Solutions, Xerxes Corporation Street Address: City: State: Zip: Submittal Date: Thu Apr 21 16:52:52 EDT 2016

62 of 176 6/13/2016 1:09 AM Public Comment No. 2-NFPA 30-2016 [ Section No. 21.4.2.1.1 ] 21.4.2.1.1* Atmospheric tanks shall be designed and constructed in accordance with recognized engineering standards. Atmospheric tanks that meet any of the following standards shall be deemed as meeting the requirements of 21.4.2.1: (1) API Specification 12B, Bolted Tanks for Storage of Production Liquids (2) API Specification 12D, Field Welded Tanks for Storage of Production Liquids (3) API Specification 12F, Shop Welded Tanks for Storage of Production Liquids (4) API Standard 650, Welded Tanks for Oil Storage (5) UL 58, Standard for Steel Underground Tanks for Flammable and Combustible Liquids (6) ANSI/UL 80, Standard for Steel Tanks for Oil-Burner Fuels and Other Combustible Liquids (7) ANSI/UL 142, Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids (8) ANSI/ UL 1316, Standard for Glass-Fiber Reinforced Plastic Underground Storage Tanks for Petroleum Products, Alcohols, and Alcohol-Gasoline Mixtures (9) ANSI/UL 1746, Standard for External Corrosion Protection Systems for Steel Underground Storage Tanks (10) UL 2080, Standard for Fire Resistant Tanks for Flammable and Combustible Liquids (11) ANSI/UL 2085, Standard for Protected Aboveground Tanks for Flammable and Combustible Liquids Statement of Problem and Substantiation for Public Comment The ANSI designation for UL 1316 was removed by UL on May 12, 2006. A copy of the communication from UL is provided. Specifically, it states, "The revisions dated May 12, 2006, were issued to delete the ANSI approval information from the title page." The heading of this communication was entitled "Summary of Topics s1316_2_sum.html." Related Item First Revision No. 19-NFPA 30-2015 [Section No. 2.3] Submitter Information Verification Submitter Full Name: Wayne Geyer Organization: Steel Tank Institute (STI/SPFA) Street Address: City: State: Zip: Submittal Date: Mon Mar 07 16:59:12 EST 2016

63 of 176 6/13/2016 1:09 AM Public Comment No. 30-NFPA 30-2016 [ Section No. 21.4.2.1.1 ] 21.4.2.1.1 * Atmospheric tanks shall be designed and constructed in accordance with recognized engineering standards. Atmospheric tanks that meet any of the following standards shall be deemed as meeting the requirements of 21.4.2.1: (1) API Specification 12B, Bolted Tanks for Storage of Production Liquids (2) API Specification 12D, Field Welded Tanks for Storage of Production Liquids (3) API Specification 12F, Shop Welded Tanks for Storage of Production Liquids (4) API Standard 650, Welded Tanks for Oil Storage (5) UL 58, Standard for Steel Underground Tanks for Flammable and Combustible Liquids (6) ANSI/UL 80, Standard for Steel Tanks for Oil-Burner Fuels and Other Combustible Liquids (7) ANSI/UL 142, Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids (8) ANSI/UL 1316, Standard for Glass-Fiber Reinforced Plastic Underground Storage Tanks for Petroleum Products, Alcohols, and Alcohol-Gasoline Mixtures (9) ANSI/UL 1746, Standard for External Corrosion Protection Systems for Steel Underground Storage Tanks (10) UL 2080, Standard for Fire Resistant Tanks for Flammable and Combustible Liquids (11) ANSI/UL 2085, Standard for Protected Aboveground Tanks for Flammable and Combustible Liquids (12) UL 142A, Outline for Special Purpose Aboveground Tanks for Specific Flammable and Combustible Liquids Statement of Problem and Substantiation for Public Comment Rationale UL142A special purpose tank types have been Listed by UL and approved by AHJs for decades, but was never referenced in NFPA 30 because they were incorrectly thought to be covered by UL142. As 10 s of thousands of these tanks have been Listed, Labeled and Approved for their special purpose applications, it would be a dis-service to Code users to deny correct document identification of UL142A requirements in the body, to which all these tanks were evaluated. As stated at the 1st Draft Meeting, UL142A contains limitations, unique features & new or revised requirements to address the specific special purpose tank types and their applications, which are not in UL142. Related Item Committee Input No. 17-NFPA 30-2015 [Section No. A.21.4.2.1.1] Submitter Information Verification Submitter Full Name: Ronald Farr Organization: UL LLC Street Address: City: State: Zip: Submittal Date: Wed May 11 15:05:45 EDT 2016

64 of 176 6/13/2016 1:09 AM Public Comment No. 32-NFPA 30-2016 [ Section No. 21.4.3.4 ] 21.4.3.4 Atmospheric storage tanks shall be vented to prevent the development of vacuum or pressure above the 1.0 psi (6.9 kpa) maximum operating pressure. Statement of Problem and Substantiation for Public Comment Public Comment Until the TG completes its proposed revisions to 21.4.3.4, we believe it is important to recognize the comprehensive safety requirements in UL2583 for verification of the functional operating parameters of normal (P/V) vents commonly used on shop fabricated tanks, as new Appendix material. A21.4.3.4 Normal (pressure/vacuum) vents evaluated to UL2583 verifies the normally closed device opens under both 0.5 psi vacuum and 1.0 psi pressure relative to normal operating conditions (fill & withdraw) and atmospheric changes (temperature & pressure) as intended per 21.4.3.1 and required by 21.4.3.4. The evaluation ensures the device opens with adequate flow at these values before and after expected installation and use conditions, such as fuel vapor and environmental exposures. Rationale Normal (P/V) vents have been Listed by UL and approved by AHJs in various flammable liquid storage tank applications for decades, but was never referenced in NFPA 30. Since UL2583 has published new & revised requirements to verify these functional safety devices will open outside of the tanks normal operating parameters of pressure and vacuum under expected installation & use conditions, including biofuels compatibility, we believe UL2583 should be referenced as meeting the minimum n-vent safety requirements in the Code. Several manufacturers are already in compliance with the new requirements. Related Item Committee Input No. 405-NFPA 30-2015 [Section No. 21.4.3.4] Submitter Information Verification Submitter Full Name: Ronald Farr Organization: UL LLC Street Address: City: State: Zip: Submittal Date: Wed May 11 15:25:49 EDT 2016

65 of 176 6/13/2016 1:09 AM Public Comment No. 34-NFPA 30-2016 [ Section No. 21.7.1 ] 21.7.1* Prevention of Overfilling of Storage Tanks. Facilities with aboveground tanks larger than 1320 gal (5000 L) storing Class I or Class II liquids shall establish procedures or shall provide equipment, or both, to prevent overfilling of tanks. 21.7.1.1 Facilities with aboveground tanks that receive and transfer Class I liquids from mainline pipelines or marine vessels shall establish and follow formal written procedures to prevent overfilling of tanks utilizing one of the following methods of protection: (1) Tanks shall be gauged at intervals in accordance with established procedures by personnel continuously on the premises during product receipt. Acknowledged communication shall be maintained with the supplier so flow can be shut down or diverted in accordance with established procedures. (2) Tanks shall be equipped with a high-level detection device that is either independent of any gauging equipment or incorporates a gauging and alarm system that provides electronic self-checking to indicate when the gauging and alarm system has failed. Alarms shall be located where personnel who are on duty throughout product transfer can arrange for flow stoppage or diversion in accordance with established procedures. (3) Tanks shall be equipped with an independent high-level detection system that will automatically shut down or divert flow in accordance with established procedures. 21.7.1.2 Alternatives to instrumentation described in 21.7.1.1(2) and 21.7.1.1(3) shall be allowed where approved as affording equivalent protection. 21.7.1.3 Instrumentation systems covered in 21.7.1.1(2) and 21.7.1.1(3) shall be wired fail-safe, such that valid alarm conditions or system failures create an alarm condition that will notify personnel or automatically shut down or divert flow. 21.7.1.3.1 Written instrumentation performance procedures shall be established to define valid alarm conditions and system failures in accordance with API 2350, Overfill Protection for Storage Tanks in Petroleum Facilities. 21.7.1.3.2 System failure shall include but not be limited to the following: (1) Loss of main electrical power (2) Electrical break, short circuit, or ground fault in the level detection system circuit or the alarm and signal circuit (3) Failure or malfunction of the level detection system control equipment or signaling devices 21.7.1.4 Formal written procedures required by 21.7.1.1 shall include the following: (1) Instructions covering methods to check for lineup and receipt of initial delivery to tank designated to receive shipment. (2) Provision for training and monitoring the performance of operating personnel by supervisors. (3) Schedules and procedures for inspection and testing of gauging equipment and high-level instrumentation and related systems. Inspection and testing intervals shall be approved but shall not exceed 1 year. 21.7.1.5

66 of 176 6/13/2016 1:09 AM An underground tank shall be equipped with overfill prevention equipment that will either alert the transfer operator when the tank is no more than 90 percent full by triggering an audible and visual high-level alarm or automatically shut off the flow of liquid into the tank when the tank is no more than 95 percent full. 21.7.1.5.1 Other methods of overfill protection shall be permitted as approved by the authority having jurisdiction. 21.7.1.6 Shop-fabricated aboveground atmospheric storage tanks, constructed to the recognized standards of 21.4.2.1.1, shall meet the requirements of 21.7.1.6.1 through 21.7.1.6.4 whenever the vertical length from the tank bottom to the top of the fill, normal vent, or emergency vent exceeds 12 ft (3.7 m). 21.7.1.6.1 An approved means shall be provided to notify the tank filling operator of the pending completion of the tank fill operation at the fill connection. 21.7.1.6.2 An approved means shall be provided to stop delivery of liquid to the tank prior to the complete filling of the tank. 21.7.1.6.3 In no case shall these provisions restrict or interfere with the functioning of the normal vent or emergency vent. 21.7.1.6.4 The manufacturer of the tank shall be consulted to determine if reinforcement of the tank is required. If reinforcement is deemed necessary, it shall be done. Statement of Problem and Substantiation for Public Comment Public Comment Until the TG completes its proposed revisions to re-write Sec 21.7.1 for overfill protection, we believe it is important to recognize the comprehensive safety requirements in UL2583 for verification of the functional operating parameters of these devices that are commonly used on shop fabricated tanks, as new Appendix material. 21.7.1.5* An underground tank shall be equipped with overfill prevention equipment A21.7.1.5 Underground tank overfill protectors are an effective means to meet parts of the US EPA Underground Storage Tank (UST) Regulations (CFR 40 Part 280). Spill containment devices (weld on, spin on, side mount or remote fill types) evaluated to UL2583 requires minimum design criteria to fit inside the fill opening, and verifies flow restriction and shutoff at the fill levels specified in 21.7.1.5 before and after expected installation and use conditions, such as fuel vapor and environmental exposures. But, overfill preventers could also apply to aboveground tanks in Sec 21.7.1 ( or shall provide equipment, or both, to prevent overfilling of tanks.), plus 3 of 4 required parts of Sec 21.1.6, so we are also proposing similar Appendix material: 21.7.1.6.1 ( means shall be provided to notify the tank filling operator of the pending completion of the tank fill operation ), 21.7.1.6.2 ( means shall be provided to stop delivery of liquid to the tank ) and, 21.7.1.6.3 (In no case shall the provisions restrict or interfere with the functioning of the normal or emergency vent.) A 21.1.6 Overfill preventers evaluated to UL2583 are also suitable for use on aboveground tanks as an effective means to meet parts of the US EPA Spill Prevention, Control & Countermeasure (SPCC) Regulations (CFR 40 Part 112), and general intent of 21.7.1 and 21.7.1.6.1 to 21.7.1.6.3. Rationale Overfill preventers have been Listed by UL and approved by AHJs in various flammable liquid storage tank applications for decades, but was never referenced in NFPA 30. Since UL2583 has published new & revised requirements to verify functional safety of these devices under expected installation & use conditions, including biofuels compatibility, and operating features for flow restriction and shutoff at fill levels per 21.7.1.5, we believe UL2583 should be referenced as meeting the minimum overfill protection requirements in the Code. Several manufacturers are already in compliance with the new requirements.

67 of 176 6/13/2016 1:09 AM Related Item Committee Input No. 406-NFPA 30-2015 [Section No. 21.7.1] Submitter Information Verification Submitter Full Name: Ronald Farr Organization: UL LLC Street Address: City: State: Zip: Submittal Date: Wed May 11 15:44:25 EDT 2016

68 of 176 6/13/2016 1:09 AM Public Comment No. 33-NFPA 30-2016 [ Section No. 22.7.3.2.2 ] 22.7.3.2.2 The wetted area of the tank shall be calculated as follows: (1) Fifty-five percent of the total exposed area of a sphere or spheroid (2) Seventy-five percent of the total exposed area of a horizontal tank (3) One hundred percent of the exposed shell and floor area of a rectangular tank, but excluding the top surface of the tank (4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank Statement of Problem and Substantiation for Public Comment Public Comment with respect to added new section after this one. Public Comment We appreciate the TC s opportunity provided by CI#407 to add a new paragraph 22.7.3.2.3 specific to emergency vent devices commonly used on shop fabricated tanks, but think it may be best within this Code cycle to recognize the comprehensive requirements in UL2583 for these e-vents to be added to the 22.7.3.1 Appendix material as follows: A22.7.3.1 Emergency vents evaluated to UL2583 verifies the devices functional opening for pressure relief as required by 22.7.3.1. The tests ensure the device in normal use is closed and vapor tight per 22.7.3.2.1, then initially opens under abnormal pressure conditions at or below the 1.0 psi operating limits (see 21.4.2.1.4) and provides the minimum CFH flow rate per 22.7.3.2 without exceeding the 2.5 psi design limits of most shop fabricated atmospheric tanks (see 21.4.2.1.4). These functional safety parameters are also evaluated after expected installation and use conditions, such as fuel vapor and environmental exposures. In addition, UL2583 requires markings that meet 22.7.3.10 and 22.7.3.10.1 to 22.7.3.10.4 based on the above test results. Rationale Emergency vents have been Listed by UL and approved by AHJs in various flammable liquid storage tank applications for decades, but was never referenced in NFPA 30. Since UL2583 has published new & revised requirements to verify functional safety of e-vents under expected installation & use conditions, including biofuels compatibility, and specific operating parameters for start-to-open & full open pressure, plus maximum flow capacity, we believe UL2583 should be referenced as meeting the minimum e-vent safety requirements in the Code. Several manufacturers are already in compliance with the new requirements. Related Item Committee Input No. 407-NFPA 30-2015 [New Section after 22.7.3.2.2] Submitter Information Verification Submitter Full Name: Ronald Farr Organization: UL LLC Street Address: City: State: Zip: Submittal Date: Wed May 11 15:36:41 EDT 2016

69 of 176 6/13/2016 1:09 AM Public Comment No. 38-NFPA 30-2016 [ Section No. 22.13.4.2 ] 22.13.4.2 Such connections for any liquid shall be closed and liquidtight when not in use and shall be properly identified. 22.13.4..3 (New Section added after 22.13.4.2Committee Input - CI 408 Statement of Problem and Substantiation for Public Comment Committee Statement: The committee might consider adding new requirements for appurtenances to tank openings other than vents. Public Comment We appreciate the opportunity provided by CI#408 for addition of new paragraph 22.13.4.3 to address safety related devices other than vents commonly used in/on or around shop fabricated tank openings. But until a proper re-write can be done for this and other appropriate sections, it would be best within this Code cycle to only add spill containment requirements here, with new Appendix material to recognize UL2583 for compliance with Code requirements for them: 22.13.4.3* Appurtenances for tank openings A permanently attached means for leak tight spill containment shall be provided around fill openings for shop fabricated aboveground tanks intended for filling by delivery vehicles through a hose transfer. The containment capacity shall be sized to collect minor spills and overfills based on the opening diameter and fill rate. When not in use, spill containers shall be closed to prevent rain or debris from entering the containment area. A22.13.4.3 Aboveground tank spill containers are an effective means to meet parts of the US EPA Spill Prevention, Control & Countermeasure (SPCC) Regulations (CFR 40 Part 112). Spill containment devices (weld on, spin on, side mount or remote fill types) evaluated to UL2583 requires minimum design criteria for capacity, height, covers/lids and optional shutoff valves to ensure sufficient leak tight containment, compatibility and protection of fill adapters, drain valves, and other functional components within. Rationale Spill containers have been Listed by UL and approved by AHJs in various flammable liquid storage tank applications for decades, but was never referenced in NFPA 30. Since UL2583 has published new & revised requirements for these devices to establish effective capacities & dimensions for different container types and tanks sizes, and verify leak tight spill containment and component functions under expected installation & use conditions, including biofuels compatibility, we believe UL2583 should be referenced as meeting the minimum spill container safety requirements in the Code. Several manufacturers are already in compliance with the new requirements. Related Item Committee Input No. 408-NFPA 30-2015 [New Section after 22.13.4.2] Submitter Information Verification Submitter Full Name: Ronald Farr Organization: UL LLC Street Address: City: State: Zip: Submittal Date: Thu May 12 08:34:06 EDT 2016

70 of 176 6/13/2016 1:09 AM Public Comment No. 49-NFPA 30-2016 [ Section No. 27.2.4 ] 27.2.4 Low Melting Point Materials. Materials that melt at a low temperature, including but not limited to aluminum, copper, or brass; materials that soften on fire exposure, such as plastics thermoplastics ; or nonductile materials, such as cast iron. Statement of Problem and Substantiation for Public Comment 1. Background: The US Chemical Safety and Hazard Investigation Board March 2007 investigation report on the 1/11/2006 fire/explosion at the City of Daytona Beach, FL Waste water Treatment Plant page 39 recommended "revise NFPA 30 to specifically exclude the use of THERMOPLASTICS in above ground flammable liquid service. (capitalization of thermoplastics added) 2. The revised NFPA 30 paragraph 27.2.4 contains an error and does not recognize the Webster's dictionary definition of thermoplastic ("capable of softening or fusing when heated"), and thermoset plastic ("capable of becoming permanently rigid when heated or cured"). 3. The Uniform Building Code calls for a flame spread of less than 200 per ASTM E84-81 whereas FRP pipe resin has a flame spread of 25, which is considerably less than the UBC flame spread criteria. Thus FRP pipe is approved in the UBC. 4. Fuel Contribution Index: Unprotected thermoset pipe will be consumed when exposed to fire and is self extinguishing when the flame is removed, thus the fuel contribution is zero. 5. Flame resistant insulated pipe: Intumescent material is incorporated in the pipe resin such that the pipe is fire rated for three hours under flow conditions. 6. Phenolic Resin FRP pipe: ASTM F 117 01 Standard Specification for Thermosetting Resin Fiberglass Pipe Systems to be used for all fluids in Marine Applications. Thus, such ASTM FRP piping is used for all fluids in marine piping systems to improve buoyancy of the structure (i.e., light weight piping). 7. Summary: The 20115 Edition NFPA 30 inadvertently substituted the word "plastic" for "thermoplastic" versus the U S Chemical Safety and Hazard Investigation Board recommendation to exclude the use of "plastic" piping in above ground flammable liquid service. Related Item Committee Input No. 404-NFPA 30-2015 [Section No. 27.2.4] Submitter Information Verification Submitter Full Name: Sullivan Curran Organization: Fiberglass Tank & Pipe Institute Street Address: City: State: Zip: Submittal Date: Sun May 15 12:53:02 EDT 2016

71 of 176 6/13/2016 1:09 AM Public Comment No. 31-NFPA 30-2016 [ Section No. 27.5.2 ] 27.5.2 Flexible Connectors. Listed flexible connectors shall Flexible connectors listed and labeled in accordance wiht UL 2039, Standard for Flexible Connector Pipe for Fuels shall be permitted to be used where installed in accordance with 27. 5.3. Statement of Problem and Substantiation for Public Comment A27.5.2 Although use of Listed flexible connectors are a recommend means to mitigate pipe damage from stress, vibration and mechanical damage typically used in piping systems, not all Listed products are suitable for flammable and combustible liquid applications. Products Listed in accordance with UL2039 - Flexible Connector Piping for Fuels have been evaluated for automotive fuels and similar flammable & combustible liquids applicable to NFPA 30 and NFPA 30A uses. Products Listed in accordance with UL536 Flexible Metallic Hose have been evaluated for flammable gasses such as LPG, butane and natural gas applicable to NFPA 52 and NFPA 58 uses. Rationale UL2039 flex connector pipe for fuels have been Listed by UL and approved by AHJs for decades, but was never referenced in NFPA 30 or NFPA 30A. Since UL2039 published new & revised requirements in 2010 to address changes in expected installation & use conditions, including biofuels compatibility and fire resistance, which many manufacturers have complied with, we believe UL2039 should establish the minimum Listing requirements in the Code. It should also be noted that similar metallic flexible connectors covered under UL536 for gaseous fuels, such as butane, propane & natural gas, have recently excluded liquid fuels which are now covered under UL2039. UL2039 covers metallic & hybrid types of primary, secondary & coaxial flex connectors for automotive or similar fuels up to 6 OD & 12 L, and is rated for underground, sump and/or aboveground applications. The main performance requirements include pressure/vacuum leakage & strength tests after sequential rough assembly & installation simulation (drop, impact, crush, torque, tension & vibration), in addition to evaluation of long term material compatibility (external fluids & environments and internal bio fuels including B20 & E85), and fire resistance. UL2039 was balloted as a consensus Standard last year and was recently published. Related Item Committee Input No. 18-NFPA 30-2015 [Section No. 27.5.2] Submitter Information Verification Submitter Full Name: Ronald Farr Organization: UL LLC Street Address: City: State: Zip: Submittal Date: Wed May 11 15:17:21 EDT 2016

73 of 176 6/13/2016 1:09 AM Public Comment No. 29-NFPA 30-2016 [ Section No. A.21.4.2.1.1 ] A.21.4.2.1.1 Atmospheric tanks include tanks of compartmented design and tanks that incorporate secondary containment. See UL 142A, Outline for Special Purpose Aboveground Tanks for Specific Flammable or Combustible Liquids for additional information regarding listing of special purpose above ground tanks. Statement of Problem and Substantiation for Public Comment Public Comment 1 - We support Committee Input #17 to reference UL142A in A21.4.2.1.1, but believe a summary of exactly what special purpose tank types are covered, and how they differ from UL142 general purpose tanks should also be added to provide important details. A21.4.2.1.1 (Replace the CI new addition with): UL142A Outline for Special Purpose Aboveground Tanks for Specific Flammable & Combustible Liquids contains requirements for shop fabricated steel generator base, work bench, lube oil, used oil and day tanks. These requirements address constructions, features and performance for tank types having special use applications, stored liquids limitation, and optional accessories that are not covered by UL142 for general purpose tank and uses. Rationale UL142A special purpose tank types have been Listed by UL and approved by AHJs for decades, but was never referenced in NFPA 30 because they were incorrectly thought to be covered by UL142. We believe the Appendix reference to UL142A with the clarifications as proposed provides the accurate information Code users need to correctly identify the differences with UL142 general purpose tank types which cover a wider range of applications for significantly more flammable & combustible liquids. Public Comment 2 - In addition to the expanded Appendix material, we also believe our original proposal to reference UL142A in the 21.4.2.1 list of design standards should be reconsidered, as it has been a practically accepted recognized engineering standard by everyone in the industry since the mid 90 s, regardless of its temporary Outline status. 21.4.2.1.1 (Add to list): (#) UL142A Outline for Special Purpose Aboveground Tanks for Specific Flammable & Combustible Liquids. Rationale UL142A special purpose tank types have been Listed by UL and approved by AHJs for decades, but was never referenced in NFPA 30 because they were incorrectly thought to be covered by UL142. As 10 s of thousands of these tanks have been Listed, Labeled and Approved for their special purpose applications, it would be a dis-service to Code users to deny correct document identification of UL142A requirements in the body, to which all these tanks were evaluated. As stated at the 1st Draft Meeting, UL142A contains limitations, unique features & new or revised requirements to address the specific special purpose tank types and their applications, which are not in UL142. Related Item Committee Input No. 17-NFPA 30-2015 [Section No. A.21.4.2.1.1] Submitter Information Verification Submitter Full Name: Ronald Farr Organization: UL LLC Street Address: City: State: Zip: Submittal Date: Wed May 11 14:57:40 EDT 2016

74 of 176 6/13/2016 1:09 AM Public Comment No. 5-NFPA 30-2016 [ Section No. A.22.5.2.4 ] A.22.5.2.4 For further information, see ASTM E119, Standard Test Methods for Fire Tests of Building Construction and Materials, and ANSI/UL 1709, Standard for Rapid Rise Fire Tests of Protection Materials for Structural Steel or ASTM E1529. Additional Proposed Changes File Name Description Approved ASTM_vs_NFPA_vs_UL_vs_ISO_vs_IEC_tests_with_titles_Nov_2015.pdf Statement of Problem and Substantiation for Public Comment Comparison between ASTM, NFPA and UL tests ASTM E1529 is the same type of test as UL 1709 - I attach a file that shows the comparison by ASTM E05 (Fire Standards committee) between ASTM, NFPA and UL standard tests. I cannot provide a copy due to copyright reasons. The standard needs to be added also to the list of referenced standards in the annex. Related Public Comments for This Document Related Comment Public Comment No. 6-NFPA 30-2016 [Section No. I.1.2.6] Related Item Public Input No. 83-NFPA 30-2015 [Section No. A.22.5.2.4] Relationship Submitter Information Verification Submitter Full Name: Marcelo Hirschler Organization: GBH International Street Address: City: State: Zip: Submittal Date: Thu Mar 24 20:10:29 EDT 2016