Committee on NFPA 407 M E M O R A N D U M TO: FROM: NFPA Technical Committee on Aircraft Fuel Servicing Jeanne Moreau-Correia DATE: February 8, 2010 SUBJECT: NFPA 407 A11 ROP Letter Ballot The ROP letter ballot for NFPA 407 is attached. The ballot is for formally voting on whether or not you concur with the committee s actions on the proposals. 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 Monday, February 22, 2010. As noted on the ballot form, please submit the ballot to Jeanne Moreau-Correia, e-mail to jmoreaucorreia@nfpa.org or fax to 617-984-7110. The return of ballots is required by the Regulations Governing Committee Projects. Attachment: Proposals
407-1 Log #CP2 Review entire document to: 1) Update any extracted material by preparing separate proposals to do so, and 2) review and update references to other organizations documents, by preparing proposal(s) as required. To conform to the NFPA Regulations Governing Committee Projects. The committee prepared a separate 407-2 (Log #CP6) to update the referenced documents. NFPA 407 has one definition that is extracted from NFPA 385 for. That definition is the same in the 2007 edition of NFPA 385 thus no update is needed (Part 1 of the proposal). Committee Proposal 407-2(Log #CP6) shows updates for Chapter 2 and Annex C. (Part 2 of the proposal). 1
407-2 Log #CP6 Provide updated references to other organizations documents in Chapter 2 and Annex C as follows: The documents or portions thereof listed in this chapter are referenced within this standard and shall be considered part of the requirements of this document. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471. NFPA 10, Standard for Portable Fire Extinguishers, 2007 2010 edition. NFPA 30, Flammable and Combustible Liquids Code, 2003 2008 edition. NFPA 70, National Electrical Code, 2005 2008 edition. NFPA 385, Standard for Tank Vehicles for Flammable and Combustible Liquids, 2000 2007 edition. NFPA 410, Standard on Aircraft Maintenance, 2004 edition. NFPA 415, Standard on Airport Terminal Buildings, Fueling Ramp Drainage, and Loading Walkways, 2002 2008 edition. NFPA 418, Standard for Heliports, 2006 edition. 2.3.1 ANSI Publications. American National Standards Institute, Inc., 25 West 43rd Street, 4th floor, New York, NY 10036. ANSI B31.3, Chemical Plant and Petroleum Refinery Piping, 1993. American Petroleum Institute, 1220 L Street, N.W., Washington, DC 20005-4070. API BULL 1529, Aviation Fueling Hose, 1998. ASME, 3 Park Avenue, New York, NY 10016-5990. ASME B31.3, Process Piping, 2008 ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959. ASTM D 380, Standard Test Methods for Rubber Hose, 1994. Revised 2006. American Welding Society, 550 N.W. LeJeune Road, Miami, FL 33126. AWS A5.10, Specification for Bare Aluminum and Aluminum Alloy Welding Electrodes and Rods, 19921999. Revised 2007.. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096. ANSI/UL 913, Standard for Intrinsically Safe Apparatus and Associated Apparatus for Use in Class I, II, and III Division 1, Hazardous (Classified) Locations, 2002. Revised August 20042006, Revised 2008. U.S. Government Printing Office, Washington, DC 20402. Title 49, Code of Federal Regulations, 1998. Revised October 2003. Merriam-Webster s Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, 2003. Revised 2006. NFPA 385, Standard for Tank Vehicles for Flammable and Combustible Liquids, 2000 2007 edition. The documents or portions thereof listed in this annex are referenced within the informational sections of this standard and are not part of the requirements of this document unless also listed in Chapter 2 for other reasons. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471. NFPA 30, Flammable and Combustible Liquids Code, 2003 2008 edition. NFPA 70, National Electrical Code, 2005 2008 edition. NFPA 77, Recommended Practice on Static Electricity, 2007 edition. NFPA 415, Standard on Airport Terminal Buildings, Fueling Ramp Drainage, and Loading Walkways, 2002 2008 edition.. American Petroleum Institute, 1220 L Street, N.W., Washington, DC 20005-4070. API BULL 1529, Aviation Fueling Hose, 1998. API/IP Std 1529, Aviation Fueling Hose and Hose Assemblies, 6th edition. 2005. API RP 2003, Protection Against Ignitions Arising Out of Static, Lightning, and Stray Currents, 1991 2008.. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959. ASTM D 86, Standard Test Method for Distillation of Petroleum Products, 1995 2009. 2
ASTM D 323, Standard Test Method for Vapor Pressure of Petroleum Products (Reid Method), 1994 2008.. Coordinating Research Council Inc., 3650 Mansell Road, Suite 140, Alpharetta, GA 30022. CRC Report No. 583, Aircraft and Refueler Bonding and Grounding Study, 1993. FM Global, 1301 Atwood Avenue, P.O. Box 7500, Johnston, RI 02919. FM Class 3610, Intrinsically Safe Apparatus and Associated Apparatus for Use in Class I, II, & III Division 1, and Class I, Zone 0 & 1 Hazardous (Classified) Locations. ISA, 67 Alexander Drive, Research Triangle Park, NC 27709. ANSI/ISA-60079-11 (12.02.01), Explosive Atmospheres Part 11: Equipment Protection by Intrinsic Safety i, 2009 ANSI/ISA 12.02.01, Electrical Apparatus for Use in Class I, Zones 0, 1,&2 Hazardous (Classified) Locations Intrinsic Safety i. National Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161. An Evaluation of the Relative Fire Hazards of JETAand JET B for Commercial Flight (N74-10709). Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096. ANSI/UL 913, Standard for Intrinsically Safe Apparatus and Associated Apparatus for Use in Class I, II, and III Division 1, Hazardous (Classified) Locations, 2002. Revised August 2004 2006, Revised 2008. ANSI/UL 60079-11, Electrical Apparatus for Use in Class I, Zones 0, 1,&2 Hazardous (Classified) Locations Intrinsic Safety i. 2009. Bachman, K. C. and W. G. Dukek, Static Electricity in Fueling Superjets, 1972. Exxon Research & Eng. Co. Brochure, Linden, NJ. The following documents or portions thereof are listed here as informational resources only. They are not a part of the requirements of this document. American Petroleum Institute, 1220 L Street, N.W., Washington, DC 20005-4070. API STD 2000, Venting Atmospheric and Low-Pressure Storage Tanks: Nonrefrigerated and Refrigerated, 1992.1999.. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959. ASTM D 910, Standard Specification for Aviation Gasolines, 1995 2007. ASTM D 1655, Standard Specification for Aviation Turbine Fuels, 1995 2009. (Reserved) This proposal updates the documents that are referenced in NFPA 407 to reflect the currently available editions. The committee will review the list again during the ROC preparation meeting. 407-3 Log #5 Bob Eugene, Underwriters Laboratories Inc. 2.3.5 UL Publications. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096. ANSI/UL 913, Standard for Instrinsically Safe Apparatus and Associated Apparatus for Use in Class I, II, and III Division 1, Hazardous (Classified) Locations, 2002. Revised August 2004 2006, Revised 2008. Update referenced standard to most recent revision. 3
407-4 Log #CP1 Adopt the preferred definition from the NFPA Glossary of Terms as follows: The pressure at which a hydraulic component fails due to stresses induced as a result of the pressure. [ 2009] This definition is the preferred definition from the Glossary of Terms. Changing the secondary definition to the preferred definition complies with the Glossary of Terms Project. Revise the proposed definition from the NFPA GOT group as follows: The pressure at which a hydraulic component fails due to stresses induced as a result of the pressure. The committee suggests that the term be removed from the definition. A component could be under pneumatic pressure and fail as well as under hydraulic pressure. The revised definition should be able to work for any NFPA TC that is concerned with component failure under a pressure condition. 4
407-5 Log #8 Fred A. Cnota, Chicago Fire Department Diesel Particulate Filter (DPF) regeneration equipped vehicles shall have a lockout mode which would prevent automatic regeneration while operating these vehicles within 30 m (100 ft) of aircraft parking areas. DPF regeneration system piping shall be shielded from engine discharge manifold to the outlet at the tailpipe. DPF regeneration equipped vehicles shall have a listed diffuser installed at the outlet of the exhaust tailpipe. All vehicles that have engines equipped with an exhaust after-treatment devices such as a DPF, that requires the filter to be cleaned at high temperature (regenerated) while installed on the vehicle shall meet the requirements of 5.6.4.1 through 5.6.4.7. DPF regeneration shall be performed only in area(s) designated by the Authority Having Jurisdiction. DPF regeneration shall not be performed within 30 m (100 ft) of any aircraft refueling operations. The size of the DPF regeneration area depends on the equipment being used (fleet size). The AHJ should designate the size and number of DPF regeneration pads and determine whether a centralized facility is advantageous. The immediate area surrounding the DPF exhaust outlet shall be concrete or other high-temperature resistant material and shall be clear of any grass, soil, or flammable materials. The area shall be in a remote location that is a minimum of 30 m (100 ft) from the nearest aircraft parking location, airport terminal, or flammable storage; or a minimum of 15 m (50 ft) from any other building. The area shall be clearly marked with a minimum 61 cm by 30 cm (2 ft by 1 ft) sign reading Vehicle DPF Regeneration Area and shall have letters at least 75 mm (3 in.) high and shall be of a color contrasting sharply with the sign background for visibility. The regeneration cycle shall be performed only by trained personnel who shall remain with the vehicle until the regeneration cycle is complete. The vehicle shall be visually inspected for any signs of fluid leaks under or around the vehicle before initiating regeneration. DPF regeneration shall not be initiated if there are any signs of any fluid leaks on or beneath the vehicle. Once a regeneration cycle is started, it shall be completed without interruption. After the regeneration process is successfully completed, the vehicle shall be permitted to return to normal service. Problems occurring during the regeneration cycle shall be corrected prior to the vehicle returning to normal service. Aircraft refueling operations shall not be initiated if the regenerative system indicates regeneration is required. Aircraft refueling vehicles with these new exhaust requirements are now being used on airfields. This TIA will address the operational issues with the regeneration sequence that will provide a measure of safety for the fuel handlers as well as the airfields they operate on. These requirements need to be sent out to the end users as soon as possible. These units will have the potential of introducing an ignition source due to the extremely high temps generated by the exhaust system, not only the exhaust gasses but the pipes themselves, any Jet-A leaked onto any part of the system would cause a fire. In the event of a spill with vapors, either the exhaust gases (between 371 and 649 degrees C (700 and 1200 degrees F)) or heat off the exhaust pipes themselves could start a fire. The emergency that exists is that these units are already in use with no current regulation. Exhaust gas temps, when in the regeneration mode, reach over 1200 degrees inside the system and exhaust gasses are over 700 degrees. Both of these are hot enough to ignite Jet-A vapors or fuel (if dripped onto exhaust system components). The potential for a life threatening event is real and regulation must be put into effect to minimize the possibility of a multiple fatality event. 5
407-6 Log #2 Fred A. Cnota, Chicago Fire Department 1. Revise 4.3.6.7 as follows: Non-turbo charged diesel engines on fuel servicing vehicles shall be equipped with flame and spark arresting exhaust systems. 2. Add new Annex material as follows: The requirement for spark arresting exhaust systems is not intended to extend to diesel engines equipped with turbochargers. The USDA Forest Service, the governmental body who regulates the spark arrestor standard, clearly identifies that all diesel engines with a turbo charger and no waste-gate (also clearly identified therein) are exempt from the requirements to have an additional spark arresting device. Previously, 4.3.6.7 stated that all engines on fuel servicing vehicles shall be provided with flame and spark arresting exhaust systems. Notice that 4.3.6.6 specifically states gasoline engines are required to have such a system. This would eliminate the confusion that it is causing. It has been brought to my attention that a TIA to rewrite 4.3.6.7 is necessary in an emergency nature. This section has caused great confusion and has almost shut down airports due to interpretation of the rule by inspectors. 407-7 Log #CP3 Revise text of 4.3.7.6 as follows: Lamps, and switching devices, and electronic controls other than those covered in 4.3.7.4 and 4.3.7.5, shall be of the enclosed, gasketed, weatherproof type. Other electrical components shall be of a type listed for use in accordance with NFPA 70 Class I, Division 2, Group D locations. The committee notes that more electronic components are are now installed on the fueling vehicles than when the requirement was first added. Electronic gauges, monitoring devcies and the like might be present and such devices can really not be designated as a lamp or a switch. 6
407-8 Log #1 Chris Dukes, DTS Refueling System, LLC Revise 4.3.16.8 to read as follows: Aircraft fuel servicing tank vehicles shall be equipped with having a positive displacement product pump shall be equipped with a product tank low level shutdown system that prevents air from being ingested into the fueling system. Centrifugal pumps, unlike positive displacement pumps, lose prime and cavitate when the tank is emptied of product. As air enters the suction port, pump output effectively stops, thus presenting no threat of dispensing air in lieu of fuel into the aircraft. Numerous aircraft fuel servicing vehicles, built with centrifugal pumps, have been unnecessarily removed from service after inspection by the authority having jurisdiction because of the NFPA 407 paragraph cited above. 407-9 Log #7 David A. Dempsey, Chicago, IL New text to read as follows: 5.1.4 Jet-A tankers shall not be allowed to travel through enclosed roadways longer than 100 feet. 5.1.4.1 The AHJ may allow a variance to 5.1.4 IF current past practice requires said tankers to travel through enclosed roadways. However, NO VARIANCES for NEW design or construction will be allowed. The problem is you could have a catastrophic failure of a tanker carrying thousands of gallons of fuel in an enclosed roadway. Such an incident would cause loss of life to all persons in said enclosed roadway should an explosion or fire develop. If the tunnel was under a runway, the runway surface would become compromised and cause aircraft damage or destruction with an even greater loss of life. Even if the enclosed roadway had a standpipe system, the delay in firefighting would be unavoidable and loss of life would occur. Additionally, the situation would put firefighters at greater risk of injury or loss of life due to the extreme heat buildup and limited access in such a location. Not even addressed are the environmental concerns a spill would create. Damage to the supporting roof structure would require shutdown of the surface area above due to possible collapse. If this surface is a runway or taxiway, airport delays and expense would be great. I realize that this situation may already exist at some airports. It would be impossible to redesign each airport, the reason for 5.1.4.1. By adding this requirement, a potential life threat is avoided in new construction or redesign of airfields. The committee agrees that tunnel safety is an important issue. Overall, the tunnel has to be safe for passage by any vehicle that may be using it. The issue is not necessarily limited to tankers that may be carrying Jet A fuel. Private autos and other vehicles that make approaches to the terminal at LAX are another example of how tunnel safety needs to be considered in a broader context. Tunnel design, operational restrictions pertaining to vehicles or a combination thereof appears to be airport specific. The layout and available space at vehicle approach points to the airport property and on the airport property itself will dictate limitations on what vehicles can or cannot use any tunnels. The committee understands that the operators of Miami International Airport do not allow fueling vehicles of any sort to use the tunnels. The committee has agreed to form a task group to further research and study this issue and see what changes might be considered at the ROC stage. The task group will consult with airport operators and make a review of related NFPA documents including NFPA 415, NFPA 424 and NFPA 502 among others. 7
407-10 Log #3 Mindy Wang, Ampco Safety Tools Add new text as follows: Where a spill is observed, the fuel servicing shall be stopped immediately by release of the deadman controls. In the event that a spill continues, the equipment emergency fuel shutoff shall be actuated. In the event that a spill continues from a hydrant system, the system emergency fuel shutoff shall be actuated. The supervisor shall be notified at once, and the operation shall not be resumed until the spill has been cleared and conditions are determined to be safe. Use clean spark-resistant tools to collect absorbed materials. NFPA 407 can better mitigate the flammability hazards by specifying the use of spark resistant tools. Without this specification, steel tools are likely to be used which can be an ignition source. NFPA 30, Flammable and Combustible Liquids, Chapter 6, Section 6.5.1 lists frictional heat or sparks as sources of ignition of flammable vapors and precaution shall be taken to control ignition sources. NFPA 921, Guide for Fire and Explosion Investigations 2008 Edition, Chapter 5 Basic Fire Science Table 5.76.1.1 Reported Burning and Sparking Temperature of Selected Ignition Sources under Mechanical Sparks lists a Steel tool temperature at 2550 F. When working with flammable gases, liquids or vapors, a potential hazard arises because of the possibility that sparks produced by steel or iron tools can become an ignition source. FM Approvals LLC, formerly Factory Mutual Research Corporation, (FM) is an international organization recognized by the U.S. government as a Nationally Recognized Testing Laboratory (NRTL) for scientific research and product certification. Product approval from a NRTL assures that products meet consensus-based standards of safety to provide the assurance, required by OSHA, that these products are safe for use in the United States workplace. FM Approval Standard 7910, Spark Resistant Tools is used as guidance to evaluate tools intended for use in environments where there is a risk of ignition of flammable materials, dusts or vapors resulting from sparks created by iron and steel hand tools. These tools prevent the ignition of flammable materials, dusts or vapors by mechanical sparks created by the use of iron and steel hand tools slipping or striking a surface. These tools provide a solution in place of ferrous tools in flammable environments. Recognizing the potential for steel tools to be an ignition source in flammable environment, the Occupational Safety & Health Administration (OSHA) provides guidance in booklet 3080 Hand and Power Tools, 2002 revised, iron and steel hand tools may produce sparks that can be an ignition source around flammable substances. Where this hazard exists, spark-resistant tools should be used. NFPA 407, Annex B Aviation Fuel, Section B.2.3 states that..the standard grades of aviation gasoline do produce flammable vapors in ignitable amounts at normal temperatures and pressure With JET B turbine fuel, due to its relatively low vapor pressure, the vapor-air mixture above the liquid surface under normal temperature and pressure conditions frequently is within the flammability range. The Pipeline and Hazardous Materials Safety Administration s (PHMSA) office of Hazardous Materials Safety and its counterparts in Canada and Mexico publish The Emergency Response Guidebook (ERG), which serves as a guide to aid first responders in identifying the hazards of the materials involved during the initial response phase of an incident. ERG Guide 128 Flammable Liquids (Non-Polar/Water-Immiscible) for gasoline, kerosene POTENTIAL HAZARDS FIRE OR EXPLOSION - HIGHLY FLAMMABLE: Will be easily ignited by heat, sparks or flames. EMERGENCY RESPONSE SPILL OR LEAK - Use clean non-sparking tools to collect absorbed material. Jet fuel manufacturers such as ExxonMobil, Chevron, Valero, and CITGO regularly require the use of non-sparking tools under Accidental Release Measures in the MSDS s for their jet fuel products. These companies clearly recognize the need for spark resistant tools in working with and around motor fuel products. A few documented incidents of steel tools as an ignition source in flammable environments: OSHA inspection #124728437, Employee #1 and a coworker, both maintenance mechanics, were working in a 30 inch by 36 inch manhole at a gas station. Employee #1 was trying to change a fuel pump, while the coworker watched from outside the manhole. Employee #1 was using an Allen wrench to loosen the bolts on the fuel pump lead when he created a spark that ignited the gas fumes in the manhole, causing an explosion. Employee #1 suffered burns to his face, hands, arms and legs in the explosion and was hospitalized. OSHA inspection #300965795, an employee in the process of cleaning loose material from drill piping with a 8
metal hammer. While striking the pipe with a hammer, an explosion occurred. Employee was killed in the explosion on site. OSHA inspection #2272953, two employees were assigned the job of tending a 100 gallon (water jacket) reactor kettle of methyl methacrylate in the mixing room. Employee #1 used a metal wrench (visegrips) to pry open the cover of a kettle. The wrench handle struck the angle iron support for the agitator motor, producing a spark. Employee #2 noticed the spark, which was immediately followed by a massive fire ball. Both employees were engulfed in the fireball. Employee #3 came to the area to assist the other employees. The investigation states that non-sparking tools were not provided for the employees. All three employees received first and second degree burns on their face, arms and abdomen. Employee #2 also received some third degree burns. All three employees were hospitalized. OSHA inspection #607366, an employee was sawing an airplane wing into sections with a portable powered hand saw, the saw created a spark that caused an explosion of gasoline vapors in the wing fuel tank. Employee #1 killed and Employee #2 injured in explosion and was hospitalized. Without the specification for spark resistant tools, steel tools are likely to be used which can be a source of ignition. The proposed text better controls the potential of ignition source from steel tools. The scope of this proposed change is too narrow. While spark resistant tools might be one part of providing a safe work condition, other subjects such as personnel hazards, clean up procedures and use of all of the proper tools and equipment work in harmony to provide a safe cleanup process. Section 5.1.1 of NFPA 407 as well as the training criteria of CFR 139 would cover the use of the proper tools and equipment for a given situation. 407-11 Log #CP5 Modify existing text as follows in 5.4.4. Where a hydrant servicer or cart is used for fueling, bond the hydrant servicer or cart to the aircraft, and then connect the hydrant coupler to the hydrant system. The bonding sequence when hydrant fueling is being done in North America is slightly different than what is used primarily outside North America at this time. In API/EI 1540 [9.2.4.2] the bonding sequence is to bond the aircraft and vehicle fist then connect the pit coupler. In NFPA 407 [5.4] it says to connect the pit coupler before bonding the equipment. The API/EI undertook an electro static review to determine which sequence would be the safest. The API/EI document will be provided to the committee for review. It says that in most instances that there is no difference from a safety stand point in the sequence except in one particular condition the sequence described in API/EI 1540 is safer. In the hopes of aligning practices globally the committee has introduced this REJECTED committee proposal in order to introduce the subject so it can be commented on. The Technical Committee has formed a task group to review this work to see if it should revise its current bonding sequence practice. The task group will report back during the ROC meeting later in 2010 and decide what changes to NFPA 407 might be in order. 9
407-12 Log #CP4 Revise text of this one sentence only (no other changes to text before or after this sentence) as follows: Where this is done, the maximum distance between extinguishers should not be over 60 90 m (300 200 ft). This change is necessary to correlate NFPA 407 with NFPA 410, Standard on Aircraft Maintenance and NFPA 415, Standard on Airport Terminal Buildings, Fueling Ramp Drainage, and Loading Walkways, with regard to placement of fire extinguishers. 407-13 Log #6 Bob Eugene, Underwriters Laboratories Inc. C.1.2.7 UL Publications. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096. ANSI/UL 913, Standard for Intrinsically Safe Apparatus and Associated Apparatus for Use in Class I, II, and III Division 1, Hazardous (Classified) Locations, 2002. Revised August 2004 2006, Revised 2008. ANSI/UL 60079-11, Electrical Apparatus for Use in Class I, Zones 0, 1, & 2 Hazardous (Classified) Locations Intrinsic Safety i, 2009. Update referenced standard to most recent revision. 10