flammable and combustible liquids code committee · 2015. 8. 17. · flcops.2015-09 agenda.doc...

FLCOPS.2015-09 Agenda.doc

FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE COMMITTEE

MEMORANDUM

TO: NFPA 30 Technical Committee on Operations

FROM: Janna Shapiro

DATE: August 13, 2015

SUBJECT: Agenda for NFPA 30 First Draft Meeting September 10, 2015 — 8:00 AM to 12:00 PM

_________________________________________________________________________________ Ladies and Gentlemen: Attached is the Agenda for the NFPA 30, Flammable and Combustible Liquids Code, First Draft meeting of the NFPA 30 Technical Committee on Operations, to be held 8:00 AM to 12:00 PM, Thursday, September 10, 2015, at the Crowne Plaza Hotel, Austin TX. 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. rpb/ cc FLCC Meeting Folder FLCOPS/NM



MEMORANDUM

TO: NFPA 30 Technical Committee on Operations

FROM: R. P. Benedetti

DATE: August 13, 2015

SUBJECT: Agenda for NFPA 30 First Draft Meeting September 10, 2015 — 8:00 AM to 12:00 PM

_________________________________________________________________________________ Ladies and Gentlemen: Attached is the Agenda for the NFPA 30, Flammable and Combustible Liquids Code, First Draft meeting of the NFPA 30 Technical Committee on Operations, to be held 8:00 AM to 12:00 PM, Thursday, September 10, 2015, at the Crowne Plaza Hotel, Austin TX. 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. rpb/ cc FLCC Meeting Folder FLCOPS/NM



AGENDA — NFPA 30 First Draft Meeting

NFPA 30 Technical Committee on Operations

Crowne Plaza Hotel, Austin TX Thursday, September 10, 2015, 8:00 AM to 12:00 PM

1. Call to Order. 2. Introduction of Attendees. Update of Committee Roster. [Attachment № A1] 3. Approval of Minutes of Last Meeting. [June, 2013, San Antonio TX] [Attachment № A2] 4. Report of Committee Chair. 5. Report of Staff Liaison.

Technical Committee Scope. [See Attachment № A3 for Proposed New Scope] Technical Committee Membership Status. Document Revision Schedule for Annual 2014 Cycle. [Attachment № A4]

6. Member Reports on Current Issues. [As Necessary] 7. Review and Act on Public Inputs to Amend the 2015 edition of NFPA 30

[Attachment № A5 – Public Inputs to Chapters 17, 18, 19, and 29] [Attachment № A6 – Global Public Inputs: Low Pressure Containers; Reference Standards]

8. Old Business.

New Definitions – “Liquids in Process” and “Staged Liquids”

Revise 18.5.4 to Eliminate Conflict with Maximum Allowable Quantities. 9. New Business. [NONE] 10. Schedule Next Meeting(s). 11. Adjournment.

Address List No PhoneOperations FLC-OPS

Flammable and Combustible Liquids

Janna E. Shapiro08/06/2015

FLC-OPS

Peter J. Willse

ChairGlobal Asset Protection Services100 Constitution Plaza, 12th FloorHartford, CT 06103XL Global Asset Protection ServicesAlternate: Mark Driscoll

I 3/21/2006FLC-OPS

Claire V. De Taeye

PrincipalTravelers Insurance Company75 Town Centre DriveRochester, NY 14623Alternate: Timothy S. Murphy

I 10/4/2001

FLC-OPS

Douglas W. Fisher

PrincipalFisher Engineering, Inc.10475 Medlock Bridge Road, Suite 520Johns Creek, GA 30097-4437

SE 10/23/2013FLC-OPS

Harold E. Grossman II

PrincipalAlcoa, Inc.Warrick Operations4000 West State Route 66, Bldg. 05Newburgh, IN 47630

U 9/30/2004

FLC-OPS

Dwight H. Havens

PrincipalBechtel Marine Propulsion CorporationKnolls Atomic Power Laboratory20 Bellflower RoadMalta, NY 12020-4431

U 7/24/1997FLC-OPS

Richard J. Hild

PrincipalAxalta Coating Systems1003 Bogart CircleBel Air, MD 21014

M 10/1/1993

FLC-OPS

Jay J. Jablonski

PrincipalHSB PLC1 State Street, 9th FloorHartford, CT 06103-3199Alternate: David Upchurch

I 4/1/1996FLC-OPS

Alwin A Kelly

PrincipalJENSEN HUGHES3610 Commerce Dr Ste 817Baltimore, MD 21227Alternate: Joseph L. Scheffey

SE 08/11/2014

FLC-OPS

Todd M. Kidd

PrincipalLiberty Mutual Insurance Companies520 Mainsail RoadSalisbury, NC 28146-1402

I 08/11/2014FLC-OPS

David C. Kirby

PrincipalBaker Engineering & Risk Consultants, Inc.1560 Clearview HeightsCharleston, WV 25312Alternate: Duane L. Rehmeyer

SE 1/1/1991

FLC-OPS

Gregory D. Kirby

PrincipalCYTEC Industries, Inc.1 Heilman AvenueWillow Island, WV 26134

M 1/17/1997FLC-OPS

Richard S. Kraus

PrincipalAPI/Petroleum Safety Consultants210 East Fairfax Street, Apt. 600Falls Church, VA 22046-2909American Petroleum InstituteAlternate: Tim D. Blackford

M 10/1/1995

1

bbenedetti

Text Box

ATTACHMENT No. A1




FLC-OPS

John A. LeBlanc

PrincipalFM Global1151 Boston-Providence TurnpikePO Box 9102Norwood, MA 02062-9102Alternate: Christopher J. Wieczorek

I 10/10/1997FLC-OPS

Gregory A. Milewski

PrincipalShell Oil Company9018 Brook ShadowKingwood, TX 77345

M 1/14/2005

FLC-OPS

David P. Nugent

PrincipalGlobal Risk Consultants2037 Clover RoadNorthbrook, IL 60062-6422

SE 04/08/2015FLC-OPS

Leo T. Old

PrincipalEnsafe, Inc.5724 Summer Trees DriveMemphis, TN 38134

SE 10/28/2014

FLC-OPS

Anthony M. Ordile

PrincipalHaines Fire & Risk Consulting Corporation1 Linda Lane, Suite BSouthampton, NJ 08088Alternate: Stephen W. Haines

SE 10/1/1993FLC-OPS

Alfredo M. Ramirez

PrincipalUL LLC333 Pfingsten RoadNorthbrook, IL 60062-2096Alternate: Roland A. Riegel

RT 4/15/2004

FLC-OPS

Robert N. Renkes

PrincipalPetroleum Equipment Institute6514 East 69th StreetTulsa, OK 74133

M 1/1/1984FLC-OPS

John W. Richmond, Sr.

PrincipalEastman Chemical CompanyPO Box 511 (B-18)Kingsport, TN 37663

M 4/14/2005

FLC-OPS

Douglas A. Rivers

Principal3M CompanyCorporate Safety3M Center, Building 224-6W-28St. Paul, MN 55144-1000Alternate: Richard E. Stutzki

U 1/1/1991FLC-OPS

Ronald G. Schaffhauser

PrincipalPPG Industries, Inc.4325 Rosanna DriveAllison Park, PA 15101

M 1/15/2004

FLC-OPS

George A. Seuss, Jr.

PrincipalThe Hanover Insurance GroupVerlan Fire Insurance Company10480 Little Patuxent ParkwaySuite 500Columbia, MD 21044-3506

I 7/22/1999FLC-OPS

Clark D. Shepard

PrincipalExxonMobil CorporationResearch & Engineering3225 Gallows Road, Room 3A2111Fairfax, VA 22037Alternate: David W. Owen

M 7/12/2001

FLC-OPS

Glen E. Smith

PrincipalArgus Consulting, Inc.6363 College Boulevard, Suite 600Overland Park, KS 66211-1882American Railway Engineering & Maintenance-of-WayAssn.

U 10/23/2013FLC-OPS

Michael D. Snyder

PrincipalDow Corning Corporation2200 West Salzburg Road (Mail #544)Midland, MI 48686-0994NFPA Industrial Fire Protection SectionAlternate: Donald B. Hicks

U 7/28/2006

2




FLC-OPS

David B. Wechsler

Principal27706 Dalton Bluff CourtKaty, TX 77494American Chemistry Council

U 3/2/2010FLC-OPS

Tim D. Blackford

AlternateChevron Energy Technology Company1200 Smith Street, Room 31050Houston, TX 77002American Petroleum InstitutePrincipal: Richard S. Kraus

M 3/1/2011

FLC-OPS

Mark Driscoll

AlternateGlobal Asset Protection Services135 Highland Avenue, Unit 3Winthrop, MA 02152Principal: Peter J. Willse

I 10/23/2003FLC-OPS

Stephen W. Haines

AlternateHaines Fire & Risk Consulting Corp.1 Linda Lane, Suite BSouthampton, NJ 08088Principal: Anthony M. Ordile

SE 8/2/2010

FLC-OPS

Donald B. Hicks

AlternateDow Corning Corporation3901 South Saginaw RoadPO Box 995, Mail #60Midland, MI 48686-0995NFPA Industrial Fire Protection SectionPrincipal: Michael D. Snyder

U 4/14/2005FLC-OPS

Timothy S. Murphy

AlternateTravelers Insurance Company1000 Windward ConcourseAlpharetta, GA 30005-2052Principal: Claire V. De Taeye

I 03/03/2014

FLC-OPS

David W. Owen

AlternateExxonMobil CorporationResearch and Engineering2800 Decker Drive MOB 541Baytown, TX 77520Principal: Clark D. Shepard

M 7/12/2001FLC-OPS

Duane L. Rehmeyer

AlternateBaker Engineering & Risk Consultants, Inc.709 Highspire RoadGlenmore, PA 19343Principal: David C. Kirby

SE 8/2/2010

FLC-OPS

Roland A. Riegel

AlternateUL LLC1285 Walt Whitman RoadMelville, NY 11747-3085Principal: Alfredo M. Ramirez

RT 4/15/2004FLC-OPS

Joseph L. Scheffey

AlternateJENSEN HUGHES3610 Commerce Drive, Suite 817Baltimore, MD 21227-1652Principal: Alwin A Kelly

SE 1/10/2002

FLC-OPS

Richard E. Stutzki

Alternate3M Company22614 Route 84 NorthCordova, IL 61242-9779Principal: Douglas A. Rivers

U 10/29/2012FLC-OPS

David Upchurch

AlternateHSB PLCPO Box 1088Cornelia, GA 30531Principal: Jay J. Jablonski

I 10/29/2012

3




FLC-OPS

Christopher J. Wieczorek

AlternateFM Global1151 Boston-Providence TurnpikePO Box 9102Norwood, MA 02062-9102Principal: John A. LeBlanc

I 1/14/2005FLC-OPS

William R. Hamilton

Nonvoting MemberUS Department of LaborOccupational Safety & Health Administration200 Constitution Ave. NW, Room N3609Washington, DC 20210Alternate: Matthew I. Chibbaro

E 3/4/2009

FLC-OPS

Matthew I. Chibbaro

Alt. to Nonvoting MemberUS Department of LaborOccupational Safety & Health Administration200 Constitution Ave. NW, Room N3609Washington, DC 20210Principal: William R. Hamilton

E 4/15/2004FLC-OPS

Jack Woycheese

Member Emeritus1649 Constable StreetPrescott, AZ 86301

SE 1/1/1991

FLC-OPS

Janna E. Shapiro

Staff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169-7471

08/04/2015

4

FLCOPS.2013-06 Minutes.doc


Minutes of NFPA 30 Second Draft Meeting


Doubletree Hotel – San Antonio Downtown San Antonio TX

Wednesday, June 19, 2013

I. Participation T. D. Blackford, Chevron Energy Technology Company (Alternate to R. Kraus)

C. V. De Taeye, Travelers Insurance Company J. J. Foley, The RJA Group, Inc. (Alternate to J. Eisenberg) D. H. Havens, Bechtel Marine Propulsion Corp. / Knowles Atomic Power Laboratory, CHAIR R. J. Hild, DuPont Performance Coatings J. J. Jablonski, HSB PLC D. C. Kirby, Baker Engineering & Risk Consultants, Inc. G. D. Kirby, CYTEC Industries, Inc. R. S. Kraus, PSC Petroleum Safety Consultants (Rep. American Petroleum Institute) J. A. LeBlanc, FM Global J. P. Levin, Liberty Mutual Commercial Markets (Rep. Property Casualty Insurers Association of America) R. A. Riegel, UL LLC (Alternate to A. Ramirez) D. A. Rivers, 3M Company J. L. Scheffey, Hughes Associates, Inc. (Alternate to J. Woycheese) G. A. Seuss, Jr., Hanover Insurance Group / Verlan Fire Insurance Company R. E. Stutzki, 3M Company (Alternate to D. Rivers) B. Tate, Office of the Fire Marshal – Ontario S. M. Tyler, AREVA NP, Inc. (Rep. Edison Electric Institute) D. B. Wechsler, American Chemistry Council C. J. Wieczorek, FM Global (Alternate to J. LeBlanc) J. Woycheese, Hughes Associates, Inc. R. P. Benedetti, National Fire Protection Association, STAFF LIAISON GUESTS: S. Ayers, U. S. Consumer Product Safety Commission

(Non-Voting Member – NFPA 30 Correlating Committee) G. Brennecke, Liberty Mutual (NFPA 30 Technical Committee on Fundamentals)

A. Burke, Restaurant Technologies, Inc. B. Schoenbauer, Restaurant Technologies, Inc. W. Stocker, Safeway, Inc. (NFPA 30 Technical Committee on Fundamentals) J. Wanko, U. S. Occupational Safety and Health Administration (NFPA 30 Technical Committee on Fundamentals) Members Not in Attendance

G. P. Bareta, Wisconsin Department of Commerce

bbenedetti

Text Box

ATTACHMENT No. A2


M. I. Chibbaro, U. S. Occupational Safety and Health Administration (Alternate to W. Hamilton) M. Driscoll, XL Global Asset Protection Services (Alternate to P. Willse) J. M. Eisenberg, The RJA Group, Inc. H. E. Grossman II, Alcoa, Inc. D. R. Hague, Liberty Mutual Insurance (Alternate to J. Levin) (Rep. Property Casualty Insurers Association of America) S. W. Haines, Haines Fire & Risk Consulting Corporation (Alternate to A. Ordile) W. R. Hamilton, U. S. Occupational Safety and Health Administration D. B. Hicks, Dow Corning Corporation (Alternate to M. Snyder)

(Rep. NFPA Industrial Fire Protection Section) G. A. Milewski, Shell Oil A. M. Ordile, Haines Fire & Risk Consulting Corporation D. W. Owen, ExxonMobil Corporation (Alternate to C. Shepard) A. M. Ramirez, UL LLC D. L. Rehmeyer, Baker Engineering & Risk Consultants, Inc. (Alternate to D. Kirby) R. N. Renkes, Petroleum Equipment Institute J. W. Richmond, Sr., Eastman Chemical Company R. G. Schaffhauser, PPG Industries, Inc. C. D. Shepard, ExxonMobil Corporation M. D. Snyder, Dow Corning Corporation (Rep. NFPA Industrial Fire Protection Section) D. Upchurch, HSB Professional Loss Control (Alternate to J. Jablonski) P. J. G. Willse, XL Global Asset Protection Services, CHAIR II. Minutes 1. The meeting was called to order at 1:00 PM on Wednesday, June 19, 2013 by Technical Committee

Chair Peter Willse. 2. Attendees introduced themselves. The Technical Committee roster was corrected as needed.

An updated roster will be posted on the Technical Committee’s web page. 3. The Minutes of the previous meeting (August 2012, NFPA, Quincy MA) were unanimously approved

as issued. 4. The Technical Committee Chair welcomed attendees and reviewed the Agenda. 5. The Staff Liaison reported on the following:

Technical Committee Scope Statement. The Technical Committee agreed to the need for a revised scope that accurately reflects the Technical Committee’s responsibilities. The Staff Liaison was directed to develop a revised scope statement for the committee’s review.

Membership Status. The Staff Liaison reported on recent changes to committee membership and on the balance of interests on the committees. At this time, there is no balance issue.

Document Revision Schedule for NFPA 30-2012. The Staff Liaison reviewed the Annual 2014 revision schedule for the 2015 edition of NFPA 30.

6. There were no reports on current issues. 7. The Technical Committee reviewed and acted on all public comments to their First Draft report on

NFPA 30. 8. There was no correspondence requiring the Technical Committee’s attention. 9. There was no old business requiring the Technical Committee’s attention. 11. The Technical Committee discussed the following new business items:

Chapter 18. There needs to be definitions for “liquid(s) in process” and “staged liquids”. There also needs to be changes made to incidental quantities to reflect correlation with MAQs in Table 9.6.1.


Guidance on Fire Protection for Process Areas. Need for a Task Group to study this and to propose appropriate language in the Annex.

Next Revision Cycle for NFPA 30. The Technical Committee discussed whether it was practical to use fire point instead of flash point to classify liquids. The Technical Committee determined that fire point appears to be no better nor worse than flash point and decided not to pursue.

12. The Technical Committee deferred action on scheduling future meetings. 13. The meeting adjourned at 6:00 PM, Wednesday, June 19, 2013.


This Committee shall have primary responsibility for documents or portions of documents on safeguarding against the fire and explosion hazards associated with operations that involve the handling, use, dispensing, and transfer of flammable and combustible liquids, either as a principal activity or as an activity that is incidental to other activities. This Committee shall also have primary responsibility for documents or portions of documents on safeguarding against the fire and explosion hazards associated with specific operations that involve the handling, use, dispensing, and transfer of flammable and combustible liquids. Responsible for Chapters 17 through 20, 28, and 29 and Annex F of NFPA 30, Flammable and Combustible Liquids Code.

bbenedetti

Text Box

ATTACHMENT No. A3

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 forTC 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 received no Comments)

5/30/16 5/30/16

Appeal Closing Date for Consent Standards (Standards that received no Comments)

6/13/16 6/13/16

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 Standards

4/17/17 4/17/17

(& 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________________________

bbenedetti

Text Box

ATTACHMENT No. A4

Public Input No. 49-NFPA 30-2015 [ Section No. 17.3.7 ]

17.3.7

When a process heats a liquid to a temperature at or above its flashpoint, the following shall apply:

(1) The process vessel shall be maintained closed during processing to prevent release of vapors to the roomin which it is located and vented to the outside of the building.

(2) If the vessel needs to be opened to add ingredients, the room ventilation shall meet the requirements ofSection 17.11 and the process heating controls will be interlocked with the ventilation such that the processheat will shut down if the ventilation fails or is turned off.

(3) The process vessel shall be equipped with an excess temperature control set to limit excessive heating of theliquid and the subsequent release of vapors.

(4) If a heat transfer medium is used to heat the liquid and the heat transfer fluid can heat the liquid to its boilingpoint on failure of the process and excess temperature heat controls, a redundant excess temperature controlshall be provided.

Statement of Problem and Substantiation for Public Input

provides specific requirements and clarification

Submitter Information Verification

Submitter Full Name: RICHARD KRAUS

Organization: APIPETROLEUM SAFETY CONSULTAN

Street Address:

City:

State:

Zip:

Submittal Date: Mon Jun 22 11:37:36 EDT 2015

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetche...

43 of 86 8/13/2015 2:39 PM

Public Input No. 50-NFPA 30-2015 [ Section No. 17.10 ]

17.10 Containment, Drainage, and Spill Control.

17.10. 1 2 *

Emergency drainage systems shall be provided to direct liquid leakage and fire protection water to a safe location.

17.10. 2 3

Emergency drainage systems, if connected to public sewers or discharged into public waterways, shall beequipped with traps or separators.

17.10. 3 1

A facility shall be designed and operated to prevent the discharge of liquids to public waterways, public sewers, oradjoining property.


renumber in logical order




Street Address:

City:

State:

Zip:



44 of 86 8/13/2015 2:39 PM

Public Input No. 90-NFPA 30-2015 [ Section No. 18.4.4 [Excluding any Sub-Sections] ]

Transfer of liquids among vessels, containers, tanks, and piping systems by means of air or inert gas pressure shallbe permitted only under all of the following conditions:

(1) The vessels, containers, tanks, and piping systems shall be designed for such pressurized transfer and shallbe capable of withstanding the anticipated operating pressure.

(2) Safety and operating controls, including pressure-relief devices, shall be provided to prevent overpressure ofany part of the system.

(3) Only inert gas shall be used to transfer Class I liquids. Only inert gas shall be used to transfer Class II andClass III liquids that are heated above their flash points.

(4) When using a diaphragm pump, transfers of Class I liquids shall be accomplished with the followingcontrols:

(a). The diaphragm pump shall be driven with an inert gas.

(b). The diaphragm pump exhaust shall be vented to an appropriate outdoor location to preventasphyxiation exposure.

(c). The diaphragm pump exhaust shall be directed to an appropriate containment location to addressliquid discharge arising from a diaphragm failure. The area surrounding the exhaust vent shall be electricallyclassified for the fluid being transferred.


Section 18.4.4.1 makes reference to scenarios where air may be used to transfer Class I liquids. This allowance has been interpreted to allow the use of air as a motive force for diaphragm pumps transferring flammable liquids.

When a diaphragm develops a leak or failure, several situations may occur, including injection of the motive force (potentially air) into the fluid discharge stream or an uncontained flammable liquid leak being issued from the diaphragm pump vent. This public input is structured to properly manage the risk of diaphragm failure while transferring Class I liquid.

Since inert motive gas is proposed, the management of asphyxiation risk from the pump exhaust discharge is also proposed.


Submitter Full Name: MICHAEL SNYDER

Organization: Dow Corning Corporation

Street Address:

City:

State:

Zip:

Submittal Date: Mon Jul 06 09:02:02 EDT 2015


45 of 86 8/13/2015 2:39 PM

Public Input No. 92-NFPA 30-2015 [ Section No. 18.5.4.1 ]

18.5.4.1

The maximum quantity of liquids permitted for incidental operations in a single fire area shall not exceed thegreater of the following:

(1)

(2) The aggregate sum of the following:

(3) 25 gal (95 L) of Class IA liquids in containers

(4) 120 gal (454 L) of Class IB, Class IC, Class II, or Class III liquids in containers

(5) 1585 gal (6000 L) of any combination of the following:

(6) Class IB, IC, II, or IIIA liquids in metal portable tanks or metal intermediate bulk containers, eachnot exceeding 793 gal (3000 L)

(7) Class II or Class IIIA liquids in nonmetallic intermediate bulk containers that have beensubjected to a standard fire test that demonstrates acceptable inside storage fire perfromance andshall be listed and labeled , each not exceeding 793 gal (3000 L)

(8) 20 portable tanks or intermediate bulk containers each not exceeding 793 gal (3000 L) of Class IIIBliquids

Additional Proposed Changes

File Name Description Approved

T29_Composite_IBCs_-_Slide_20_from_2015_NFPA_Conference.pdf T29 Compostie IBCs Slide


Non-listed Composite IBCs (Rigid nonmetallic intermediate bulk containers) that contain hydrocarbon liquids have been shown in laboratory testing to fail between 1 minute 12 second and 1 minute 56 seconds following fire exposure, and in large scale fire testing in the range of 2 minutes 30 seconds (UK HSE, 2007; Wieczorek & Yee, 2008). The catastrophic loss of hydrocarbon liquid creates an exposure pool fire in excess of 3000 square feet and can result in instantaneous heat release rates in excess of 588 Megawatts (George & Snyder, 2015). The subsequent exposure of other non-listed composite IBCs results in a rapidly expanding fire with catastrophic results (Fire Protection Research Foundation, 2014)

At present, the allowances for maximum quantity of liquids permitted for incidental operations in a single fire area are inadequate to manage the life safety and property risk presented by the rapidly released fuel load from non-listed composite IBCs involved in fire.

To adequately manage this risk, this public input is framed to do the following:

1. Require that any Rigid Plastic IBCs (UN 31H1 or 31H2) and Composite IBCs with rigid inner receptacle (UN31HZ1) for allowed in Section 18.5.4.1(1)(c)(ii) of Class II and IIIA liquids be shall be subjected to a standard fire test that demonstrates acceptable inside storage fire performance and shall be listed and labeled.

References:

UK Health & Safety Executive. (2007). Fire performance of composite IBCs. Norwich, England: accessed from http://www.hse.gov.uk/research/rrpdf/rr564.pdf

Wieczorek, C.J. & Yee, G.G.; (2008). Fluid Compatibility with Intermediate Bulk Containers; FM Global

George, T. & Snyder M; (2015). Managing Fire Risks of Composite Intermediate Bulk Containers (CIBCs): Understanding Challenges & Fire Code Requirements. 2015 NFPA Conference & Expo Technical Presentation T29; Slide 20.

Fire Protection Research Foundation; The fire risk of Intermediate Bulk Containers (IBCs). (2014). Retrieved July 4, 2015, from http://www.nfpa.org/ibc

* The amount required to supply incidental operations for one continuous 24-hour period


46 of 86 8/13/2015 2:39 PM

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 76-NFPA 30-2015 [Section No. 9.4.3[Excluding any Sub-Sections]]

Identical risk control issues for non-listed Composite IBCsin Class II and IIIA liquid service.


Submitter Full Name: MICHAEL SNYDER

Organization: Dow Corning Corporation

Street Address:

City:

State:

Zip:

Submittal Date: Mon Jul 06 09:17:10 EDT 2015


47 of 86 8/13/2015 2:39 PM

•P

oo

l Fir

es a

re t

he

enem

y!

•C

on

sid

er a

275

gal

lon

CIB

C o

f L

ub

e O

il:

20CIBCS–M

ITIGATIONST

RATEGY 83

BTU

/sec

to694 BTU

/sec

300,000 BTU

/hto

2,500,000 BTU

/h

Typical Package

Boiler

Depth of spill

0.125 in.

0.25 in.

0.5 in.

1 in.

Area of spill

3,529 sq.ft.

1,765 sq.ft.

882 sq.ft.

441 sq.ft.

557,480 BTU

/sec278,808 BTU

/sec139,221 BTU

/sec69,221 BTU

/sec

588 MW

294 MW

147 MW

73 MW

Duration

1.03 min

2.06 min

4.13 min

8.25 min

Flam

e Height*

69 ft

54 ft

43 ft

34 ft

# of Package

Boilers**

803 boilers

401 boilers

200 boilers

100 boilers

Heat Release

*M

etho

d of

Tho

mas

-R

efer

ence

: SF

PE H

andb

ook

of F

ire

Prot

ectio

n En

gine

erin

g, 2

nd E

ditio

n, 1

995,

Pag

e 3-

204.

**A

ssum

ing

2,50

0,00

0 B

TU/h

rB

oile

r

Public Input No. 51-NFPA 30-2015 [ New Section after 19.2.1 ]

TITLE OF NEW CONTENT

A 19.2.1 Used or waste.cooking oil shall not be contaminated with lowwer classification liquids. ..


provides that class IIIB waste or used oil covered by the chapter is not degraded to a lower classification




Street Address:

City:

State:

Zip:



48 of 86 8/13/2015 2:39 PM

Public Input No. 35-NFPA 30-2015 [ Section No. 19.7 ]

19.7 Cooking Oil Storage Tank Systems in Commercial Kitchens.

19.7.1 Scope.

19.7.1.1

This section shall apply to storage tank systems for cooking oil, as defined in 19.2.1, located in commercialkitchens where tank capacities are greater than 60 gal (227 L).

19.7.1.2

This section shall apply to both fresh and waste cooking oil storage tank systems.

19.7.1.3*

Where there are conflicts between the requirements of this section and requirements of other sections of this code,the requirements of this section shall take precedence.

19.7.2 Design and Construction of Cooking Oil Storage Tanks.

19.7.2.1 Materials of Construction.

Tanks shall be of metallic or nonmetallic construction.

19.7.2.1.1

Tanks and their appurtenances shall be constructed of materials compatible with cooking oil.

19.7.2.1.2*

For tanks storing waste cooking oil, the tanks and their appurtenances shall be constructed of materials compatiblewith cooking oil at a minimum temperature of 140°F (60°C) continuous and 235°F (113°C) intermittent.

19.7.2.2 Design Standards.

19.7.2.2.1*

Metallic cooking oil storage tanks shall be listed in accordance with ANSI/UL 142, Standard for Steel AbovegroundTanks for Flammable and Combustible Liquids, or ANSI/UL 80, Standard for Steel Tanks for Oil-Burner Fuels andOther Combustible Liquids.

19.7.2.2.2

Nonmetallic cooking oil storage tanks shall meet the following requirements:

(1) Tanks shall be listed for use with cooking oil, unless otherwise approved.

(2) Tanks shall not exceed 200 gal (757 L) per tank.

19.7.2.3 Normal Venting.

19.7.2.3.1

The normal vent(s) shall be located above the maximum normal liquid level.

19.7.2.3.2

The normal vent shall be at least as large as the largest filling or withdrawal connection.

19.7.2.3.3

Where used, normal vents, including vent piping, that are smaller than 1.25 in. (32 mm) nominal inside diametershall be tested to verify that internal tank pressures will remain below a gauge pressure of 0.5 psi (3.5 kPa) undermaximum expected flow rates for tank filling and withdrawal. These tests shall be permitted to be conducted by aqualified outside agency or by the manufacturer, if certified by a qualified observer.

19.7.2.3.4*

Normal vents shall be permitted to discharge inside the building.

19.7.2.4 Emergency Venting.

19.7.2.4.1

Cooking oil storage tanks shall be provided with emergency relief venting in accordance with Chapter 22.

19.7.2.4.2

For nonmetallic cooking oil storage tanks, emergency relief venting by form of construction shall be permitted. Thisshall include the low melting point of the material of construction of the tank.

19.7.2.4.3

For metallic cooking oil storage tanks, emergency relief venting by form of construction shall be prohibited.

19.7.2.4.4

Emergency vents shall be permitted to discharge inside the building.


49 of 86 8/13/2015 2:39 PM

19.7.2.5* Prevention of Overfilling of Cooking Oil Storage Tanks.

Every cooking oil storage tank shall be provided with means to prevent an accidental overfill. Such means shall beautomatic and fail-safe in nature. (This requirement seems to overstep the NFPA and adds additional costs thatwhen used with cooking oil, in a short time clogs and sticks requiring regular maintenance. Lights, alarms, visuallevel indicators should be acceptable alternatives to perevent accidental overfills.)

19.7.2.6 Tank Heating.

19.7.2.6.1*

Electrical equipment used for heating cooking oil shall be listed to ANSI/UL 499, Standard for Electrical HeatingAppliances, and shall comply with NFPA 70, National Electrical Code.

19.7.2.6.2*

Electrical equipment used for heating cooking oil shall comply with NFPA 70, National Electrical Code, and shall beequipped with automatic means to limit the temperature of the oil to less than 140°F (60°C).

19.7.2.6.3

Use of electrical immersion heaters in nonmetallic tanks shall be prohibited. (Unneccesary, if 19.7.2.6.1 and19.7.2.6.2 can be met with an immersion heater, then immersion heaters should be permitted.)

19.7.3 Tank Installation and Testing.

19.7.3.1 Location of Cooking Oil Storage Tanks.

Tanks shall be installed in locations appropriate for storage of foodstuffs or inventory and shall not be installed inareas designated as cooking areas.

19.7.3.1.1*

Tanks shall be spaced at least 3 ft (0.9 m) away from any cooking appliance or any surface heated to atemperature above 140°F (60°C) continuous and at least 6 ft (1.8 m) away from any open flame.

19.7.3.1.2*

Tanks shall not be installed under commercial kitchen ventilation hoods.

19.7.3.1.3

Tanks shall not be required to be separated from one another.

19.7.3.2 Foundations for and Anchoring of Cooking Oil Storage Tanks.

19.7.3.2.1

Tank supports shall be secured to the tank and to the floor, ceiling or wall to prevent the tank from tipping over. Fora flat-bottom tank resting directly on the floor, the tank shall be secured to the floor, ceiling or wall to prevent thetank from tipping over.

19.7.3.2.2

In areas subject to earthquakes, tank supports, the foundation, and anchoring shall meet the requirements of theapplicable building code for the specific seismic zone. Engineering evaluation by a qualified, impartial outsideagency shall be an acceptable method of meeting this requirement.

19.7.3.2.3

Where a tank is located in areas subject to flooding, the method for anchoring the tank to the floor shall be capableof preventing the tank, either full or empty, from floating during a rise in water level up to the established maximumflood stage. Engineering evaluation by a qualified, impartial outside agency shall be an acceptable method ofmeeting this requirement.

19.7.3.3 Tank Openings Other than Vents.

19.7.3.3.1

Each connection to the tank below the normal liquid level through which liquid can normally flow shall be providedwith an internal or external valve located as close as possible to the shell of the tank, in accordance with Chapter22.

19.7.3.3.2*

Connections to the tank above the normal liquid level through which liquid can normally flow shall not be requiredto have a valve, provided there exists a liquidtight closure at the opposite end of the line. The liquidtight closureshall be in the form of a valve, a plug, or a coupling or fitting with positive shutoff.

19.7.3.4 Field Testing.

19.7.3.4.1*

As an alternate method to the testing requirements in Chapter 21, cooking oil storage tanks shall be tested forleaks at the time of installation by filling the tank with cooking oil to a liquid level above the highest tank seam orconnection within the normal liquid level. Before the tank is placed in service, all leaks shall be corrected in anapproved manner or the tank shall be replaced.

19.7.3.4.2

An approved listing mark on a cooking oil storage tank shall be considered to be evidence of compliance with tanktesting requirements.

19.7.4 Fire Protection for Cooking Oil Storage Tanks.


50 of 86 8/13/2015 2:39 PM

19.7.4.1 Identification for Emergency Responders.

A sign or marking that meets the requirements ofNFPA 704, Standard System for the Identification of the Hazardsof Materials for Emergency Response, or another approved system, shall be applied to each cooking oil storagetank in accordance with Chapter 21. Additional signage shall be applied to each tank identifying the contents of thetank as cooking oil, either fresh or waste.

19.7.4.2*

In areas where tanks are located, no additional ventilation shall be required beyond that necessary for comfortventilation, provided that all cooking equipment is equipped with exhaust systems in accordance with NFPA 96,Standard for Ventilation Control and Fire Protection of Commercial Cooking Operations.

19.7.4.3

If ventilation is not provided as specified in 19.7.4.2, then the tank shall be vented to another room inside thebuilding that meets these requirements, or the tank shall be vented to the outside of the building.

19.7.5 Transfer Lines.

19.7.5.1* Design and Construction of Fresh Cooking Oil Transfer Lines.

Transfer lines for fresh cooking oil shall be permitted to be constructed of metallic or nonmetallic materials that arecompatible with cooking oil and food products. Nonmetallic transfer lines shall also meet the followingrequirements:

(1) Transfer lines in pressure applications shall be rated for a working gauge pressure of 100 psi (689 kPa) at70°F (21°C) or the maximum output pressure of the transfer pump, whichever is higher.

(2) Transfer lines in suction applications shall be rated for full vacuum at 70°F (21°C).

(3) Transfer lines shall be rated for temperatures up to 120°F (49°C) continuous.

(4) The maximum nominal inside diameter shall be no larger than 1.25 in. (32 mm).

(5) Leakage shall be controlled through the use of check valves or antisiphon valves at points where the linesconnect to the fresh oil tank.

19.7.5.2* Design and Construction of Waste Cooking Oil Transfer Lines.

Waste cooking oil transfer lines shall be permitted to be constructed of metallic or nonmetallic materials that arecompatible with cooking oil.

19.7.5.2.1

Transfer lines shall be rated for use with cooking oil at elevated temperatures of 275°F (135°C) continuous and350°F (177°C) intermittent.

19.7.5.2.2

Nonmetallic transfer lines shall be rated for working pressures up to 250 psi (1724 kPa) at 275°F (135°C).

19.7.5.3 Flow Control.

Cooking oil transfer lines shall be equipped with means to prevent unintended transfer or dispensing of cooking oil.These means shall be permitted to be in the form of momentary control switches, valves, check valves, antisiphonvalves, plugs, couplings, fittings, or any combination thereof that are fail-safe in nature.

19.7.5.4 Pressure Control.

Pumping systems used to transfer cooking oil shall have means to prevent overpressurization of transfer lines.These means shall be in the form of relief valves, bypass valves, pressure sensor devices, or the pressurelimitation of the pump itself.

19.7.5.5 Installation of Cooking Oil Transfer Lines in Plenum-Rated Spaces.

Cooking oil transfer lines installed in plenum-rated spaces shall be enclosed in noncombustible raceways orenclosures, or shall be covered with a material listed and labeled for installation within a plenum.

19.7.5.6 Testing of Cooking Oil Transfer Lines.

Cooking oil transfer lines shall be tested after installation and prior to use. Testing shall be with cooking oil at thenormal operating pressures. Any leaks discovered in transfer lines as a result of testing shall be repaired or thetransfer lines replaced prior to placing the transfer lines into service.


My company has been installing tanks for many years. I believe you have taken one company's perspective and the parameters seem to fit their containment system design.

I made three suggested changes;. .1. This is really not an NFPA issue, but a housekeeping issue. Less expensive options exist, I have suggested several that would put the control in the hands of the location management. 2. Immersion heaters that meet the prior two points should be acceptable, 19.7.2.6.3 is unnecessary. 3. These systems are not prone to tip any more than a hot water heater connected to fixed piping would tip. If this requirement stays in place, options exist that are were not taken into account, Ceiling or wall supports should also be


51 of 86 8/13/2015 2:39 PM

acceptable to prevent a tip over.


Submitter Full Name: Richard Sabol

Organization: Mahoney Environmental

Street Address:

City:

State:

Zip:

Submittal Date: Thu Jun 11 15:29:16 EDT 2015


52 of 86 8/13/2015 2:39 PM


19.7.2.2 Listing Requirements and Design Standards.

19.7.2.2.1 *

Metallic cooking oil storage tanks shall be listed in accordance with ANSI/UL 142, Standard for Steel AbovegroundTanks for Flammable and Combustible Liquids, or ANSI/UL 80, Standard for Steel Tanks for Oil-Burner Fuels andOther Combustible Liquids.

19.7.2.2.2

Nonmetallic cooking oil storage tanks shall meet the following requirements:Tanks shall be listed for use withcooking oil, unless otherwise approved.Tanks in accordance with UL 2152 Outline of Investigation for SpecialPurpose Nonmetallic Containers & Tanks for Specific Combustible or Noncombustible Liquids. Nonmetallictanks shall not exceed 200 gal (757 L) per tank.


The UL 2152 Outline of Investigation was developed to evaluate the construction and performance of nonmetallic tanks for the storage of new and waste cooking oil. As a convenience to code users this proposal requires nonmetallic tanks to be listed to UL 2152, and removes corresponding construction and performance requirements from the code that are difficult if not impossible for designers and code enforcers to determine compliance. Marking and instruction requirements in UL 2152 reflect many of the installation requirements included in Section 19.7. UL 2152 production line test requirements verify compliance with Section 19.7.3.4.2 .


Submitter Full Name: RONALD FARR

Organization: UL LLC

Street Address:

City:

State:

Zip:

Submittal Date: Thu Jul 02 13:50:58 EDT 2015


53 of 86 8/13/2015 2:39 PM


29.3.28.4

Where no fire water main is provided, at least two 150 lb (68 kg) wheeled dry chemical extinguishers with ratingsof 240-B:C shall be provided. The extinguishers shall be located within 50 ft (15 m) of pump or manifold areas andshall be easily reached along emergency access paths.


A 150 lb dry chemical extinguisher has a rating of 240-B:C. The rating relates to the fire fighting capacity of the extinguisher. Referring to the rating rather than weight will ensure that an appropriate extinguisher is installed.


Submitter Full Name: Jennifer Boyle

Organization: Fred B. Goodnight, Amerex Corporation

Affilliation: Fire Equipment Manufacturers Association

Street Address:

City:

State:

Zip:

Submittal Date: Fri May 22 09:27:34 EDT 2015


68 of 86 8/13/2015 2:39 PM

Public Input No. 25-NFPA 30-2015 [ Section No. A.29.3.28 ]

A.29.3.28

Because of the many variables involved, exact requirements cannot be provided. However, Table A.29.3.28provides guidance on the level of fire protection typically provided at wharves and marine terminals handlingflammable liquids.

Table A.29.3.28 Typical Fire Protection for Wharves and Marine Terminals

Locations

WaterDemand

(gpm)

Hydrant

Monitorsa

(gpm)HoseReels

FireExtinguisher

DryChemical

InternationalShore

Connection

EmergencyEquipment

Lockers

Monitorsand Hose

FoamConcentrate

Required(gal)

Fire BoatConnection

30lb

150 lb120-B:C

240-B:CWheeled

Bargeterminals

500–1000 Two 500Two 1

1⁄42 NR NR 1 100b NR

Tankers20,000 DWTand under

1000–2000 Two 500Two 1

1⁄42 1 1 1 300b 2

20,001–70,000DWT

2000 Two 1000Four 1

1⁄4 c 2 2d 2 1 2000 2

70,001 DWTand over 2000e Two 1000

Four 11⁄4 c 3 2d 2 1 2000f 2

Sea islands 2000–4000e Three 1000Four 1

1⁄4 c 4 2 3 2 3000 2

For SI units, 1 gpm = 3.8 L/min; 1 gal = 3.8 L; 1 lb = 0.45 kg.

NR: Not required.

aA minimum of two 1 1⁄2 in. (38 mm) hydrant outlets should be provided at each monitor riser.

bCan be provided by onshore mobile equipment.

cOne hose reel at each berth should have foam capability.

dThe proximity of adjacent berths can reduce total required.

eUnder-dock systems are optional. Add water for under-dock system (0.16 × area).

fUnder-dock systems are optional. Add foam for under-dock system (0.16 × 0.3 × 30 × area).


A 30 lb dry chemical extinguisher is rated 120-B:C. A 150 lb wheeled extinguisher is rated 240-B:C. The ratings refer to the fire fighting capacity of the extinguisher. Using extinguisher ratings will ensure that the appropriate extinguishers are installed.


Submitter Full Name: Jennifer Boyle

Organization: Fred B. Goodnight, Amerex Corporation

Affilliation: Fire Equipment Manufacturers Association

Street Address:

City:

State:

Zip:

Submittal Date: Fri May 22 09:44:20 EDT 2015


72 of 86 8/13/2015 2:39 PM

bbenedetti

Text Box

ATTACHMENT No. A5

Public Input No. 21-NFPA 30-2015 [ Global Input ]

This Global Public Comment is a follow-up to Global Public Input No. 50 and a l l linkedPublic Inputs submitted to the First Draft, which proposed a change of containers from"containers, portable tanks, and intermediate bulk containers" to "containers, low pressurecylinders, portable tanks, and intermediate bulk containers". This simply added thedesignation of a 'low pressure cylinder' to the list of containers that were covered by NFPA30.

The NFPA 30 Technical Committee was unsure whether this new designation of products should belisted in NFPA 30, NFPA 30B, NFPA 58, or a new section altogether. Due to only limited testingprovided, it was decided that an intercommittee Task Group including members of NFPA 30, 30B,and 58 would determine the appropriate means to address this issue and make recommendationsto the NFPA Standards Council. The test data supplied to NFPA was generated by

3rd parties (Intertek Group plc in conjunction with the University of Colorado) under contract by 3M.

Since the Technical Committee met to discuss the First Draft, new DOT legislation has beenapproved and put into place as of January 7, 2013 (See attached "Federal Register Vol. 78 No. 4").Approved by the US DOT's Pipeline and Hazardous Materials Safety Administration (PHMSA), thischange echoes the changes in UN Classification on 'Chemical under pressure'. In the updatedFederal Register, the Hazardous Materials Table (HMT) has been updated to include sixspecifications of "Chemical under pressure": UN3500-UN3505.

In the Register, PHMSA claims "The 'Chemical under pressure, n.o.s.' HMT entries are added toaddress shipments of liquids or solids (e.g. adhesives, coatings, and cleaners) combined with a gasor gas mixtures utilized to expel the contents from pressure vessels." Special Provision 362, whichstates that "classification of these materials is to be based on hazard characteristics of thecomponents in the propellant, the liquid, or the solid forms", was amended to include the six newUN numbers that specify "Chemical under pressure".

Furthermore, Special Provision TP40 and T50 provide more detailed instruction for correcttransportation of "Chemical under pressure" in various circumstances.

Along with this new support, all claims made in Global Public Input No. 50 should be considered aswell.

Attached to this Global Public Comment is the Updated Federal Register as well as a list of thePublic Inputs submitted to the First Draft Report that this Global Public Comment affects; asummary of results generated by 3rd party tests have been attached (video was unable to attach tothis Public Comment; however, this video is now a public document following the First DraftReport).

It is recommended that any change pertaining to this Public Comment be applied to all past PublicInputs.



NFPA_30_SWC_PC_16_Rejected_But_Held_to_be_emulated.pdf Public Comment #16.

DOT_PHMSA_Federal_Register_Vol_78_No_4.pdf DOT PHMSA Federal Register

Michael_Jacobs_3M_First_Draft_Public_Input_List_Held.pdf Public Input List

3M_Cylinder_Testing_Report.pdfTest report for 3rd party testing on low pressure cylinders.


NOTE: The following Public Input appeared as "Reject but Hold" in Public Comment No. 16 of the A2014 Second Draft Report for NFPA 30 and per the Regs. at 4.4.8.3.1.

Classifying flammable liquids under low pressure.


Submitter Full Name: TC ON FLC-SWC

Organization: NFPA


1 of 86 8/13/2015 2:39 PM

bbenedetti

Text Box

ATTACHMENT No. A6

Street Address:

City:

State:

Zip:

Submittal Date: Thu Apr 09 11:29:08 EDT 2015


2 of 86 8/13/2015 2:39 PM

Public Comment No. 16-NFPA 30-2013 [ Global Input ]

This Global Public Comment is a follow-up to Global Public Input No. 50 and all linked Public Inputs submitted to the First Draft, which propsed a change of containers from "containers, portable tanks, and intermediate bulk containers" to "containers, low pressure cylinders, portable tanks, and intermediate bulk containers". This simply added the designation of a 'low pressure cylinder' to the list of containers that were covered by NFPA 30.

The NFPA 30 Technical Committee was unsure whether this new designation of products should be listed in NFPA 30, NFPA 30B, NFPA 58, or a new section altogether. Due to only limited testing provided, it was decided that an inter-committee Task Group including members of NFPA 30, 30B, and 58 would determine the appropriate means to address this issue and make recommendations to the NFPA Standards Council. The test data supplied to NFPA was generated by 3rd parties (Intertek Group plc in conjunction with the University of Colorado) under contract by 3M.

Since the Technical Committee met to discuss the First Draft, new DOT legislation has been approved and put into place as of January 7, 2013 (See attached "Federal Register Vol. 78 No. 4"). Approved by the US DOT's Pipeline and Hazardous Materials Safety Administration (PHMSA), this change echoes the changes in UN Classification on 'Chemical under pressure'. In the updated Federal Register, the Hazardous Materials Table (HMT) has been updated to include six specifications of "Chemical under pressure": UN3500-UN3505.

In the Register, PHMSA claims "The 'Chemical under pressure, n.o.s.' HMT entries are added to address shipments of liquids or solids (e.g. adhesives, coatings, and cleaners) combined with a gas or gas mixtures utilized to expel the contents from pressure vessels." Special Provision 362, which states that "classification of these materials is to be based on hazard characteristics of the components in the propellant, the liquid, or the solid forms", was amended to include the six new UN numbers that specify "Chemical under pressure".

Furthermore, Special Provision TP40 and T50 provide more detailed instruction for correct transportation of "Chemical under pressure" in various circumstances.

Along with this new support, all claims made in Global Public Input No. 50 should be considered as well.

Attached to this Global Public Comment is the Updated Federal Register as well as a list of the Public Inputs submitted to the First Draft Report that this Global Public Comment affects; a summary of results generated by 3rd party tests have been attached (video was unable to attach to this Public Comment; however, this video is now a public document following the First Draft Report).

It is recommended that any change pertaining to this Public Comment be applied to all past Public Inputs.


National Fire Protection Association Report

8/13/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...Page 1 of 7


DOT_PHMSA_Federal_Register_Vol_78_No_4.pdf

Department of Transportation's Pipeline and Hazardous Materials Safety Adminstration Federal Register.

Michael_Jacobs_3M_-_First_Draft_Public_Input_List.pdf

Related Public Inputs submitted to the Technical Committee for the First Draft

3M_Cylinder_Testing_Report.pdfTest report for 3rd party testing on low pressure cylinders

Statement of Problem and Substantiation for Public Comment

Classifying flammable liquids under low pressure.



Related ItemPublic Input No. 48-NFPA 30-2012 [Section No. 1.3.2]

Public Input No. 49-NFPA 30-2012 [Section No. 1.3.3]

Public Input No. 50-NFPA 30-2012 [Global Input]







Public Input No. 71-NFPA 30-2012 [Section No. 9.3.9 [Excluding any Sub-Sections]]

Public Input No. 72-NFPA 30-2012 [Section No. 9.3.9.1]









Public Input No. 81-NFPA 30-2012 [Section No. A.16.1.1]

Public Input No. 82-NFPA 30-2012 [Section No. 13.1]




Public Input No. 86-NFPA 30-2012 [Section No. 15.3 [Excluding any Sub-Sections]]


















Public Input No. 102-NFPA 30-2012 [Section No. A.16.2.3]

Public Input No. 103-NFPA 30-2012 [Section No. E.2.3.3]

Public Input No. 113-NFPA 30-2012 [New Section after 3.3.12.1]


Submitter Full Name: Michael Jacobs

Organization: 3M

Street Address:

City:

State:

Zip:

Submittal Date: Thu May 02 08:58:56 EDT 2013

Committee Statement



Committee Action:

Rejected but held



Resolution: At the August 2012 NFPA 30 First Draft Meeting, the NFPA 30 Technical Committee on Storage and Warehousing of Containers and Portable Tanks reviewed a series of Public Inputs (PI No. 50 et al) to the 2012 edition of NFPA 30 that would have included requirements for storage, handling, and use of low pressure containers used to dispense flammable and combustible liquids (e.g., for adhesives application, coatings application and similar uses)by means of a compressed gas. These low pressure containers are currentlynot within the scope of NFPA 30. In the course of its deliberations, theTechnical Committee considered whether these types of containers would bebetter addressed in NFPA 30B, Code for the Manufacture and Storage ofAerosol Products. However, the current scope of NFPA 30B is limited in itsapplication to aerosol products in “…metal..containers ..up to a maximum of 1000ml..”. Thus, neither document appears to address low pressurecontainers, as described in the original public inputs. At the time of the First Draft Meeting, the Technical Committee concluded that an intercommittee Task Group was needed to determine how best to address the subject. At the time, four options presented themselves: - Coverage under NFPA 30, Flammable and Combustible Liquids Code - Coverage under NFPA 30B,Code for the Manufacture and Storage of Aerosol Products - Coverage underNFPA 58, Liquefied Petroleum Gas Code - Establishing an enirely new codedevelopment project At the June 2013 Second Draft Meeting, the followingproduct issues were discussed: The low pressure containers are typicallysignificantly larger in size, and are now using U.S. Depat. of Transportation-approved containers. The products fall into four general categories: 1. Ignitable liquid – flammable propellant 2. Non-Ignitable liquid – flammable propellant These two categories are of most concern. There can be a substantial amount of flammable gas in one of these containers, creating a hazard similar to the filling operation of aerosols products. It may be appropriate to protect them that way. Currently, these containers are in storage at manufacturing sites, in warehouses, and at user locations, without clear guidance on the proper level of protection. 3. Ignitable liquid – non-flammable propellant. In this case, use of these containers appear to be no different than pressurized dispensing, which is already covered in NFPA 30. There is room for improvement for this category, but the bottom line is control of discharge, i.e., if container or piping vents, the result is limited to only discharge of the inert gas. 4. Non-ignitable liquid – non-flammable propellant. There appears to be no need of requirements from a fire protection standpoint for a product with a non-ignitable liquid and a non-flammable propellant. The Technical Committee on Storage and Warehousing of Containers and Portable Tanks has concluded that there are three options: 1. Amend the Scope of NFPA 30 to address low pressure containers. But, this would involve formation of a new Technical Committee (under the NFPA 30 project) to address the subject, because none of the current NFPA 30 technical committees have the appropriate expertise. Also, the new technical committee would need to include representation from the Technical Committee on Aerosol Products and representation by manufacturers of the containers and user industries. 2. Amend the Scope of NFPA 30B to include low pressure containers. It is not unlikely that NFPA 30B technical Committee has the appropriate expertise to deal with this issue, either. Likely, it, too, would have to create a new committee, ass described above. 3. Create a new project to develop a new code or standard that would deal strictly with low pressure containers exclusively. This might function under either of theabove-named technical committees or might require formation of an entirelynew committee, depending on subsequent review of NFPA's Standards Council. Therefore, the Technical Committee on Storage and Warehousing ofContainers and Portable Tanks has decided to first seek guidance from theNFPA Standards Council as to their preferred direction and then proceedaccordingly.

Copyright Assignment



I, Michael Jacobs, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Michael Jacobs, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature



1040 Federal Register / Vol. 78, No. 4 / Monday, January 7, 2013 / Rules and Regulations

Sym

bols

Haz

ardo

us m

ater

ials

de

scrip

tions

and

pr

oper

shi

ppin

g na

mes

Haz

ard

clas

s or

di

visi

on

Iden

tific

a-tio

n N

os.

PG

La

bel

code

s

Spe

cial

pr

ovis

ions

(§

172.

102)

(8)

(9)

(10)

Pac

kagi

ng (

§17

3.**

*)

Qua

ntity

lim

itatio

ns (

see

§§17

3.27

and

175

.75)

V

esse

l sto

wag

e

Exc

eptio

ns

Non

-bul

k B

ulk

Pas

seng

er

airc

raft/

rail

Car

go

airc

raft

only

Loca

tion

Oth

er

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8A

) (8

B)

(8C

) (9

A)

(9B

) (1

0A)

(10B

)

Car

trid

ges

for

wea

pons

, bl

ank

or C

artr

idge

s,

smal

l arm

s, b

lank

or

Car

trid

ges

for

tool

s,

blan

k.

1.4S

U

N00

14...

.II

......

......

...1.

4S...

......

....

......

......

......

.....

63...

......

....

62...

......

....

Non

e...

......

25 k

g...

.....

100

kg...

...01

......

......

.25

**

**

**

* G

C

hem

ical

und

er p

ress

ure,

co

rros

ive,

n.o

.s.

2.2

UN

3503

....

......

......

......

.2.

2, 8

......

..36

2, T

50,

TP

40

Non

e...

......

335

......

.....

313

......

.....

For

bidd

en10

0 kg

......

D...

......

......

40

G

Che

mic

al u

nder

pre

ssur

e,

flam

mab

le,

corr

osiv

e,

n.o.

s.

2.1

UN

3505

....

......

......

......

.2.

1, 8

......

..36

2, T

50,

TP

40

Non

e...

......

335

......

.....

313

......

.....

For

bidd

en75

kg

......

..D

......

......

...40

G

Che

mic

al u

nder

pre

ssur

e,

flam

mab

le,

n.o.

s.2.

1 U

N35

01...

....

......

......

....

2.1

......

......

362,

T50

, T

P40

N

one

......

...33

5...

......

..31

3...

......

..F

orbi

dden

75 k

g...

.....

D...

......

......

40

G

Che

mic

al u

nder

pre

ssur

e,

flam

mab

le,

toxi

c, n

.o.s

.2.

1 U

N35

04...

....

......

......

....

2.1,

6.1

.....

362,

T50

, T

P40

N

one

......

...33

5...

......

..31

3...

......

..F

orbi

dden

75 k

g...

.....

D...

......

......

40

G

Che

mic

al u

nder

pre

ssur

e,

n.o.

s.2.

2 U

N35

00...

....

......

......

....

2.2

......

......

362,

T50

, T

P40

N

one

......

...33

5...

......

..31

3...

......

..75

kg

......

..15

0 kg

......

B

G

Che

mic

al u

nder

pre

ssur

e,

toxi

c, n

.o.s

.2.

2 U

N35

02...

....

......

......

....

2.2,

6.1

.....

362,

T50

, T

P40

N

one

......

...33

5...

......

..31

3...

......

..F

orbi

dden

100

kg...

...D

......

......

...40

**

**

**

* Io

dine

mon

ochl

orid

e, li

q-ui

d.8

UN

3498

....

II...

......

......

8...

......

......

IB2,

T7,

TP

2...

.15

4...

......

..20

2...

......

..24

2...

......

..1

L...

......

...30

L...

......

.D

......

......

...40

, 66

, 74

, 89

, 90

Io

dine

mon

ochl

orid

e,

solid

.8

UN

1792

....

II...

......

......

8...

......

......

B6,

IB

8, I

P2,

IP

4, N

41,

T7,

T

P2.

Non

e...

......

212

......

.....

240

......

.....

For

bidd

en50

kg

......

..D

......

......

...40

, 66

, 74

, 89

, 90

**

**

**

* K

rill m

eal

......

......

......

......

.4.

2 U

N34

97...

.II

......

......

...4.

2...

......

...15

5, I

B6,

IP

2,

T3,

TP

33.

Non

e...

......

212

......

.....

242

......

.....

No

limit

.....

No

limit

.....

B...

......

......

25,

88,

128

III...

......

.....

4.2

......

......

155,

IB

8, I

P3,

T

1, T

P33

.N

one

......

...21

3...

......

..24

2...

......

..N

o lim

it...

..N

o lim

it...

..A

......

......

...12

8

**

**

**

* A

W

Mer

cury

con

tain

ed in

m

anuf

actu

red

artic

les.

8 U

N35

06...

.III

......

......

..8,

6.1

......

..A

191

......

......

....

164

......

.....

Non

e...

......

Non

e...

......

No

limit

.....

No

limit

.....

B...

......

......

40,

97

**

**

**

* G

N

itrile

s, li

quid

, to

xic,

n.

o.s.

6.

1 U

N32

76...

.I

......

......

....

6.1

......

......

5, T

14,

TP

2,

TP

13,

TP

27.

Non

e...

......

201

......

.....

243

......

.....

1 L

......

......

30 L

......

....

B...

......

......

52

II...

......

......

6.1

......

......

IB2,

T11

, T

P2,

T

P27

.15

3...

......

..20

2...

......

..24

3...

......

..5

L...

......

...60

L...

......

.B

......

......

...52

III...

......

.....

6.1

......

......

IB3,

T7,

TP

1,

TP

28.

153

......

.....

203

......

.....

241

......

.....

60 L

......

....

220

L...

.....

A...

......

......

52

G

Nitr

iles,

sol

id,

toxi

c, n

.o.s

. 6.

1 U

N34

39...

.I

......

......

....

6.1

......

......

IB7,

IP

1, T

6,

TP

33.

Non

e...

......

211

......

.....

242

......

.....

5 kg

......

....

50 k

g...

.....

D...

......

......

52

II...

......

......

6.1

......

......

IB8,

IP

2, I

P4,

T

3, T

P33

.15

3...

......

..21

2...

......

..24

2...

......

..25

kg

......

..10

0 kg

......

B...

......

......

52

III...

......

.....

6.1

......

......

IB8,

IP

3, T

1,

TP

33.

153

......

.....

213

......

.....

240

......

.....

100

kg...

...20

0 kg

......

A...

......

......

52

VerDate Mar<15>2010 18:13 Jan 04, 2013 Jkt 229001 PO 00000 Frm 00054 Fmt 4701 Sfmt 4700 E:\FR\FM\07JAR2.SGM 07JAR2wre

ier-

avile

s on

DS

K7S

PT

VN

1PR

OD

with

Michael Jacobs

3M Company Industrial Adhesives and Tapes Division

3M Center Bldg 230-1S-36

St. Paul, MN 55144

NFPA 30 First Draft Public Input #s with the related sections of NFPA 30 by Michael Jacobs of

3M Company:

48: Section 1.3.2

49: Section 1.3.3

50: Global

63: Section 1.3.4

66: Section 1.3.5

67: Section 1.3.6

68: Section 3.3.34

69: Section 3.3.50

70: Section 9.1.3

71: Section 9.3.9

72: Section 9.3.9.1

73: Section 9.3.9.2

74: Section 9.3.10

75: Section 9.4.3

76: Section 9.4.2

77: Section 9.12.1

78: Section 12.3.4

79: Section 12.6.2.2

80: Section 12.8.1

81: Section A.16.1.1

82: Section 13.1

83: Section 13.3.8

84: Section 14.1

85: Section 15.1

86: Section 15.3

87: Section 15.3.2

88: Section 15.4.1

89: Section 16.1.1

90: Section 16.2.3

91: Section 16.4.1.1

92: Section 16.4.1.2

93: Section 16.4.1.2

94: Section 16.5.2.1

95: Section 16.5.2.2

96: Section 16.5.2.3

97: Section 16.5.2.4

98: Section 18.4.8

99: Section 18.4.9

100: Section 18.5.2

101: Section 18.5.4.1

102: Section A.16.2.3

103: Section E.2.3.3

113: Section 3.3.12.3

Flammable and combustible liquids contained in a cylinder designed per DOT regulations and relief

devices designed per CGA regulations at low internal working pressures (<260 psi @77F) exhibit fire

hazards at high temperatures that are no greater than currently accepted receptacles that contain

flammable liquids or portable tanks.

Science and test data have shown that under fire conditions flammable liquids in well designed cylinders

under low pressure can be safely stored under the same code as Flammable liquids.

A well designed cylinder is constructed and certified to Dept of Transportation (DOT) standards and has

pressure relief devices installed to Compressed Gas Association (CGA) standards.

Testing has shown that a cylinder constructed to DOT 39 and DOT4BW240 has walls and welded seams

that can withstand an internal pressure increase until the relief devices open to lower the pressure. By

standards this is at a minimum of four times the working pressure. This is would be two times the

pressure under fire conditions. This is a very adequate safety margin.

Testing has shown that the two styles of relief devices (frangible disk and spring loaded valve) installed

per CGA specification open at a minimum of four times the working pressure and two times pressure

under actual fire conditions. This is a very adequate safety margin.

Testing has shown that the relief device orifice per CGA regulations are wide to allow internal pressure

to vent at a high enough rate in CFM (cubic feet per minute) to prevent any pressure increase past the

designated relief pressure limit. The cylinder seams will not burst because the relief device is

adequately sized.

Testing has shown that the volume of flammable vapor expelled through the relief device does not

dislocate the cylinder. Relief valve discharges do not dangerously “rocket” the cylinder as can happen

with unchained high pressure cylinders (3,000 psi).

Science has shown that the product formulations in the cylinder cannot autoignite or create a boiling

liquid expanding vapor explosion (BLEVE).

**MORE TESTING REPORTS WILL BE SUBMITTED AS A HARD COPY TO SUPPLEMENT THIS CHANGE AND

ALL CHANGES LINKED TO THIS GLOBAL INPUT

Flammable Liquid in a Low Pressure Cylinder Flame Test Report Reference: NFPA 30, Global Public Input #50

Norm Sato

Michael Jacobs

June 2012

ABSTRACT

In this experiment, the behavior of low pressure cylinders containing flammable liquids in

extreme situations of heat and open flame was studied. Three different sizes of low pressure

cylinders – 5, 25, and 50 gallon – were put in direct contact with open flame to emulate the

situation wherein the storage area for low pressure cylinders catches fire. Through testing, it was

determined that low pressure cylinders containing flammable liquids behave in a manner equal to

or less hazardous in a fire than flammable liquids in currently approved containers. The resulting

data within NFPA 30 Global Public Input 50 and all linked Public Inputs, related to inclusion of

low pressure cylinders in NFPA 30: Flammable and Combustible Liquids.

BACKGROUND AND PURPOSE

Innovative new products frequently do not fit established regulatory templates, creating

inconsistent warehousing or storage conditions – see FAQs in Appendix A. Current liquid based

spray adhesives products (larger than aerosol) covered by this submission is unique and required

testing under two NFPA test methods: (1) the design of the cylinder to DOT standards; and (2)

the design of the pressure relief devices to CGA standards. The resulting cylinder designs

function in manner equal to or less hazardous in a fire than flammable liquids in currently

approved containers.

The purpose of the testing, report, and submission to NFPA is to support the inclusion of

flammable liquid adhesives in low pressure cylinders into NFPA 30: Flammable and

Combustible Liquids. Video and photographic data is available to support this submission.

TEST MATERIALS, EQUIPMENT, AND PROCEDURE

The basic setup for this experiment, as shown in Figure 1, included a low pressure cylinder that

was heated through direct contact with an open flame provided by propane torches. A pressure

gauge was attached to the main valve opening of the low pressure cylinder. This gauge reports

pressure to the test operator, allowing testing to be shut down if internal pressure was to exceed

the relief valve specifications. Above the low pressure cylinder was another open flame

provided by a propane torch. This was used as a ‘flare’ or ‘pilot light’ to ignite any of the

material that escapes through the relief valves.

In addition to the basic setup, extra precautions were taken by building concrete retaining walls

around three sides of the experiment and each low pressure cylinder tested was chained to the

ground. Cameras were set up to record video of the test from distance. All testing was done

outside.

FIGURE 1. Simple diagram of flame test set-up.

Three different sizes of cylinders, as described in Appendix B, were tested: 5 gallon, 25 gallon,

and 50 gallon cylinders. The 5 gallon cylinder has a “frangible disk” relief valve found on the

cylinder wall itself. When the frangible relief disk fails (breaks), a 0.12 in2 orifice should be

opened providing an escape route for contents inside the cylinder. The 5 gallon cylinder used in

this test has manufacturer specifications claiming the relief valve will open between 360 and 520

psig. Both the 25 and 50 gallon cylinders have a spring loaded relief valve found on the back

side of the main valve. When the gauge pressure of the cylinder reaches a certain level, the

spring should be stretched enough to open an orifice and let some of the pressure escape from the

cylinder. After a noticeable amount of gas has been released, the pressure inside the cylinder

will decrease, causing the spring close the orifice. Both cylinders used in this test have

manufacturer specifications claiming the relief valves will open between 360 and 480 psig.

All cylinders were heated by the propane torches until either a relief valve opened or the internal

pressure exceeded relief valve specifications. For the 5 gallon containing a frangible disk relief

valve, propane torches used for heating were extinguished following rupture of the frangible

disk. The test was continued with a 10 minute observation and cool down period. Water was

used to speed the cooling of the cylinder following the 10 minute observation. For the low

pressure cylinders containing a spring relief valve, propane torches used for heating were

extinguished following the second opening of the relief valve. The test was continued until the

pressure relief valve would not re-open, followed by a 10 minute observation and cool down

period. Water was used to speed the cooling of the cylinder following the 10 minute

observation.

RESULTS

5 GALLON CYLINDER

Pressure was recorded once every second during the test. Figure 2 shows the change in pressure

over time for the testing of the 5 gallon cylinder.

FIGURE 2. Internal Pressure (psig) vs Time Elapsed (sec) during the testing of the 5 gallon cylinder.

The maximum pressure reached during the testing was 360.1 psig, 193 seconds into the test. At

this point, the frangible disk broke and a rush of gas escaped from the cylinder immediately,

dropping the pressure to 181.7 psi, at 200 seconds. From then on, pressure gradually decreased

as the liquefied propellant (dimethyl ether in this case) vaporized and escaped through the orifice

under the frangible disk. Vapors that escaped from the relief valve caught on fire from the flare

above.

25 GALLON CYLINDER



0

50

100

150

200

250

300

350

400

0 50 100 150 200 250 300 350 400

Inte

rnal

Pre

ssu

re (

psi

g)

Time Elapsed (sec)

Pmax = 360.1 psig Frangible Disk Rupture

FIGURE 3. Internal Pressure (psig) vs. Time Elapsed (sec) during the testing of the 25 gallon cylinder.

The maximum pressure reached during testing was 410.0 psig, 283 seconds into the test. This

was the first time the pressure relief valve opened. Propane torches were left on while gas

escaped from the cylinder. Within two seconds of the relief valve opening, the spring loaded

valve closed at a pressure of 352.2 psi. The cylinder continued heating and pressure increased

again until the relief valve opened the second time at 397.7 psig, 302 seconds into the test.

Following the second relief valve closure, propane torches were extinguished. Due to

thermodynamic interia, the spring relief valve opened two more times to relieve pressure. Figure

4 shows, in more detail, change in pressure over time during with the spring relief valve opened

and closed. Vapors that escaped from the relief valve caught on fire from the flare above.

0

50

100

150

200

250

300

350

400

450

0 200 400 600 800 1000 1200 1400 1600

Inte

rnal

Pre

ssu

re (

psi

g)

Time Elapsed (sec)

Pmax = 410.0 psig

Cool down with water begins


50 GALLON CYLINDER




The maximum pressure reaching during testing was 446.3 psig, 361 seconds into the test. This

was the first time the pressure relief valve opened. Propane torches were left on while gas

escaped from the cylinder. Within two seconds of the relief valve opening, the spring loaded

250.0

270.0

290.0

310.0

330.0

350.0

370.0

390.0

410.0

430.0

250 300 350 400 450

Spring relief valve opens


Heat off

0

50

100

150

200

250

300

350

400

450

500

0 500 1000 1500 2000

Pmax = 446.3 psig

Cool down with water begins

valve closed at a pressure of 387.9 psi. The cylinder continued heating and pressure increased

again until the relief valve opened the second time at 441.8 psig, 398 seconds into the test.

Following the second relief valve closure, propane torches were extinguished. Despite this, the

spring relief valve opened two more times to relieve pressure. Figure 6 shows, in more detail,

change in pressure over time during with the spring relief valve opened and closed. Vapors that

escaped from the relief valve caught on fire from the flare above.


DISCUSSION AND CONCLUSIONS

The pressure of the escaping vapor was determined to be low enough that the safety chains used

are not needed.

Safety of the relief valves is confirmed; the data presented shows that relief devices specified by

CGA open at 50% of the burst strength (see Appendix B) of the cylinders, allowing a very large

safety margin.

Testing shows that the DOT cylinder construction is more than adequate in design to withstand

fire situations listed under NFPA 30: Flammable and Combustible Liquids.

300

320

340

360

380

400

420

440

460

480

500

250 300 350 400 450 500 550 600 650 700 750


Spring relief valve closes

Heat off

APPENDIX A: FAQs

1. Q: Why do existing regulations not clearly apply to cylinder spray adhesives?

A: Cylinder spray adhesives consist of a spray gun connected by a flexible rubber hose to a

metal tank that is filled with dissolved resin in a solvent, under gas pressure. This innovative

product does not exactly fit into current UN and DOT transportation regulations or current

NFPA warehouse and storage fire codes, causing confusion and questions as fire marshals,

inspectors and insurance agents evaluate the underlying science. Understanding the product

and revising current regulations is key to establishing safe and consistent storage conditions.

2. Q: Are all cylinder spray adhesives Flammable?

A: No, flammability varies according to the product ingredients. Our products that contain

both flammable and non-flammable solvents and propellants:

Table 1. Description of various types of adhesives

Adhesive Solvent Propellant

1 Non Flammable Flammable Flammable

2 Non Flammable Non Flammable Flammable

3 Non Flammable Flammable Non Flammable

4 Non Flammable Non Flammable Non Flammable

3. Q: The final product is a solid glue, why not store it as a solid?

A: This product, as stored, does not fit the definition of a solid. The solvents and propellant

have dissolved the solid raw materials into a liquid mixture, so it can be sprayed. The 20-

30% non flammable solid adhesive remains only after the carrier solvents and propellants

have dissipated. The viscous mixture does lower the flammability characteristics of the pure

solvent and the propellant gases.

4. Q: Could this product be covered under the Aerosol codes per NFPA 30B?

A: This product has been described as a cost effective alternative to the aerosol spray can for

the high volume user. This product does not exactly fit the definition of an aerosol container

as the size is too large.

“NFPA 30B 3.3.2 Aerosol Container: A metal can or plastic container, up to a maximum

size of 1000 ml (33.8 fl oz).”

5. Q: Could this product be covered as a Gas, as the cylinders resemble my backyard BBQ

liquid propane tanks?

A: The tanks we use are very similar because the US Department of Transportation (DOT)

regulates the construction, shipment, inspection and storage during transport of pressurized

metal cylinders. All of our non-refillable cylinders are certified to DOT 39 construction

requirements per 49 CFR 173. This includes the materials and burst strength of the cylinder

wall, the main valve and the pressure relief disks and valves. Our cylinders are shipped and

stored during transport as a GAS under current DOT regulations as this is the most

expeditious.

6. Q: If it is shipped as a Flammable Liquified Gas, why not store it as a gas under NFPA

55?

A: We believe that DOT shipping regulations and NFPA storage codes for Gas cylinders are too

restrictive and inappropriate for this product line. This product does not exactly fit the

definition of a Liquefied Gas. The gas propellant is usually in the formula at less than 15%

by weight. Gas is present in the small “headspace” above the liquid resin. 85% of the

container is the non-volatile solid adhesive dissolved in a flammable liquid solvent. The

small amount of gas propellant is at a low pressure of about 200 psi as it does not take much

pressure to force the liquid out of the container. Some of the gas has mixed with the liquid,

much like a carbonated soda can.

7. Q: If DOT shipping regulations are inappropriate for this product line is DOT

considering amendments to those regulations?

A: Europe has already rewritten its regulations to contain new United Nation (UN) shipping

codes which very closely fit our product line (UN3501). We hope that DOT will accept the

UN codes and rewrite applicable DOT regulations in the near future. The UN3501 shipping

codes are already included in the 2012 Emergency response guidebook.

8. Q: Is this product a flammable liquid?

A: This product does not exactly fit the definition of a liquid but it is close as 85% of the

container volume is liquid. The remaining 15% headspace allows the propellants to come to

equilibrium with the solution. The headspace allows for a safety margin in the event of a fire

which can cause the internal pressure to increase.

“NFPA 30 4.3.1 Flammable liquids, (1) Class IA Liquid —Any liquid that has a flash point

below 73°F (22.8°C) and a boiling point below 100°F (37.8°C)”

9. Q: Could this product be covered under the NFPA 30 Flammable Liquid regulations?

A: Yes, we believe our product is a stable Class 1A flammable liquid under low pressure and

this might be the current best fit. There is precedent. Aerosol spray cans were stored as

Flammable liquids under this code before NFPA 30B was created in 1990.

“Prior to 1990 the storage of flammable aerosols were set forth in NFPA 30, Flammable and

Combustible Liquids Code, where they were treated as Class IA flammable liquids. NFPA 30

2011 pp4”

10. Q: Is this product a viscous flammable liquid?

A. The primary product is a viscous liquid with a viscosity over 100 cps. A viscous mixture does

lower the flammability characteristics of the pure solvents as acknowledged in NFPA 30

16.2.5.

11. Q: Does NFPA 30 allow the storage of US-DOT approved Metal containers?

A: Yes, storage of US-DOT approved Metal containers is allowed,

“NFPA-30 Chapter 9.4.1Only the following approved containers, intermediate bulk

containers, and portable tanks shall be used for Class I, Class II, and Class IIIA liquids:

(1) Metal containers, metal intermediate bulk containers, and metal portable tanks meeting

the requirements of and containing products authorized by the U.S. Department of

Transportation Hazardous Materials Regulations in Title 49, Code of Federal Regulations,

Parts 100–199, or by Part 6 of the UN Recommendations on the Transport of Dangerous

Goods”

12. Q: Does NFPA 30 or DOT consider this product a Portable tank?

A: We do not believe our cylinders fit the definition of a Portable Tank because our product has

a capacity less than 1,000 lbs and less than 60 gallons.

“NFPA-30 Chapter 9 Definitions, Cylinder means a pressure vessel designed for pressures

higher than 40 psia and having a circular cross section. It does not include a portable tank,”

“NFPA 30 3.3.47.5 Portable Tank. Any vessel having a liquid capacity over 60 gal (230 L)

intended for storing liquids and not intended for fixed installation.”

“DOT-49CFR171.8 Portable tank means a bulk packaging (except a cylinder having a water

capacity of 1,000 pounds or less)”

13. Q: Would this product qualify as Bulk Packaging under NFPA 30?

A: We do not believe our cylinders fit the definition of Bulk Packaging as tanks are too small.

“Table 9.4.3 Maximum Allowable Size: bulk packaging has a maximum capacity greater

than 450 L (119 gallons) as a receptacle for a liquid. “Non-bulk packaging means a

packaging which has: (1) A maximum capacity of 450 L (119 gallons) or less as a

receptacle for a liquid.”

APPENDIX B: Cylinder Specifications

Table 2. Cylinder Specifications

Cylinder Characteristic 5 Gallon 25 Gallon 50 Gallon

Capacity (lbs H2O) 48.77 238 476

Volume (cf) 0.78125 3.81 7.63

Working Pressure (psig) 200 200 200

Burst Pressure (psig) 650 960 960

Relief Type Frangible Disk Spring Relief Spring Relief

Relief Pressure (psig) 360-520 360-480 360-480

Relief Area (orifice) 0.120" +/- 0.005" n/a n/a

Relief Capacity (CFM Air) n/a 240 240

CGA Relief Requirement (CFM Air) 80.32 362.63 725.27

Estimated or Known CGA Relief Capacity 67.913 240 240

Public Input No. 6-NFPA 30-2015 [ Global Input ]

Throughout standard remove references to the following and replace with the following:

(1) ANSI/UL and replace with UL.

(2) API Specification and replace with API SPEC.

(3) API Standard and replace with API STD.

(4) ANSI/ASME B31.3 and replace with ASME B31.3.

(5) ANSI Z129.1 and replace with ANSI Z400.1/Z129.1.

(6) API # and so on and replace API STD # or API RP #.


Recommended updates to correlate with PI-5 and PI-7.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 5-NFPA 30-2015 [Section No.2.3]

Referenced current SDO names, addresses, standard names,and years.

Public Input No. 33-NFPA 30-2015 [Section No.I.1.2]


Submitter Full Name: Aaron Adamczyk

Organization: [ Not Specified ]

Street Address:

City:

State:

Zip:

Submittal Date: Fri Feb 06 00:46:52 EST 2015


3 of 86 8/13/2015 2:39 PM

flammable and combustible liquids code committee · 2015. 8. 17. · flcops.2015-09 agenda.doc...

Documents