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INT.2015-11 Agenda.doc

TECHNICAL COMMITTEE ON INTERNAL COMBUSTION ENGINES

MEMORANDUM

TO: Technical Committee on Internal Combustion Engines

FROM: R. P. Benedetti

DATE: October 27, 2015

SUBJECT: Agenda for NFPA 37 First Draft Meeting November 12, 2015 — 9:00 AM to 5:00 PM November 13, 2015 — 8:00 AM to 12:00 PM

_________________________________________________________________________________ Gentlemen: Attached is the Agenda for the NFPA 37, Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines, First Draft meeting to be held Thursday, November 12, and Friday, November 13, 2015, at NFPA’s offices in Quincy MA. The meeting is scheduled to run from 9:00 AM to 5:00 PM Thursday and 8:00 AM to Noon on Friday. This Agenda will also be posted to the NFPA 37 Document Information Page at http://www.nfpa.org/37 If you have additional items for the Agenda, please bring them with you to the meeting. rpb/ cc INT Meeting Folder INT/NM



AGENDA — NFPA 37 First Draft Meeting

Technical Committee Internal Combustion Enginess

NFPA Offices, Quincy MA Thursday, November 12, 2015, 9:00 AM to 5:00 PM Friday, November 13, 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. [March, 2013, Greenville SC] [Attachment № A2] 4. Appointment of Committee Chair Pro Tempore. 5. Report of Staff Liaison.

Technical Committee Scope. [See Attachment № A3] Technical Committee Membership Status. [Attachment № A3] Document Revision Schedule for Annual 2017 Cycle. [Attachment № A4]

6. Member Reports on Current Issues. [As Necessary]

NFPA Liquids Classification vs. OSHA GHS 7. Review and Act on Public Inputs to Amend the 2015 edition of NFPA 37

[Attachment № A5 – Public Inputs & Attachments to Same] 8. Old Business. [NONE] 9. New Business.

Applicability of NFPA 37 to Marine Installations. [Attachment № A6] Paragraph 4.3(3) – Clarification. [Attachment № A7] Paragraph 5.3.1.1 – Performance Criteria Needed. [K. elovitz]

(To give meaning and make objectively enforceable. E.g., state flow and allowable back pressure for sizing vent piping.)

Subsection 5.4.3 – Clarification. [Attachment № A8] Paragraph 5.4.4.4 – Clarification. [Attachment № A9] Paragraph 6.3.2.2 – Clarification. [Attachment № A10] Subsection 6.3.3 & TIA. [K. Elovitz] Electrical Area Classification of Interior of Enclosure. [Attachment № A11] Definition of Pierced Wall. [Attachment № A12] Subsection 11.4.4 – Design Criteria. [Attachment № A13] Subsection A.11.3.1 – Clarification. [Attachment № A14]


Electrical Area Classification for Vents – NFPA 30 vs. NFPA 30A [Attachment № A15] Corrections to ASHRAE References. [Attachment № A16] Correlation – NFPA 37 & NFPA 85. [Attachment № A17] Turbine Lube Oil Tanks – NFPA 30, Chapter 24? [G. Schnee] Paragraph 11.4.5.1 – Amend to specify Extra Hazard Group 2 [B. Chase, NFPA] Normal (Breather) Vents for Fuel Tanks. [Staff Liaison] Need for Clearance between Fuel Gas and Electrical Service? [Staff Liaison] Miscellaneous Items. [Staff Liaison]

10. Schedule Next Meeting(s). 11. Adjournment.

Address List No PhoneInternal Combustion Engines INT-AAA

Robert P. Benedetti10/21/2015

INT-AAA

James B. Biggins

PrincipalGlobal Risk Consultants Corporation15732 West Barr RoadManhattan, IL 60442-9012

SE 1/1/1992INT-AAA

Kevin J. Carlisle

PrincipalKarl Dungs, Inc.3890 Pheasant Ridge Drive, NEBlaine, MN 55449

M 07/29/2013

INT-AAA

Lawrence M. Danner

PrincipalGE Power & Water300 Garlington RoadGTTC Room 200DGreenville, SC 29615-0648Alternate: William S. Lockhart

M 7/19/2002INT-AAA

Kenneth M. Elovitz

PrincipalEnergy Economics, Inc.26 Elm StreetFoxboro, MA 02035

SE 1/1/1994

INT-AAA

Daniel D. Groff

PrincipalAIG Energy and Engineered Risk2525 Country Side LaneWexford, PA 15090-7941Alternate: Arthur M. Partin

I 07/29/2013INT-AAA

Fred L. Hildebrandt

PrincipalAmerex/Janus Fire Systems1102 Rupcich Drive, Millennium ParkCrown Point, IN 46307Fire Suppression Systems Association

M 8/2/2010

INT-AAA

Zuhair M. Ibrahim

PrincipalExponent, Inc.5401 McConnell AvenueLos Angeles, CA 90066-7027Alternate: Stephen Garner

SE 3/4/2009INT-AAA

David M. Nieman

PrincipalBechtel Corporation11720 Plaza America Drive, 10th FloorReston, VA 20190-4757Alternate: Keegan M. Kinney

U 8/5/2009

INT-AAA

Steve Oxtoby

PrincipalKohler Power SystemsN7650 County Trunk LSMail Stop 072Sheboygan, WI 53083-5518

M 08/11/2014INT-AAA

Steven H. Pasternack

PrincipalIntertek Testing Services3933 US Route 11Cortland, NY 13045

RT 4/17/2002

INT-AAA

Owen M. Preston

Principal3221 Blair DrivePalatka, FL 32177

SE 7/1/1994INT-AAA

Y. R. Reddy

PrincipalR-B Pumps, Inc.PO Box 557Baxley, GA 31513

U 4/1/1994

INT-AAA

Steve R. Sappington

PrincipalCaterpillar Inc.175 Cutstone CourtFayetteville, GA 30215-6206

M 04/08/2015INT-AAA

Richard Scott

PrincipalChubb Group of Insurance CompaniesOne Financial CenterBoston, MA 02111-2697

I 1/1/1994

1

bbenedetti

Text Box

Attachment No.A1

Address List No PhoneInternal Combustion Engines INT-AAA

Robert P. Benedetti10/21/2015

INT-AAA

Matthew M. Shanks

PrincipalMontgomery County255 Rockville Pike, 2nd FloorRockville, MD 20850-4186

E 04/08/2015INT-AAA

Milan Tretinjak

PrincipalSolar Turbines Incorporated9330 Sky Park Court, MZ-CSC-24San Diego, CA 92123Alternate: Gerard J. Schnee

M 4/17/2002

INT-AAA

Kow Ken Sun

Voting AlternateAES CorporationRua XV De Novembro, 1510Centro, ParanaMarechal Candido Rondon, 85960 BrazilVoting Alt. to AES Rep.

U 10/29/2012INT-AAA

Stephen Garner

AlternateExponent, Inc.1013 North Honore Street, Unit 1Chicago, IL 60622-3718Principal: Zuhair M. Ibrahim

SE 04/08/2015

INT-AAA

Keegan M. Kinney

AlternateBechtel Power Corporation11720 Plaza America DriveReston, VA 20190Principal: David M. Nieman

U 10/29/2012INT-AAA

William S. Lockhart

AlternateGE Power & Water2429 NW 59th StreetOklahoma City, OK 73112-7373Principal: Lawrence M. Danner

M 03/03/2014

INT-AAA

Arthur M. Partin

AlternateAIG Energy & Engineered Risk10207 Rubury PlaceTampa, FL 33626Principal: Daniel D. Groff

I 10/28/2014INT-AAA

Gerard J. Schnee

AlternateSolar Turbines Incorporated9280 Skypark CourtSan Diego, CA 92123Principal: Milan Tretinjak

M 10/27/2009

INT-AAA

Robert P. Benedetti

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

7/2/2002

2


MINUTES of MEETING

Technical Committee on Internal Combustion Engines

GE Power and Water Greenville, SC

March 5 & 6, 2013

I. Attendance

J. B. Biggins, Global Risk Consultants Corporation L. M. Danner, GE Power and Water F. L. Hildebrandt, Janus Fire Systems K. M. Kinney, Bechtel Power Corporation O. M. Preston, Palatka, FL Y. R. Reddy, R-B Pumps, Inc. (March 5 only) J. E. Reiter, AES Corporation C. C. Roberts, American International Group, Inc., CHAIR G. J. Schnee, Solar Turbines Incorporated B. J. Wertz, Power Plant Management Consulting LLC R. P. Benedetti, National Fire Protection Association, STAFF LIAISON GUESTS: K. Carlisle, Karl Dungs, Inc. D. McMenamin, Dan McMenamin & Assoc., Inc. R. Weber, GE Power & Water MEMBERS NOT ATTENDING: K. M. Elovitz, Energy Economics, Inc.

Z. M. Ibrahim, Exponent, Inc. S. H. Pasternack, Intertek Testing Services R. Scott, Chubb Group of Insurance Companies K. K. Sun, AES Corporation M. Tretinjak, Solar Turbines Incorporated

II. Minutes 1. The Meeting was called to order at 8:20 AM on March 5, 2013. Mr. Eric Kaufman welcomed the

Technical Committee to the GE Power & Water facility. 2. Attendees introduced themselves and the Technical Committee roster was updated as needed.

An updated roster will be posted to the Technical Committee’s Document Information Web Page. 3. The Minutes of the last meeting (May 2012, NFPA Headquarters, Quincy MA) were unanimously

approved as submitted. 4. Technical Committee Chair Cliff Roberts briefed the Technical Committee on the Agenda.

bbenedetti

Text Box

Attachment No. A2

5. The Staff Liaison reviewed with the Technical Committee the following items:

Technical Committee Scope Statement. The Technical Committee agreed no changes are necessary.

Technical Committee Membership. – Two new alternate members were appointed to the Technical Committee at the October 2012 Standards Council meeting: Keegan Kinney (alternate to David Nieman) and Kow Ken Sun (alternate to John Reiter). – The Staff Liaison reported that Ron Shaffer has resigned from the Technical Committee due to a change in his employment. The Staff Liaison also reported that contact has been lost with the Technical Committee Secretary, Stephen Wetter. It was determined during the course of the meeting that Mr. Wetter is no longer employed by Caterpillar Inc. Action Item: The Technical Committee needs to solicit representation from Caterpillar Inc. or some other manufacturer of internal combustion prime movers for stationary application. Technical Committee members are asked to provide contacts for the Staff Liaison, so that he can invite participation. – The Staff Liaison pointed out that, with the loss of Messrs. Shaffer and Wetter, the Technical Committee is seriously overbalanced with Special Experts, who currently make up 43% of the roster. As noted at the last meeting, there is a need for members in all other categories other than Special Expert. Action Item: Technical Committee members are asked to identify any likely candidates for membership, particularly in the interest categories of: User; Enforcing Authority; Insurance; Installer/Maintainer (those who install or provide contract maintenance of units); and manufacturers of system components.

The Enforcer Participation & Alternate Member Emphasis Programs. The Staff Liaison reported that no progress has been made in securing representation from the enforcement community, but some progress has been made in naming alternates. Action Item: See above. Also, those Technical Committee members who do not yet have an alternate are asked to provide a nominee.

Review of Fall 2013 Document Revision Schedule. The Staff Liaison reviewed the next mileposts in the document revision cycle for the 2014 edition of NFPA 37. There was discussion that, due to advances in technology, NFPA 37 should go from a four-year revision cycle to a three-year cycle. The Technical Committee agreed. Action Item: The Staff Liaison was directed to recommend to the Standards Council that NFPA 37 be moved to a three-year revision cycle and that it enter the Fall 2016 cycle.

6. For the benefit of the new members, Larry Danner reviewed the Kleen Energy explosion incident as

the background for the development and release of NFPA 56PS, Standard for Fire and Explosion Prevention During Cleaning and Purging of Flammable Gas Piping Systems. He reported that the task of revising NFPA 56PS into a formal NFPA standard is almost complete and that the official standard will be offered for Association adoption at the June 2013 meeting. Basically, it will affirm the recommendation by the U. S. Chemical Safety and Hazard Investigation Board not to use live gas for purging pipelines. He reported that there did not seem to be, at this time, any likelihood of a Notice of Intent to Make a Motion (NITMAM). The standard will be identified as NFPA 56 and will carry a 2014 edition date. Action Item: A reference to NFPA 56 might need to be added to Section 5.1 of NFPA 37.

7. The Technical Committee heard a presentation by Dan McMenamin, Dan McMenamin Associates, on behalf of Verizon Wireless regarding a proposed Tentative Interim Amendment (TIA) to Paragraph 6.6.3.1 of NFPA 37-2010. (See Attachment № M1.) After discussion, Messrs. Biggins and Roberts

agreed to jointly support the TIA. Jim Biggins offered to revise the proposed changes to effect broader application of the concept. The proposed TIA, based on the text of the current 2010 edition of NFPA 37, reads as follows: “6.6.3 Piping for fuel tanks other than engine-mounted tanks shall be in accordance with 6.6.3.1 through 6.6.3.4 Chapter 27 of NFPA 30, Flammable and Combustible Liquids Code. 6.6.3.1 Tanks shall be filled by a closed piping system. The fill pipe shall terminate outside the building at a point at least 600 mm (24 in.) from any building opening at the same or lower level. 6.6.3.2 Piping for fuel tanks shall be in accordance with Chapter 21 of NFPA 30, Flammable and Combustible Liquids Code. 6.6.3.3 The fill pipe shall terminate on an exterior wall of the room or structure at a point at least 600 mm (24 in) from any building opening at the same or lower level, except as provided for in 6.6.3.3.1. 6.6.3.3.1 The provisions of 6.6.3.3 shall not be required for tanks that are filled manually at their fill port or fill connection, provided that the tank and its fill port or fill connection are located within the spill containment required by 6.3.2.4, 6.3.5.3, or 6.3.6.3 and the filling operation is constantly attended.” Action Item: The Staff Liaison was directed to circulate this proposed TIA to letter ballot of the Technical Committee for both the 2010 and (upcoming) 2014 editions of NFPA 37.

8. The Technical Committee reaffirmed its decision to proceed with the proposed Tentative Interim

Amendment (TIA) to Subsection 9.9.3 of the 2010 edition of NFPA 37. This TIA will correct the inadvertent omission from the 2010 edition of NFPA 37 of this provision. Action Item: The Staff Liaison was directed to circulate this proposed TIA to letter ballot of the Technical Committee for the 2010 edition of NFPA 37.

9. Larry Danner presented the report of the Task Group on Aero (Thin-Wall) Turbines to the Technical

Committee. This Task Group was charged with developing appropriate text for NFPA 37 to address cool-down time for so-called aero-derivative stationary turbines (turbine designs based on aircraft propulsion turbines). The Technical Committee reviewed and made appropriate changes to the text. Implementation of the Task Group’s report involves five separate Committee Comments, one for each numbered paragraph and annex paragraph affected. These five Committee Comments address Public Input PI19 and First Revision FR23.

10. The Technical Committee reviewed and took appropriate action on the five Committee Inputs (CIs)

that were a part of the First Draft Report on NFPA 37-2014.

CI № 3 on Paragraph 4.4.1.1: This originated as Public Input № 22 during the First Draft stage. The Technical Committee did not adopt the proposed amendment, preferring to solicit additional information from interested persons. None was received. The Technical Committee is still not persuaded that the scope of NFPA 37 should be extended to areas designated as hazardous (classified) locations in accordance with NFPA 70®, National Electrical Code®. (Example: offshore marine facilities). These are more properly the jurisdiction of Chapter 5 of NFPA 70. Therefore the Technical Committee determined it should not incorporate the amendments proposed under Public Input № 22.

CI № 4 on Subsection 1.3.3: Adoption of this amendment was dependent on adoption of amendment(s) to §4.4.1.1 via CI № 3. Since no such amendment was developed, this revision to 1.3.3 also was not adopted.

CI № 12 on Subsection 5.2.1: This was accepted and incorporated into Second Revision № 18. CI № 13 on Subsection 5.2.2: This was addressed by the Technical Committee’s action on Public

Comment № 12. CI № 14 on Paragraph 5.3.1.1: This was addressed by the Technical Committee’s action on

Public Comment № 11

11. The Technical Committee reviewed and acted on all Public Comments (PCs) received on the First Draft Report on NFPA 37-2014 (Proposed Amendments to NFPA 37-2010). NOTE: There were no Public Comments Nos. 1, 2, or 4.

PC № 3: Although this was not strictly a public comment, but rather an inquiry of sorts, the

Technical Committee determined that it raised issues that warranted an amendment to Paragraph 9.3.2(4) and a new annex item to Paragraph 9.3.2. These amendments will be designated Second Revision №s 13 and 14 in the Second Draft Report.

Public Comment #5: Accepted. Public Comment #6: The Technical Committee agreed with the need to provide a more

extensive explanation, but found some of the Commenter’s proposed text to be extraneous. The Technical Committee developed its own version, to be designated Second Revision № 4 in the Second Draft Report.

Public Comments Nos. 7 & 8: The Technical Committee rejected both of the proposed amendments on the basis that developing testing protocols was beyond the Technical Committee’s scope.

Public Comment #9: Accepted. Public Comment #10: The Technical Committee rejected this proposed amendment because a

full-capacity relief valve can accomplish the same operation. Public Comment #11: The Technical Committee chose to accept the proposed text, but as an

annex item to (new) 5.2.1(10). See Second Revision № 17. Public Comment #12: The Technical Committee accepted the comment, but revised it for clarity

and to address Committee Input № 13. The final version will be designated as Second Revision № 16

Public Comment #13: The Technical Committee accepted this comment, but revised it to address Committee Input № 14 and to better meet the submitter’s objective. The final version will be designated as Second Revision № 15.

12. The Technical Committee reviewed two minor issues relating to NFPA 37 and determined that neither

required any action or change to the standard.

With respect to building openings in walls adjacent to engines, the building code would cover this issue.

With respect to tank capacity, NFPA 37 governs for tanks installed indoors and there are no limits to the capacities of tanks installed outside buildings or structures.

13. There was no correspondence requiring the Technical Committee’s attention. 14. There was no Old Business requiring the Technical Committee’s attention. 15. Under “New Business”, the Technical Committee discussed termination of normal vents from sub-

base fuel tanks. The Technical Committee decided to appoint a Task Group to develop any appropriate amendments to NFPA 37 for review of the Technical Committee during the next document revision cycle. Action Item: Technical Committee members interested in participating on this Task Group are asked to notify the Staff Liaison. Any suggested approaches are also welcome.

16. The Technical Committee will formally schedule its next meeting, the first of a new document

revision cycle, at an appropriate time after adoption of the proposed 2014 edition of NFPA 37. Tentatively, this will be March 2015. Effort will be made to combine this meeting with a tour of a gas turbine power plant.

17. The meeting adjourned at 10:00 AM on March 6.

INT Scope Statement & Member Balance.doc - 10/27/2015


SCOPE STATEMENT

This Committee shall have primary responsibility for documents on the fire safety of the installation, operation, and control of internal combustion engines, including gas turbine engines, using all types of fuel, within structures or immediately exposing structures. Responsible for NFPA 37, Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines.

COMMITTEE MEMBERSHIP BALANCE

Principals: 16 M: 6 (35%)* U: 3 (18%) Voting Alternates: 1 I/M: 0 L/C: 0 Alternates: 5 R/T: 1 (6%) E: 1 (6%)

Non-Voting: 0 I: 2 (12%) SE: 4 (24%) Emeritus 0

Task Group: 0 Hold List: 1 Balance: Overbalanced by 1 M *(combustion controls: 1 generator sets: 2 internal combustion engines: 0

fire suppression systems: 1 turbines: 2)

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. 4-NFPA 37-2015 [ Global Input ]

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

(1) ANSI/UL and replace with UL.

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

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

Statement of Problem and Substantiation for Public Input

Corresponds with PI-5 and PI-6.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 5-NFPA 37-2015 [SectionNo. 2.3]

Referenced current SDO names, addresses, standardnames, and years,

Public Input No. 6-NFPA 37-2015 [SectionNo. B.1.2]

Referenced current SDO names, addresses, standardnames, and years,

Submitter Information Verification

Submitter Full Name: Aaron Adamczyk

Organization: [ Not Specified ]

Street Address:

City:

State:

Zip:

Submittal Date: Sat Feb 07 01:55:00 EST 2015

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

1 of 36 10/27/2015 9:53 PM

bbenedetti

Text Box

Attachment No. A5

Public Input No. 5-NFPA 37-2015 [ Section No. 2.3 ]

2.3 Other Publications.

2.3.1 API Publications.

American Petroleum Institute, 1220 L Street, NW, Washington, DC 20005-4070.

API STD 620, Design and Construction of Large Welded Low-pressure Storage Tanks, 11th 12thedition, February 2008 2013, Amendment 1, 2014 .

API STD 650, Welded Tanks for Oil Storage, 11th 12th edition, June 2007 2013, Errata, 2014 .

2.3.2 ASME Publications.

American Society of Mechanical Engineers, Three ASME International , Two Park Avenue, New York,NY 10016-5990.

ANSI/ ASME Boiler and Pressure Vessel Code, 2007 2015 .

ANSI/ ASME B31.3, Process Piping, 2002 2014 .

2.3.3 MSS Publications.

Manufacturers Standardization Society of the Valve and Fittings Industry Inc. , 127 Park Street NE, Vienna,VA 22180-4602 .

MSS SP -69 58 , Pipe Hangers and Supports — Selection and Application, 2003. And Supports -Materials, Design, And Manufacture, Selection, Application, And Installation, 2009 . (SupersedesMSS SP-69)

2.3.4 UL Publications.

Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096.

ANSI/ UL 900, Standard for Air Filter Units, 2004, with revisions through November Revised 2012.

2.3.5 Other Publications.

Merriam-Webster’s Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, 2003.


Referenced current SDO names, standard numbers, names, and years



Public Input No. 4-NFPA 37-2015 [Global Input]

Public Input No. 6-NFPA 37-2015 [Section No. B.1.2]




Street Address:

City:

State:

Zip:



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Public Input No. 18-NFPA 37-2015 [ New Section after 3.3.8 ]

3.3.x Protected Pressure. A pressure that equals the setting of the nearest, upstream overpressureprotection device or is the inlet pressure to the service regulator, whichever is lower.

Additional Proposed Changes

File Name Description Approved

3.xx_definition_of_protected_pressure.pdf original


This would be a useful term to introduce in 5.9 to remove ambiguity with OPD regulators.


Submitter Full Name: KEVIN CARLISLE

Organization: KARL DUNGS INC

Street Address:

City:

State:

Zip:

Submittal Date: Thu Jul 02 14:02:26 EDT 2015


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3.3.x Proof-of-Closure Switch. A switch installed in a safety shutoff valve that activates only after the valve isfully closed.



3.x.x_POC_definition.pdf original


Suggest that this term be defined, and that the definition be the same as in NFPA 86.




Street Address:

City:

State:

Zip:



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3.3.x.x Overpressure cutoff device. an overpressure protection device. such as such as a slam-shut valve ora high-pressure switch in combination with an adequately rated shutoff valve. functions by completelyshutting off the flow of gas into the downstream system.

3.3.x.x pressure relief valve : an overpressure protection device which vents gas from the downstreamsystem to a safe location.

3.3.x.x Monitoring Regulator. an overpressure protection device that acts as backup pressure regulator.which is set in a non-regulated state and in series with another main pressure regulator. for the purpose oftaking over and providing a regulated pressure should the main pressure regulator fail.

3.3.x.x Series Regulator. one of two pressure regulators in series. both of which are in a regulated state.and one acts as an overpressure protection device for the purpose of continuously providing a regulatedpressure should the other regulator fail.



3.xx_defintion_of_OP.pdfOriginal


Overpressure Protection Devices are required, and section 5.9 discussed what they do. But a definition of what they are would be good to have in ' the code.




Street Address:

City:

State:

Zip:



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3.3.x Service Regulator. A pressure regulator installed by the serving gas supplier to reduce and limit theservice line gas pressure (e.g. street pressure) to point of delivery pressure (delivery pressure).



3.3xx_defintion_of_service_regulator.pdf original


Definitoin of service regulator is needed in order to clarify the definition of protected pressure.




Street Address:

City:

State:

Zip:



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TITLE OF NEW CONTENT

4.1.4.1 The engine shall be installed in a location such that the termination of the exhaust system is inaccordance with 8.2.3.


Currently, the Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines (“NFPA 37”) and the National Electrical Code (“NFPA 70 (NEC)”) do not address carbon monoxide (“CO”) poisoning hazards for stationary generators. A U.S. Consumer Product Safety Commission (“CPSC”) staff proposal to add generator installation requirements in the 2017 NEC to address carbon monoxide poisoning hazards resulted in the addition of an Informational Note in section 445.10 in the first draft of the NEC: “See NFPA 37, Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines for information on the location of generator exhaust.” Code-making Panel No. 13 believed that the CO hazard needed to be addressed during generator installation and stated: “Where the NEC addresses the permanent installation of combustible engine driven generators, it is prudent to reference NFPA 37. Prescriptive requirements for generator exhaust is under the purview of NFPA 37 and any proposed changes should be directed to that committee.”

The proposed additions to 4.1.4 and 8.2.3 are intended to prevent combustion gases exhausted from an engine generator from infiltrating a structure to reduce the risk of consumer CO poisoning injuries and deaths from stationary generators.

The CPSC’s databases include at least two incidents involving stationary generators installed outdoors that caused CO poisonings indoors. In a 2011 incident (documented in CPSC In-Depth Investigation report [“IDI”] 110912HNE1118), two victims died from CO poisoning from a 7 kilowatt (“kW”) propane engine-powered stationary generator installed in the immediate vicinity of a ground-level screened access vent/window for the crawlspace, which ran under the entire dwelling. In a 2005 incident (IDI 050830HNE2737), four victims suffered severe nonfatal CO poisoning from a propane engine-powered12 kW stationary generator. The stationary generator was installed on the side of the house, right under a large window, and next to the air conditioner ventilation system.

The U.S. Environmental Protection Agency’s Nonroad Small Spark-Ignition Engine Certification Data1 include data showing that the CO emission rates from propane and natural gas-fueled engines, such as those used in stationary generators, are often just as high as those from gasoline-fueled engines, such as those used in portable generators. For the 10-year period of 2004 through 20132, CPSC has reports of 15 non-work-related consumer CO deaths resulting from the exhaust of gasoline-fueled portable generators operating outdoors infiltrating the homes; there are other published sources that show CO deaths and injuries from outdoor operation of gasoline-fueled portable generators. A number of these sources document that the injured consumers generally used their portable generators, on average, only a few feet away from the nearest door or window.3,4 In 2013, the Centers for Disease Control and Prevention (“CDC”) began recommending that portable generators should never be placed less than 20 feet from an open window, door, or vent where exhaust can infiltrate into an enclosed area5; and CPSC is now making this recommendation as well.6 This recommendation is based, in part, on results of modeling studies performed by the National Institute of Standards and Technology (“NIST”) on the effects on indoor CO concentration profiles of operating an existing, gasoline-fueled carbureted generator outdoors.7,8

NFPA 37, NFPA 70, and UL 2200, Standard for Stationary Engine Generator Assemblies currently deal only with fire and shock hazards; they do not address the CO poisoning hazard related to exhaust emissions. The natural gas and propane engines used in stationary generators have CO emission rates comparable to gasoline-fueled portable generators,1 which have a long history of causing CO poisoning fatalities and injuries when placed outside the home, but close enough to the home to allow the exhaust to infiltrate indoors. NFPA 37 currently allows stationary generators to be located 5 ft. from openings in walls (e.g., windows, doors) and even closer placement, with NO minimum distance, if the adjacent structure wall is fire resistant or the generator enclosure will not ignite combustible materials outside the enclosure.

References:


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1. CO emission rates of natural gas and propane engines in the EPA’s exhaust emission database for small non-road spark-ignited engines have CO emission rates comparable to the gasoline-fueled engines: http://www.epa.gov/otaq/certdata.htm#smallsi.

2. Matthew V. Hnatov, U.S. Consumer Product Safety Commission, Incidents, Deaths, and In-Depth Investigations Associated with Non-Fire Carbon Monoxide from Engine-Driven Generators and Other Engine-Driven Tools, 2004-2013, http://www.cpsc.gov//Global/Research-and-Statistics/Technical-Reports/Home/Portable-Generators/GeneratorsandOEDTFatalities-2014-FINAL.pdf<, June 2014.

3. CDC, 2006. Carbon Monoxide Poisonings After Two Major Hurricanes - Alabama and Texas, August - October 2005, Morbidity and Mortality Weekly Report (“MMWR”), United States Centers for Disease Control and Prevention: 4. 4. CDC, Carbon Monoxide Poisoning from Hurricane-Associated Use of Portable Generators- Florida, 2004, MMWR 2005; 54:697-700. 5. Carbon Monoxide Poison Prevention, Centers for Disease Control and Prevention Web page, http://www.cdc.gov/features/copoisoning/.

6. U.S. Consumer Product Safety Commission Winter Weather Alert: Generators, CPSC website, http://www.cpsc.gov/onsafety/2014/01/winter-weather-alert-generators/.

7. Liangzhu (“Leon”) Wang, S. J. Emmerich, NIST Technical Note 1637, Modeling the Effects of Outdoor Gasoline Powered Generator Use on Indoor Carbon Monoxide Exposures, August 2009, http://fire.nist.gov/bfrlpubs/build09/art009.html. 8. Liangzhu (“Leon”) Wang, S. J. Emmerich, and R. Powell, NIST Technical Note 1666, Modeling the Effects of Outdoor Gasoline Powered Generator Use on Indoor Carbon Monoxide Exposures – Phase II, July 2010, http://www.cdc.gov/nceh/airpollution/pdfs/cdc_phaseii_tn1666.pdf.

**This proposal is that of the CPSC staff, has not been reviewed or approved by, and may not necessarily reflect the views of, the Commission.



Public Input No. 16-NFPA 37-2015 [Section No. 8.2.3.1] dependent


Submitter Full Name: DOUGLAS LEE

Organization: US CONSUMER PRODUCT SAFETY COM

Affilliation: US Consumer Product Safety Commission Staff

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Submittal Date: Wed Jul 01 16:20:00 EDT 2015


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Public Input No. 11-NFPA 37-2015 [ Section No. 4.1.4 ]

4.1.4 * Engines Located Outdoors.

Engines, and their weatherproof housings, if provided, that are installed outdoors shall be located at least1.5 m (5 ft) from openings in walls and at least 1.5 m (5 ft) from structures having combustible walls. A Theminimum separation distance shall not be required where either permitted to be decreased where anyone of the following conditions exist:

(1) All If all walls of the structure that are closer than 1.5 m (5 ft) from the engine enclosure have a fireresistance rating of at least 1 hour, no minimum separation distance shall be required .

(2) The weatherproof enclosure is constructed of noncombustible materials and it has beendemonstrated that a fire within the

the engine shall be permitted to be placed ata distance no lower than that used during the fire test from a combustible wall similar to the one usedin the test.

(3) * If calculations acceptable to the authority having jurisdiction have demonstrated that a fire within theengine enclosure will not ignite a combustible materials wall outside the enclosure at the distanceat which the engine is placed .

A.4.1.4 It has been demonstrated that, when engines fail, they can generate large fires and cause ignitionof nearby structures.

A.4.1.4 (2) Combustible materials exhibit different levels of combustibility or of ignitability. Examples ofcombustible exterior wall materials include various types of siding, such as vinyl, wood and polypropylene,as well as different exterior wall coverings (such as particleboard), exterior insulation and finish systemsand decorative laminates. It has been shown that these various combustible materials can have verydifferent levels of fire performance or of ignitability (see for example, NFPA 555, Guide on Methods forEvaluating Potential for Room Flashover). Therefore, the full scale fire tests should be conducted in thepresence of combustible materials that adequately represent the potential fire hazard to be expected at thelocation where the engine is to be placed. Moreover, it is advisable that engines located outdoors shouldbe placed at a separation distance from the nearest combustible wall that is greater than the distance atwhich the fire tests have been conducted, to provide a margin of safety. An example of the type of full scalefire tests that have been conducted, which will serve for guidance, can be found in a publication byHirschler (Marcelo Hirschler, “Testing of Residential Electrical Generators”, Fire and Materials Conf., SanFrancisco, CA, Jan. 31-Feb. 2, 2011, pp. 71-81, Interscience Communications, London, UK.)

A.4.1.4 (3) Calculation procedures, such as those given in NFPA 555, Guide on Methods for EvaluatingPotential for Room Flashover, are useful tools to assess the probability of safe engine placement.

The calculating procedure in Chapter 10 of NFPA 555 is similar to the Radiant Ignition of a Near Fuelalgorithm in NIST’s FPETOOL for calculation ignition from a nearby fire. It is a sound, engineering-basedmethod of predicting the risk of ignition from a fire.

The values in 4.1.4 and the reference to the NFPA 555 calculation method are the result of the calculationspresented to the committee in 1996. The calculations treated an engine fire as a vertical cylinder. The valuesin 4.1.4 changed somewhat in the 1998 edition of NFPA 37, based on those calculations. They arereasonably consistent with the requirements of the BOCA building code, which was in effect at the time. Thecommittee wanted to include a performance alternative in NFPA 37 . The reference in this annex section tothe NFPA 555 method provides guidance on how to evaluate proposed alternatives.

(Also add the proposed reference into an annex on informational references).


This section lacks the information an authority having jurisdiction needs to assess any reports provided by an engine manufacturer seeking to place engines close to combustible walls. There are no criteria for how to demonstrate that an engine fire will not ignite a combustible wall or for how close to the wall the engine can be

*If a full scale fire test involving an actual engine and a

combustible wall has demonstrated that the complete consumption of the combustibles within thetested engine will not cause ignition of the nearby wall,


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placed. The proposed language provides that information without being a detailed test protocol and without ruling out the use of calculations as a tool.1. In view of the close proximity between homes that often install engines or generators to ensure uninterrupted electrical supply, clear criteria for engine placement are essential to permit adequate enforcement. NFPA 37 does not contain enforceable criteria.2. This public input incorporates the wishes of the technical committee in the last cycle that NFPA 37 should not specify details of the full scale fire test procedure to be used for determining acceptable separation distances. This is reflected in the proposed wording.3. This comment also accepts the wishes of the technical committee that calculation methods be retained as an option. This is reflected in the proposed wording.4. This comment does not propose wording that would require specific test protocols but simply proposes wording that ensures a minimal level of safety, after the calculations or full scale fire tests have been conducted.5. This comment suggests the addition of the phrase “acceptable to the authority having jurisdiction” because that will ensure an “approved” level of safety.6. If an engine burns it can cause the ignition of nearby combustible walls. Whether ignition of combustible walls occurs will depend primarily on three factors: (a) the amount and fire performance of the combustible materials in the engine and the engineering design of the engine and its enclosure, (b) the materials contained in the combustible walls present and (c) the distance between the engine and the combustible walls.7. Fire tests have demonstrated that fire tests with some engines can be more severe when the generator/engine is not operating because the associated cooling fan in the generator/engine can result in the extinguishment of the fire when the generator/engine is operating but not when the generator/engine is idle. This has been shown for at least two engine designs. (a) Jason Huczek (Southwest Research Institute) [“Custom Fire Testing of Power Generators for NFPA 37 Compliance”, at the NFPA 2010 Annual Meeting, Session T68, June 9, 2010] and (b) Marcelo Hirschler [“Testing of Residential Electrical Generators”, Fire and Materials Conf., San Francisco, CA, Jan. 31-Feb. 2, 2011, pp. 71-81, Interscience Communications, London, UK]. A proposed reference to the latter work, which involved full scale fire tests, is proposed to be added to NFPA 37.8. There can be no assurance that every generator/engine will be provided with an adequate fan. Therefore, full scale fire tests or calculations should be conducted with both the engine operating and the engine idle. However, that requirement is not included here, to allow maximum flexibility for the fire test.9. The full scale fire tests or calculations leading to the determination of the safe location distance need to be conducted in such a way that there is complete consumption of the combustible materials in the engine/enclosure to ensure that the full scale fire tests or calculations actually address the fire hazard.10. If the full scale fire tests or calculations do not result in complete consumption of the combustible materials in the engine there can be no assurance that the results are fully representative of the actual fire hazard.11. There are different types of combustible wall materials that are in common use and the full scale fire tests need to be conducted using either the wall materials to be used in the actual installation or the combustible wall materials with the poorest fire performance. Fire tests have demonstrated that polypropylene siding is a more combustible wall material than either wood siding or vinyl (PVC) siding. Peak heat release rate data for polypropylene, wood and PVC siding materials are shown below.12. The distance between the engine and the combustible walls should provide be a reasonable margin of safety so that if the tests are conducted at a distance of, for example 1 ft., the engine enclosure should not be permitted to be placed closer than 1.5 ft. (i.e. a 50% margin of safety).13. This public input proposes the elimination of the requirement that the weatherproof enclosure be constructed of noncombustible materials because that is neither a needed requirement (if the engines have been properly designed) and has long been ignored by manufacturers. For the vast majority of engines the weatherproof enclosures contain some combustible components (such as knobs, for example) and their presence or absence is of no consequence if a fire that destroys all combustible materials does not cause wall ignition, and that is the key issue.

Heat release rate of siding materials (calorimeter testing)Vinyl (PVC) siding: 187 kW/m2Cedar siding: 309 kW/m2Polypropylene siding: 546 kW/m2

Note that existing annex text has been included in this public input as well as proposed revised annex text.



Public Input No. 12-NFPA 37-2015 [Section No. A.4.1.4(2)]

Public Input No. 29-NFPA 37-2015 [Section No. 4.1.4]


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Public Input No. 30-NFPA 37-2015 [Section No. B.2]


Submitter Full Name: MARCELO HIRSCHLER

Organization: GBH INTERNATIONAL

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Submittal Date: Mon Jun 29 12:59:28 EDT 2015


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4.1.4 Engines Located Outdoors.

Engines, and their weatherproof housings, if provided, that are installed outdoors shall be located at least1.5 m (5 ft) from openings in walls and at least 1.5 m (5 ft) from structures having combustible walls. Aminimum separation shall not be required where either of the following conditions exist:

(1) All walls of the structure that are closer than 1.5 m (5 ft) from the engine enclosure have a fireresistance rating of at least 1 hour.

(2) The weatherproof enclosure is constructed of noncombustible materials and it has beendemonstrated

The full scale fire test shall involve a worst case scenario of a fullyinvolved engine.


This is a more generic approach to that PI 11 to include requirements for a full scale fire test. The same justification is valid and the same revisions would be necessary for the annex note (as shown in PI 12).

The substantiation for PI 11 is not being repeated here for the purposes of brevity.









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* When documentation regarding a full scale fire test of the engine acceptable to the

AHJ has been provided demonstrating that a fire within the enclosure will not ignite combustiblematerials outside the enclosure.


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5.1.1

Gas piping shall be installed in accordance with the following methods:

(1) All fuel gas systems at service pressures equal to or less than a gauge pressure of 860 kPa (gaugepressure of 125 psi) shall be installed in accordance with NFPA 54, National Fuel Gas Code.

(2) All fuel gas systems at service pressures in excess of a gauge pressure of 860 kPa (gauge pressureof 125 psi), other than LP-Gas systems, shall be installed in accordance with ANSI/ASME B31.3,Process Piping.

(3) LP-Gas systems, whether liquid or vapor phase, shall be installed in accordance with the provisionsof NFPA 58, Liquefied Petroleum Gas Code.

(4) Biogas piping systems shall be installed in accordance with the provisions of ANSI/GSA 8149.6.



5.1.1_ANSI_CSA_B149_6_ref.pdforiginal


ANSI/GSA 8149.6 is a code for digester gas, landfill gas, and biogas generation and utilization. This code covers the proper gas piping requirements when using such gases.




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5.1.3

Approved metallic flexible connectors shall be permitted for protection against damage caused bysettlement, vibration, expansion, contraction, or corrosion. All flexible connectors used for vibrationdampening shall be properly anchor and installed according to manufacturer's instructions.



5.1.3_flex_hose.pdf original


Too many installation use flexible connectors, and there is no proper anchoring of the flex hose. This whips the gas train, and increasing the risk of causing significant damage to devices and components upstream.




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5.2.x. (6)*1f a high-pressure limit control trips. a manual reset shall be required to re-start the engine.


Manual reset is required so that the failed component can be identified and replaced before other components, such as diaphragms for sensing andcontrol, are damaged by a repeat high-pressure condition.




Public Input No. 27-NFPA 37-2015 [Section No. A.5.2]

Public Input No. 28-NFPA 37-2015 [New Section after A.5.1.2]




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5.2.1

Gas trains, as defined in 3.3.5, shall contain at least the following safety components:

(1) An equipment isolation valve

(2) A gas pressure regulator, if the prime mover does not operate at the gas supply pressure

(3) Two automatic safety shutoff valves (ASSVs)

(4) A manual leak test valve for each ASSV or an alternative means of proving the full closure of theASSV

(5)

(6)

(7) A vent valve or a valve proving system (VPS) for inlet gas pressures greater than a gauge pressure of14 kPa (gauge pressure of 2 psi)

(8) A flame arrester, where biogases are used and there is risk of having oxygen in the biogas

(9) A gas filter or strainer

(10)





Public Input No. 26-NFPA 37-2015 [New Section after 5.2.1]

Public Input No. 27-NFPA 37-2015 [Section No. A.5.2]




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* A low-pressure limit control for engines with a 732 kW (2.5 million Btu/hr) full-load input or greater

* A high-pressure limit control (manual reset) for engines with a 732 kW (2.5 million Btu/hr) full-loadinput or greater

* Any other components or equipment that the manufacturer requires for safe operation


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Public Input No. 20-NFPA 37-2015 [ Section No. 5.3.2.1 ]

5.3.2.1 Such relief valves and any

If the protected pressure to the equipment isolation valve exceeds the pressure rating of any downstreamcomponent, an overpressure protection device shall be installed. either upstream or downstream of theequipment isolation valve.

5.3.2.2 The overpressure protection device. when required in 5.3.2.1. shall provide a protected pressure thatis equal to or lower than the lowest rated. downstream component or device on the gas train

5.3.2.3 The overpressure protection device shall be one of the following:

(I) A second regulator in series with the supply pressure regulator

(2) A monitoring regulator installed in series with an operating regulator

(3) A pressure relief valve

(4) An overpressure cutoff device. such as a slam-shut valve or a high-pressure switch in combination withan adequately rated shutoff valve

5.3.2.4 If a pressure relief valve is used to comply with 5.3.2.1. the pressure relief valve and all connectedpiping shall be sized to

ventfully relieve the required volume of gas resulting from the failure of the nearest, upstream pressure regulatorunder the following conditions:

1 . The pressure regulator has failed in the wide open position.

2. The pressure. at which the relief capacity to be sized. shall be based on the protected pressure to thepressure relief valve.

5.3.2.5 The overpressure protection device shall have a pressure rating that is equal to or greater than theprotected pressure to the overpressure protection device.

5.3.2.6 Each gas train. for which an overpressure protection device is required in 5.3.2. 1. shall be designedand installed so that an overpressure condition is detectable.



5.3.1.1_OPD_requirements_.pdf original


Moves the annex requirements in A.5.2.1 (1 0) and provides minimum requirements for properly using and apply overpressure protection devices




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Public Input No. 1-NFPA 37-2014 [ Section No. 5.4.3 [Excluding any Sub-Sections] ]

The ASSVs shall stop the flow of fuel within 1 second within 2 seconds in the event the engine stops fromany cause. The ASSV shall fail closed without an externally applied source of power.


The change to 2 seconds is to match ANSI Z21.21


Submitter Full Name: Steve Oxtoby

Organization: Kohler Power Systems

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City:

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Submittal Date: Tue Oct 07 10:23:41 EDT 2014


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5.4.3.1*

It For prime movers below 400,000 btu/hr and if operating at inlet pressures of 2PSI or less, it shall bepermissible to replace one of the ASSVs required by Section 5.2 with one of the following devices,provided the device will automatically shut off the flow of fuel within 1 second if the engine stops from anycause:

(1) Carburetion valve

(2) Zero governor–type regulating valve

(3) Auxiliary valve


For large engines, it is a very unsafe practice to use a zero governor type regulating valve as an alternative to an ASSV for the following reasons:1) It does not shut off the flow of gas to the engine. The engine must first stop, then the zero governor type regulating valve disc closes in response to the negative pressure signal from the gas engine. There is no "safety" shutoff function in a zero governor regulator, and this type of operation and level of safety is not what is intended in a safety shutoff valve.2) If the diaphragm ruptures, which is the failure mode of zero governor type regulating valves, the failure results in a complete bypass around the closing disc. Thus, they cannot be considered a close-off valves. 3) Moreover, NFPA 37-2010 requires a vent valve when the supply pressure is above 2 PSI. The vent valve acts as a safety device to eliminate the buildup of gas pressure on the downstream valve in the case that the upstream valve leaks. In order for this safety feature to work properly, the downstream shutoff valve must be closed and a tight shutoff-type valve, otherwise, gas flows into the gas engine if the upstream shutoff valve leaks. Relaying on a zero governor regulating valve as the downstream shutoff valve defeats the safety feature of the vent valveIt can be easily be field adjusted to remove open, even if the engine has stopped.4) It can be easily be field adjusted to remove open, even if the engine has stopped. 5) It can also have the atmospheric side backloaded, and this connection can be connected is such a way that when the engine cranks (air pressure in the turbo charger), the zero governor regulator opens because of the air pressure backloading the diaphragm. Such a function defeats safety intended with having two automatic valves closed between the gas engine and the fuel supply.




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Submittal Date: Tue Jul 07 10:06:08 EDT 2015


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See Substantation

6.6.3

Piping for fuel tanks, other than engine-mounted tanks, shall be in accordance with the provisions of6.6.3.1 through 6.6.3.3, except as provided for in 6.6.3.4.

6.6.3.1

Piping for fuel tanks shall meet the applicable requirements of Chapters 21 and 27 of NFPA 30, Flammableand Combustible Liquids Code.

6.6.3.2

Tanks shall be filled by a closed piping system.

6.6.3.3

The fill pipe for each tank shall be provided on an exterior wall of the room or structure enclosing the tank ata point at least 600 mm (24 in.) from any building opening at the same or lower level.

6.6.3.4

A fill pipe terminating in accordance with 6.6.3.3 shall not be required for tanks that are filled manually atthe fill connection on the tank, provided that the tank and its fill connection are located within the spillcontainment required by 6.3.2.4, 6.3.5.3, or 6.3.6.3 and the filling operation is constantly attended.



TIA_37-15-1.pdf TIA 37-15-1


NOTE: This public input originates from Tentative Interim Amendment No. 37-15-1 (Log 1102) issued by the Standards Council on 8/14/14 and per the NFPA Regs., needs to be reconsidered by the Technical Committee for the next edition of the Document.

Substantiation and Emergency Nature provided by the TIA submitter:The purpose of this Tentative Interim Amendment (TIA) is to reinstate an important safety provision of earlier editions of NFPA 37 that was inadvertently deleted in the processing of the current 2010 edition. This requirement appears in the prior (2006) edition of NFPA 37 as Subsection 9.3.2..Technical Validity: Proposal 37-20 (Log #CP19) in the Fall 2009 Report on Proposals (ROP) proposed a rewrite of Chapter 9 of NFPA 37. Proposal 37-20 was accepted by the Technical Committee on InternalCombustion Engines and the text being proposed for reinstatement by this TIA appears in the proposal as Subsection 9.3.2. Comment 37-7 (Log #6) proposed amendments to the rewrite of Chapter 9 in the form of anew rewrite of the text beginning with Subsection 9.2.1 and extending to the end of the chapter. This comment also was accepted.Unfortunately, the text of Subsection 9.3.2 from the 2006 edition was not included in the text of the public comment and, therefore, does not appear in the text accepted therein. A poll of the Technical Committee members disclosed that it was never anyone’s intent to delete this provision and all agreed the text needs to be reinstated.This TIA reinstates the provision, numbered accordingly.

Emergency Nature: Failure to properly purge the exhaust system of a gas turbine can result in a significant quantity of fuel remaining in the system. History has shown that this residual fuel can igniteexplosively during turbine light off, resulting in significant damage to the system, including catastrophic rupture of the exhaust system with atten



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Submitter Full Name: TC on INT-AAA

Organization: Technical Committee on Internal Combustion Engines

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Submittal Date: Tue May 05 13:49:27 EDT 2015


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8.2.3.1 *

Exhaust systems shall terminate outside the structure at a point where hot gases , and sparks , orproducts of combustion will discharge to a safe location. Products of combustion shall discharge at least20 feet from any opening in a structure, such as a window, door, crawl space access at or below gradelevel, or ventilation opening. The distance shall be measured from the generator exhaust systemtermination to the closest point on the structure opening. Exhaust systems shall not terminate understructures (including loading platforms).






NFPA 37, NFPA 70, and UL 2200, Standard for Stationary Engine Generator Assemblies currently deal only with fire and shock hazards; they do not address the CO poisoning hazard related to exhaust emissions. The natural gas and propane engines used in stationary generators have CO emission rates comparable to gasoline-fueled portable generators,1 which have a long history of causing CO poisoning fatalities and injuries when placed outside the home, but close enough to the home to allow the exhaust to infiltrate indoors. NFPA 37 currently allows stationary generators to be located 5 ft. from openings in walls (e.g., windows, doors) and even closer placement, with NO minimum distance, if the adjacent structure wall is fire resistant or the generator enclosure will not ignite


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combustible materials outside the enclosure.

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Public Input No. 17-NFPA 37-2015 [Section No. A.8.2.3.1]





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Public Input No. 12-NFPA 37-2015 [ Section No. A.4.1.4(2) ]

A.4.1.4(2)

Compliance can be demonstrated by full-scale fire tests or by calculationIt has been demonstrated that, when engines fail, they can generate large fires and cause ignition ofnearby structures.

A.4.1.4 (2) Combustible materials exhibit different levels of combustibility or of ignitability. Examples ofcombustible exterior wall materials include various types of siding, such as vinyl, wood and polypropylene,as well as different exterior wall coverings (such as particleboard), exterior insulation and finish systemsand decorative laminates. It has been shown that these various combustible materials can have verydifferent levels of fire performance or of ignitability (see for example, NFPA 555, Guide on Methods forEvaluating Potential for Room Flashover). Therefore, the full scale fire tests should be conducted in thepresence of combustible materials that adequately represent the potential fire hazard to be expected at thelocation where the engine is to be placed. Moreover, it is advisable that engines located outdoors shouldbe placed at a separation distance from the nearest combustible wall that is greater than the distance atwhich the fire tests have been conducted, to provide a margin of safety.An example of the type of full scalefire tests that have been conducted, which will serve for guidance, can be found in a publication byHirschler (Marcelo Hirschler, “Testing of Residential Electrical Generators”, Fire and Materials Conf., SanFrancisco, CA, Jan. 31-Feb. 2, 2011, pp. 71-81, Interscience Communications, London, UK.)

A.4.1.4 (3) Calculation procedures, such as those given in NFPA 555, Guide on Methods for EvaluatingPotential for Room Flashover , are useful tools to assess the probability of safe engine placement .

The calculating procedure in Chapter 10 of NFPA 555 is similar to the Radiant Ignition of a Near Fuelalgorithm in NIST’s FPETOOL for calculation ignition from a nearby fire. It is a sound, engineering-basedmethod of predicting the risk of ignition from a fire.

The values in 4.1.4and the reference to the NFPA 555 calculation method are the result of the calculationspresented to the committee in 1996. The calculations treated an engine fire as a vertical cylinder. Thevalues in 4.1.4 changed somewhat in the 1998 edition of NFPA 37, based on those calculations. They arereasonably consistent with the requirements of the BOCA building code, which was in effect at the time.The committee wanted to include a performance alternative in NFPA 37 . The reference in this annexsection to the NFPA 555 method provides guidance on how to evaluate proposed alternatives.

(Also add the proposed reference into an annex on informational references).


This is tied to the proposed change to 4.1.4, and further information for conduction of a full scale fire test are proposed to be shown in the body of the standard.









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Submittal Date: Mon Jun 29 13:36:16 EDT 2015


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Public Input No. 28-NFPA 37-2015 [ New Section after A.5.1.2 ]

A.5.2.x. A Manual reset feature within the safety circuitry is required so that the all high gas conditions canbe identified before other components, such as diaphragms for sensing and control. are damaged byrepeated high-pressure conditions. The manual reset function can be integrated into the high gas switch orbe integrated within the engine controller.









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Public Input No. 35-NFPA 37-2015 [ New Section after A.5.1.2 ]

A.5.1.3 Not installing flexible connectors properly, if used to dampen vibration, and according tomanufacturer's instructions, significant damage to the upstream devices and components can occur, one ofwhich is premature and

catastrophic failure of gas connections. Consider the following when using a flex connector for vibrationdampening.

1. Since most machinery vibrates in a radial direction from the main shaft, the flex hose should be installedparallel to the shaft (i.e. in line with the engine).

2. Install a flex hose in a pre-stress condition (e.g. minimum offset/displacement).

3. Do not install a flexible hose in the gas line and then attempt to pull, compress, or torque in order to alignflex hose into position

4. Piping and the flex hose should be lined up within a maximum of 1/8". If using a flex hose toaccommodate misalignments, an additional or a longer hose may be needed to dampen the vibration.

5. In order for a flex hose to absorb movement, it must be properly anchored. Installing an anchor near thehose at the opposite end of the source of motion is a fundament rule. A flex hose increases flexibility. Thisadded flexibility can result in extreme deflection being applied to both the pipe and the metal hose,potentially adding large forces similar to a "snap-the-whip" action.

6. Piping must be supported by hangers or anchors so that its weight is not carried by the flexible connector.Excessive weight can compress the hose and relax the braid tension.

7. A rigid anchor installed within 4 pipe diameters of the flex hose should be installed to prevent "snap-the-whip" of the upstream components.

8. For best results, add a second anchor within 10 pipe diameters upstream.


Recommend adding annex information to provide special consideration, which are often overlooked, when using flex connectors to dampen vibration.




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Public Input No. 27-NFPA 37-2015 [ Section No. A.5.2 ]

A.5.2

The requirements in this section state the minimum requirements for compliance with this standard. Thesecontrols and valves are required as part of the prime mover installation and are to be dedicated solely to thesingle individual prime mover. These components of the gas train might or might not be supplied by themanufacturer of the prime mover. Authorities having jurisdiction and manufacturer’s data sheets for gastrain components might have additional requirements. Prior editions of this standard required an automaticcontrol valve, which is an operating component to control the engine under load and not a safety device.Therefore, the requirement for an automatic control valve is no longer within the scope of NFPA 37.

For calculations, the fuel input rating is to be based on the higher heating value (HHV), also called totalheating value, which is the number of British thermal units produced by the combustion, at constant

pressure, of 1 ft3 (0.028 m3) of gas when the products of combustion are cooled to the initial temperatureof the gas and air, when the water vapor formed during combustion is condensed, and when all necessarycorrections have been applied.

The following paragraphs describe the basis for the requirements in this standard that are applicable toeach component of the gas train:

(1) The equipment isolation valve is installed to allow the gas supply to a single prime mover to be shutoff without affecting other equipment. This valve could be used in an emergency, but the primaryapplication is the isolation of the prime mover for maintenance of the prime mover and/or the gas trainwithout a danger of a gas leak.

(2) The regulator provides steady gas pressure to the engine for stable operation. With its own regulator,the prime mover will be less affected by pressure spikes or dips caused by the operation of otherloads in the plant or on the same gas supply system.

(3) The automatic safety shutoff valves (ASSVs) ensure the automatic shutoff of the fuel supply to theprime mover in the event the prime mover stops for any reason or there is a serious fuel or controlproblem.

(4) The manual leak test valve is for periodic testing of the ASSV. An ASSV requires periodic testing(proofing) to verify complete blockage of the gas flow. The ASSV manual leak test valve must beinstalled downstream of but prior to any other device that can block the flow of gas. Somemanufacturers build in proofing provisions for this valve as part of the ASSV; it is permissible to usethis provision for the manual leak test valve if it is located on the downstream side of the ASSV. Amanual leak test valve can consist of a shutoff valve, suitable for the specific fuel, that is capped orplugged when not being used to conduct a leak test.

(5) The low-pressure switch shuts down the engine if the gas pressure to the engine falls below the levelwhere the engine can operate properly, thereby reducing the risk of unburned gas discharge throughthe exhaust. Either a manual or automatic resettable switch is acceptable.

(6) The high-pressure switch (with manual reset) protects against high pressure in the gas supply. Ahigh-pressure condition is usually caused by failure of a component, such as a regulator. Manualreset is required so that the failed component can be identified and replaced before othercomponents, such as diaphragms for sensing and control, are damaged by a repeat high-pressurecondition.

Figure A.5.2 illustrates the typical arrangement of components of a gas train.

Figure A.5.2 Typical Piping Arrangement of a Gas Train.


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Public Input No. 32-NFPA 37-2015 [ Section No. A.5.2.1(10) ]

A.5.2.1(10)

An example of an additional component might be an overpressure protection device that protectsdownstream components if the supply pressure exceeds the pressure rating of any such downstreamcomponent. Examples of such overpressure protection devices would be any of the following:

(1) A second regulator in series with the supply pressure regulator

(2) A monitoring regulator installed in series with an operating regulator

(3) A full-capacity pressure relief valve

(4) An overpressure cutoff device, such as a slam-shut valve or a high-pressure switch in combinationwith an adequately rated shutoff valve


Delete annex since annex reuirements in A.5.2.1(10) and move to main body text.




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Public Input No. 33-NFPA 37-2015 [ Section No. A.5.3.1.2 ]

A.5.3.1.2

A full Lock-up is a feature of some pressure regulators where under no-flow conditions there is a maximumpressure increase downstream of the regulator (aka "lock-up pressure"). This lockup pressure should besignificantly less than the inlet pressure to the regulator under. A lock-up regulator generally permits notmore than 150% of the outlet pressure setting or 5 in. W.C, whichever is a specially designed regulatorthat can shut off tight, thus stopping the flow of gas entirely if the load goes to zero and preventing thedownstream pressure from rising more than 51 mm (2 in.) Hg above the set point greater, however. this canvarv for a given regulator design and application. In addition, there are variables for each regulator designthat affect the lock-up pressure. (e.g. ambient temperature, condition of the regulator disc after some use,flow, inlet pressure, outlet pressure setting, the volume between the regulator and the first downstreamsafety shutoff : valve, the sizing of the regulator, and the length of the atmospheric vent connection, ifvented) .


Propose to add this annex information to aid the industry on what the characteristic of lockup type regulators are and what affects the lockup pressure for a given application.




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Public Input No. 17-NFPA 37-2015 [ Section No. A.8.2.3.1 ]

A.8.2.3.1

Exhaust systems should not terminate under structures (including loading platforms) or where exhaust gasentrainment into ventilation intakes might occur.






NFPA 37, NFPA 70, and UL 2200, Standard for Stationary Engine Generator Assemblies currently deal only with fire and shock hazards; they do not address the CO poisoning hazard related to exhaust emissions. The natural gas and propane engines used in stationary generators have CO emission rates comparable to gasoline-fueled portable generators,1 which have a long history of causing CO poisoning fatalities and injuries when placed outside the home, but close enough to the home to allow the exhaust to infiltrate indoors. NFPA 37 currently allows stationary generators to be located 5 ft. from openings in walls (e.g., windows, doors) and even closer placement, with NO minimum distance, if the adjacent structure wall is fire resistant or the generator enclosure will not ignite combustible materials outside the enclosure.

References:


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Public Input No. 16-NFPA 37-2015 [Section No. 8.2.3.1] dependent





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Public Input No. 6-NFPA 37-2015 [ Section No. B.1.2 ]

B.1.2 Other Publications.

B.1.2.1 ANSI Publications.

American National Standards Institute, Inc., 25 West 43rd Street, 4th floor, New York, NY 10036.

ANSI B133.4, Gas Turbine Control and Protection Systems, 2007 (withdrawn 1997) .

ANSI B133.6, Procurement Standard for Gas Turbine Ratings and Performance, 1994 (Out of Print) .

ANSI Z21.21, Automatic Valves for Gas Appliances, 2005 4th edition, 2012 .

B.1.2.2 ASHRAE Publications.

ASHRAE, 1791 Tullie Circle, NE, Atlanta, GA 30329-2305.

ASHRAE, Handbook — Fundamentals, 1997 2013 .

ASHRAE and SFPE, Design Handbook of Smoke Management Systems Control Engineering , 19922012 .

B.1.2.3 ASTM Publications.

ASTM International, 100 Barr Harbor Drive, P.O. Box C700. West Conshohocken, PA 19428-2959.

ASTM SI 10 SI10 , Standard for the Use of the International System of Units (SI): The Modern MetricSystem, 1997 2010 .

B.1.2.4 CSA Publications.

Canadian Standards Association, 5060 Spectrum Way, Mississauga 178 Rexdale Blvd, Toronto , ON, L4W5N6, Canada Canada M9W 1R3 .

CSA B149.6, Code for Digester Gas and Landfill Gas Installations for Piping Materials and Practices, 2011.

B.1.2.5 SAE Publications.

Society of Automotive Engineers SAE International , 400 Commonwealth Drive, Warrendale, PA 15096.

SAE J1349, Engine Power Test Code, Spark Ignition and Compression Ignition, 1990 2011 .

B.1.2.6 UL Publications.

Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096.

UL 2080, Fire Resistant Tanks for Flammable and Combustible Liquids, 2000.

UL 2085, Protected Aboveground Tanks for Flammable and Combustible Liquids, 1997, revised 2010.


Referenced current SDO names, standard names, and years.



Public Input No. 5-NFPA 37-2015 [SectionNo. 2.3]

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

Public Input No. 4-NFPA 37-2015 [GlobalInput]




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Public Input No. 30-NFPA 37-2015 [ Section No. B.2 ]

B.2 Informational References. (Reserved)

Marcelo Hirschler, “Testing of Residential Electrical Generators”, Fire and Materials Conf., San Francisco,CA, Jan. 31-Feb. 2, 2011, pp. 71-81, Interscience Communications, London, UK.


The reference proposed to be added by PI 12.









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1

Benedetti, Bob

From: Benedetti, BobSent: Thursday, August 14, 2014 3:54 PMTo: 'Danner, Larry (GE Power & Water)'Subject: RE: Applicability of NFPA Codes & Standards to Marine installations

Larry: I agree with Denise. Maybe an annex item is in order here. Will add to next agenda. Bob Benedetti From: Danner, Larry (GE Power & Water) [mailto:[email protected]] Sent: Tuesday, July 08, 2014 6:42 AM To: Beach, Denise Cc: Benedetti, Bob Subject: RE: Applicability of NFPA Codes & Standards to Marine installations Good morning Denise, Thank you for your quick response. Regards,

Larry Danner, CSP Principal Engineer Product Safety Engineering GE Power & Water

From: Beach, Denise [mailto:[email protected]] Sent: Monday, July 07, 2014 5:13 PM To: Danner, Larry (GE Power & Water); Benedetti, Bob Subject: RE: Applicability of NFPA Codes & Standards to Marine installations Larry, I believe that the installation you describe would fall under the scope of NFPA 85 because NFPA 85 is not limited to installations in permanent, land‐based structures. If for some reason you need to seek an equivalency, then the AHJ is the US Coast Guard. Please let me know if you need any further information from me. Best Regards, Denise

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From: Danner, Larry (GE Power & Water) [mailto:[email protected]] Sent: Monday, July 07, 2014 11:28 AM To: Benedetti, Bob; Beach, Denise Subject: Applicability of NFPA Codes & Standards to Marine installations Importance: High Bob and Denise, I am hoping this finds you both in good health and good cheer! We have a project that will place a GT on an LNG Transport ship and are trying to understand if NFPA guidance would be applicable. One of my colleagues thought this may fall under NFPA 37 and / or NFPA 85. My initial reaction is this would, as a maritime situation, fall under Coast Guard regulations; however, I wanted to make sure that supposition is correct. I believe the answer for NFPA 37 is “no” as this would be considered a “portable” unit that does NOT get connected to a fixed structure:

Bob, Could you please confirm my understanding is correct? Denise, I could not identify any similar language in NFPA 85 that would limit the applicability of the Code to any exhaust treatment equipment (HRSG, SCR, etc.) that may be installed with the turbine. Can you confirm the applicability of NFPA 85 in this situation? A response at your earliest convenience would be appreciated to keep the project moving forward. Thanks and regards,

Larry Danner, CSP Principal Engineer Product Safety Engineering GE Power & Water Power Generation Products T: (864) 254-4185 F: (864) 254-4228 D: 8*288-4185 E: [email protected] W: www.gepower.com 300 Garlington Rd. GTTC 200D GREENVILLE, SC 29615 GE GAS TURBINES, LLC GE imagination at work

Sub-paragraph (3) is causing us uncertainty, we are not sure what this really means. I note the entiresection is marked with a change bar, but could NOT find the change recommendation(s) in either theROP or the ROC documents for the 2010 update. So, here are the “choices” we came up with forwhat MIGHT be intended by the sub-paragraph:

The technician gains access to the engine by opening a door or removing a panel to do his work, butcannot physically enter the enclosure.

The access into the enclosure must be located in the “nonhazardous outside area” identified in sub-paragraph (2) and the technician then moves about inside the enclosure to do his work. We initially thought the first interpretation would be the intent, but would like to get a reading on this. So there are two question: Is the first bullet interpretation above the intent of 4.3(3)? Is the second bullet interpretation above the intent of 4.3(3)? If the answer is NO to both, is it possible to be advised of the actual intent? I know, that smacks of aformal interpretation from which I will, of course, recuse myself! Thanks and regards,

Larry Danner, CSP Principal Engineer Product Safety EngineeringGE Power & WaterPower Generation Products T: (864) 254-4185 F: (864) 254-4228 D: 8*288-4185 E: [email protected]: www.gepower.com 300 Garlington Rd. GTTC 200D GREENVILLE, SC 29615 GE GAS TURBINES, LLCGE imagination at work


http://www.gepower.com/

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Benedetti, Bob

From: Oxtoby Steve <[email protected]>Sent: Thursday, October 02, 2014 11:58 AMTo: Benedetti, BobSubject: NFPA37 technical committee

Good morning Bob, I have a technical question on NFPA37 and as I now sit on the technical committee I was not sure if I needed to ask through regular channels or not. My question pertains to the ASSV’s for gaseous fueled engines. In A.3.3.12.1 the standard states the a valve that meets ANSI Z21.21 meets the definition of a ASSV, but in 5.4.3 the standard states that the ASSV must close within one second. The closing time requirements listed in ANSI Z21.21‐2012 are that the valve must close within two seconds, 7.4.1 A C/I valve shall close in less than two (2) seconds after being de‐energized. The reason I am asking this is that I also sit on the UL2200 STP and we are having discussions on harmonizing UL2200 with NFPA37 more closely and the majority of the Z21.21 certified ASSV valve manufacturers that the genset manufacturers use do not have the testing data to support the 1 second closing time per NFPA37. Could I get more information on where the one second closing time requirement came from, or the rational why the ANSI21.21 requirements were deemed insufficient? Thanks, Steve Steve Oxtoby Senior Project Analyst 3rd Party Certifications, Codes and Standards KOHLER Co. | Kohler Power Systems Office: 920.457.4441 ext 33225 [email protected] Find complete power solutions at: Kohlerpower.com

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Benedetti, Bob

From: Danner, Larry (GE Power & Water) <[email protected]>Sent: Thursday, August 14, 2014 4:02 PMTo: Benedetti, BobSubject: RE: I would like to pick you brain for a moment

Thanks for that response. I personally do not like the idea of having back pressure against the gas train vents either. A note for your consideration comes from ISO 21789 (yes, I know that at least one member of the TC doesn’t feel that document means anything to NFPA 37 … ). In that document, the turbine community recognized the necessity to send the vent to a flare when the fuel has a toxic constituent (such as “sour gas” with 1 or 2% Hydrogen Sulfide). In that case, the ISO document permits a max back pressure of 0.5 BARg (7.4 PSIg) and it permits the inclusion of a normally open isolation valve in addition to the vent valve to permit maintenance after a fault in the system. BTW, the client has his turbine in a refinery …


From: Benedetti, Bob [mailto:[email protected]] Sent: Thursday, August 14, 2014 3:50 PM To: Danner, Larry (GE Power & Water) Subject: RE: I would like to pick you brain for a moment Hi, Larry: Yes, the intent here, as I read it, is that the piping between the two ASSVs has installed a vent valve that operates upon engine shutdown to dump any gas in the line directly to atmosphere. The valve must be of the fail-open type. The text states “shall discharge outdoors”, which tells me the intent is to dump directly to the surrounding area and not to any other system. Perhaps next cycle, we should say “shall discharge directly to outdoors”? Bob Benedetti From: Danner, Larry (GE Power & Water) [mailto:[email protected]] Sent: Monday, June 02, 2014 11:17 AM To: Benedetti, Bob Subject: I would like to pick you brain for a moment

Good morning Bob, In NFPA 37, we state:

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With this in the Annex:

The situation we have is a client that wants to connect the vent to his refinery’s flare stack system that has an approximate 25 PSIg back pressure (this through a fail open vent valve … ). The obvious issue for me is the refinery is NOT going to shut down to remove the back pressure as the repairs are being done so there is risk of the valve popping open. Yes, I know, one can add a manual valve in the vent system; however, I really HATE human dependent safety features. Two really bad scenarios here 1) the valve gets left open during maintenance exposing the maintainer to lots of really bad stuff if the automatic vent valve fails (such as a power failure) and 2) the valve is left closed after the maintenance and there is a problem that really needs the vent to work. We have proposed a separate, local vent for the turbine so as to not have the back pressure issue, but the client doesn’t want to spend the money to do so. Here is the crux of the matter, what is the intent of the term “depressurize”? Since that term has no specific value assigned to it within the Standard, the client is claiming his 25 PSIg flare system has depressurized the gas fuel system from the 450 PSIg normal supply pressure to a much lower pressure; therefore, so he is in compliance. Would you agree with this “interpretation” or would you take the position that the intent of “depressurize” is to reduce the pressure in the piping to atmospheric? Thanks and regards,

Larry Danner, CSP Principal Engineer Product Safety Engineering

GE Power & Water

Power Generation Products T: (864) 254-4185 F: (864) 254-4228 D: 8*288-4185 E: [email protected] W: www.gepower.com 300 Garlington Rd. GTTC 200D GREENVILLE, SC 29615 GE GAS TURBINES, LLC GE imagination at work

From: Benedetti, BobTo: "Lebowitz, Jeremy"Subject: NFPA 37 QuestionDate: Thursday, September 12, 2013 2:38:00 PM

Hi, Jeremy: Note that Paragraph 6.3.2.2 of NFPA 37 applies to fuel tanks that are “not in a room bythemselves”. Note also that the same paragraph requires tanks larger than this to be in a room“in accordance with 6.3.5 or 6.3.6”. The third sentence, in my opinion, applies to tanks that are“not in a room by themselves”. Otherwise, the second sentence is not logical and there is noincentive or reason for Subsections 6.3.5 or 6.3.6. Since the 1250 L (660 gal) maximum restriction on capacity in 6.3.2.2 is not stated in eitherSubsection 6.3.5 or Subsection 6.3.6, my interpretation of all three leads me to believe that asingle 5000 gal tank would be allowed inside a building, as long as it is in a room by itself, saidroom to be in compliance with Subsection 6.3.6. Please understand that this response is a personal opinion and does not constitute a FormalInterpretation of NFPA, as noted below and as described in Section 6 of NFPA’s RegulationsGoverning Committee Projects. It is not to be relied upon to definitively determine compliancewith any laws, ordinances, rules, or regulations. To determine legal compliance, you should referto the appropriate authority having jurisdiction or seek legal advice. It is not intended, nor shouldit be relied upon, to provide professional consultation or services. To determine the adequacy orsafety of any device or installation, you should consult with an appropriate professional. I hope this response is helpful. If you have a follow-up question related to this inquiry, pleasereply to this email. If you have another question on a separate topic or a different document,please return to the document information pages and submit your new question(s) by clicking onthe “Technical Questions” tab. R. P. Benedetti cc 37/IFI-------------------------------------------------------------------------------------------------------------------------Robert P. Benedetti, CSP, PEPrincipal Flammable Liquids EngineerNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169-7471617-984-7433617-984-7110 (FAX)617-571-8494 (CELL)[email protected] From: Lebowitz, Jeremy [mailto:[email protected]] Sent: Thursday, September 05, 2013 10:20 AMTo: Benedetti, BobSubject: NFPA 37 Question Hi Bob, I hope all is well with you. I have a brief technical question on a particular section of NFPA 37, 6.3.2.2(2006 / 2010 Editions). The text states: 6.3.2.2* Fuel tanks not in a room by themselves shall not exceed 2500 L (660 gal) capacity. Fuel tanks larger than 2500 L(660 gal) capacity shall be enclosed in a room in accordance with 6.3.5 or 6.3.6. Not more than one 2500 L (660 gal)capacity tank, or two or more tanks with an aggregate capacity of not more than 2500 L (660 gal), shall be connected to any



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Attachment No. A10

one engine.Exception: Fuel tanks of any size shall be permitted within engine rooms or mechanical spaces, provided the engine ormechanical room is designed using recognized engineering practices with suitable fire detection, fire suppression, andcontainment means to prevent the spread of fire beyond the room of origin. I have a case where it is desired to have a single tank with approx. 5,000 gal capacity located indoors. My question is, does the highlighted text apply where I am providing an enclosed fuel tank room per6.3.5 or 6.3.6, or in other words, am I allowed to connect a single tank larger than 660 gallons to agenerator if I protect it in accordance with 6.3.5 or 6.3.6 as applicable? Your response is greatlyappreciated. Best regards, Jeremy

Jeremy Lebowitz, P.E.(Registered in MA)Consultant–––––––––––––––––––––––––––Rolf Jensen & Associates, Inc.1661 Worcester Road - Suite 501Framingham, MA 01701 USAOffice: +1 508-620-8900 x 11043Fax: +1 508-620-0908www.rjainc.com RJA Project No.JL/ (This electronic message contains information which may be confidential or privileged. Ifyou are not the intended recipient of this message, be aware that any disclosure, copying,distribution or use of the contents of this information is prohibited. If you have receivedthis electronic transmission in error, please immediately notify the sender at the abovephone number.)

http://www.rjainc.com/

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Benedetti, Bob

From: Danner, Larry (GE Power & Water) <[email protected]>Sent: Wednesday, April 16, 2014 11:07 AMTo: Benedetti, BobSubject: FW: NFPA 37: need clarification for GT package to be installed in US market

Hello Bob, I received an internal request for interpretation of NFPA 37 and the necessity of considering the interior of a package containing a gas turbine as a “hazardous location”. If you could, please let me know if my interpretation of “enclosure” versus “room” and the necessity for the manufacturer of a packaged unit to classify the space based on analysis is in line with your understanding. THANKS!


From: Danner, Larry (GE Power & Water) Sent: Wednesday, April 16, 2014 10:17 AM To: Amoroso, Maria Pilar (GE Oil & Gas) Cc: Paglione, Luigi (GE Oil & Gas); Marra, Angelo (GE Oil & Gas) Subject: RE: NFPA 37: need clarification for GT package to be installed in US market Hello Maria, Since I am an active member of an NFPA Technical Committee, I am required to include the following statement: Please understand that this response is a personal opinion and does not constitute a Formal Interpretation of the NFPA, as noted below and as described in Section 6 of NFPA’s Regulations Governing Committee Projects. It is not to be relied upon to definitively determine compliance with any laws, ordinances, rules, or regulations. To determine the adequacy or safety of any device or installation, you should consult with an appropriate professional. To determine legal compliance, you should refer to the appropriate authority having jurisdiction or seek legal advice. Thank you for contacting me on this question. Rather than simply stating “yes” or “No” to your question, let me provide you the background and rationale for your understanding first then my recommendations. I believe the first element that needs to be addressed is how to define the “package” that surrounds the turbine. When NFPA 37 states “enclosure”, the intent of the text is a cover that fits closely over the equipment and servicing of the equipment is accomplished either by removing the enclosure or accessing the equipment through a hatch / removable panel. A good example of an engine with an “enclosure” is a home backup power unit such as those sold by Generac: http://www.generac.com/for-homeowners/home-backup-power Since the packaged turbine unit under consideration includes a door through which a person can enter the package and stand inside, it meets the definition of an “occupiable” area under NFPA 101 and would, therefore, be considered a “room” for the purposes of applying NFPA 37. For the rest of my discussion, I will use the term “enclosure” for the package as that is what we typically call it in our business.

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Now to the discussion of classification. The guidance within NFPA 37 was established based on IC engines. The fuel supply for IC engines will be one of four types:

Gravity fed liquid fuel to a carburetor (this is what existed in 1905) Low pressure (less than 7 PSIg / 0.5 BARg) gas to a metering valve in the air induction system Pressurized (typically less than 100 PSIg / 7 BARg) liquid or gas fuel injection

Clearly, this is quite different from the turbine that uses a continuous flow gas or liquid injection directly into the combustor at pressures above 250 PSIg / 17 BARg for gaseous fuels and near 1000 PSIg / 70 BARg for liquid fuels. When the Standard states classification is not “solely by reason of the engine fuel, lubricating oil, or hydraulic fluid”, the intent is that the existence of these materials does not necessarily require classification of the space. The manufacturer is expected to analyze the situation an apply classification of the space as appropriate based on that analysis. Since approximately 2002, the industrial gas turbine industry has been applying the Dilution Ventilation concept (proposed by the UK HSE team and developed with support by the Atkins group and GE, and later incorporated into ISO 21789 when it was published in 2009 – this is the next concept I need to drive in to NFPA 37 … ) to assure the explosion safety of the installations. While the concept was originated in the European Union, it has been adopted in many jurisdictions and embraced by the manufactures (who were all part of the ISO 21789 committee) worldwide following publication of the ISO standard. The approach normally assures the potentially ignitable volume of gas within the enclosed space is detected at a size that precludes damage to the turbine enclosure (precludes injury to persons standing next to the enclosure), and there is a hazardous gas protection system that acts to shut the turbine down if the leakage reaches a point that the explosive volume exceeds the criteria. This overall effect of this is the classification based on the criteria would be considered “Zone 2 NE” under IEC / EU regulations; which translates to “unclassified” under the US NEC. However, it must be understood that the basis for the dilution ventilation system is a leak that is categorized as “minor”; these are the typical leaks seen in service. Should the unit experience the occasional “major” leak, the dilution ventilation system is overwhelmed and a significant hazardous zone will exist within the space. For this reason. it has been deemed appropriate by GE (and others) to consider the interior of the turbine enclosure as a hazardous area. With best regards, Larry Danner, CSP Principal Engineer Product Safety Engineering GE Power & Water IMPORTANT NOTICE: This correspondence is not a Formal Interpretation issued pursuant to NFPA Regulations. Any opinion expressed is the personal opinion of the author, and does not necessarily represent the official position of the NFPA or its Technical Committees. In addition, this correspondence is neither intended, nor should it be relied upon, to provide professional consultation services.

From: Amoroso, Maria Pilar (GE Oil & Gas) Sent: Monday, April 14, 2014 8:00 AM To: Danner, Larry (GE Power & Water) Cc: Paglione, Luigi (GE Oil & Gas); Marra, Angelo (GE Oil & Gas) Subject: NFPA 37: need clarification for GT package to be installed in US market Dear Larry, we’d like to present ourselves we are Luigi Paglione, Maria Pilar Amoroso of Technical Regulation and Standard (TRS) engineering team of O&G business and Angelo Marra of ITO with expertise in electrical/instrumentation for GT turbine packages supported by several year of experience from Design engineer role. We write to you about NFPA 37, as we noted you are part of technical committee on internal combustion engines.

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1) We need your help to clarify the wiring requirements inside our gas turbines packages for US; in particular, let’s consider this example

Reading this requirement of NFPA 37

4.5 Electrical Installations. 4.5.1 Electrical installations in rooms containing engines shall comply with NFPA 70, National Electrical Code. 4.5.2 Engine rooms or other locations shall not be classified as hazardous locations as defined in Article 500 of NFPA 70, National

Electrical Code, solely by reason of the engine fuel, lubricating oil, or hydraulic fluid.

and considering the definition of enclosure according NFPA 37 (we haven’t see a definition of room)

3.3.2* Enclosure. A cover intended to protect an engine and related equipment. A.3.3.2 Enclosure. An enclosure is not considered to be a structure or a room.

As per our understanding, the requirement of point 4.5 does not apply to engine enclosures, so inside it NFPA 70 is not

applicable. a) Can we consider the package containing the gas turbine as shown in the example as an engine enclosure not subject to

point 4.5 of NFPA 37 and NFPA 70? And if so, b) can the GT package be considered as a “black box” standard manufacturer and therefore commercialized, sold and

installed “as is” without having issues with the Authorities Having Jurisdiction (AHJ)?

The reason of this question is particularly related to special cables selected for wiring inside the packages; we have some

concerns with suppliers not having evidences of compliance with NFPA 70 art. 500‐505 wiring methods.

2) Concerning this requirement 4.5.2 Engine rooms or other locations shall not be classified as hazardous locations as defined in Article 500 of NFPA 70, National

Electrical Code, solely by reason of the engine fuel, lubricating oil, or hydraulic fluid.

Can you help us to understand the aim of this requirement, in particular what determines in case of gas turbines that use fuel (gas and liquid) and lubricating oil (mineral & synthetic) only.

3) Do you know which States/AHJ apply NFPA 37 to gas turbine installations in US?

Thank you and kind regards

Maria Pilar, Luigi and Angelo

Maria Pilar Amoroso, Ph.D GE Oil & Gas TR&S Engineering - TMS

From: Danner, Lawrence M (GE Power & Water)To: Benedetti, BobSubject: Openings in wallsDate: Friday, March 22, 2013 8:35:10 AM

Good morning Bob, I am in the process of reviewing the public comments to NFPA 2 (all 608 pages worth …) and notedNFPA 55 has created a definition for an “unpierced wall” for their 2013 edition:

I suspect it is too late for 37 now, but I recall we had some significant discussions regarding openingsin walls and if the openings were not easily opened (sealed windows, bolted panels versus doors) theycould possibly be disregarded in determining if the installation met the applicable opening distancecriteria. Just thinking out loud, Larry Danner, CSP Principal Engineer Product Safety EngineeringGE Power & Water T: (864) 254-4185 F: (864) 254-4228 D: 8*288-4185 E: [email protected]: www.gepower.com 300 Garlington Rd. GTTC 200D GREENVILLE, SC 29615 GE GAS TURBINES, LLCGE imagination at work



http://www.gepower.com/

bbenedetti

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Attachment No. A12

1

Benedetti, Bob

From: Benedetti, BobSent: Tuesday, October 01, 2013 1:11 PMTo: Danner, Larry (GE Power & Water)Subject: RE: Gap in NFPA guidance for Combustion Turbines

Hi, Larry: I agree; we should look at this next cycle. I will add to the “Next Meeting” file. Bob

From: Danner, Larry (GE Power & Water) [mailto:[email protected]] Sent: Monday, September 30, 2013 2:10 PM To: Benedetti, Bob Subject: Gap in NFPA guidance for Combustion Turbines Hi Bob, A question has come up here that points to a gap in the guidance for combustion turbine exhaust systems. The question relates to purging of the exhaust flow path so as to avoid potential explosions from the existence of fuel within the exhaust either as a residual unburned quantity or from valve through leakage while shut down. NFPA 85 is very clear on this subject (section 8.8.4.2 to be specific) stating the conditions and limits for the purge. One “absolute” is for a five minute minimum purge duration. Very specific and comprehensive to include four options for determining the adequacy of the purge cycle. An absolute in all that discussion is the requirement that the purge cycle not be any less than 5 minutes. The “gap” occurs when the turbine is connected to a simple stack; NFPA 85 applicability for Combustion Turbines is states as: “1.1 (3) Fired or unfired steam generators used to recover heat from combustion turbines [heat recovery steam generators (HRSGs)] and other combustion turbine exhaust systems at any heat input rate.” This “applicability” is reiterated at Paragraph 8.1.1. When I chatted with Denise Beach about this, the sense I got was “other combustion turbine exhaust systems” was intended to include Selective Catalytic Converters (SCRs) and other exhaust equipment that affect the exhaust in one manner or another, but does NOT apply to the a simple exhaust duct (very large “pipe”, in essence). For the simple exhaust duct, which typically includes a vertical stack, one would then turn to NFPA 37 as the probable guidance document for the situation. When I look at Chapter 8, paragraph 8.1.4 has a discussion regarding ignition of unburned fuel (the hazard of concern) and the stated options are either strong enough to withstand the force of the ignition or to include: “provisions to relieve those forces without damaging the exhaust system.” The annex material goes on to state that the “built-in strength” of the exhaust normally meets the requirement (I firmly believe that for smaller IC engines) and that “relief valves, rupture disks or their equivalents” can be used if the exhaust strength is inadequate. For what is essentially a thin walled “sheet metal” duct designed to allow for the significant thermal gradients, the strength approach is not practical. Relief valves for 12 foot ducts tend to not be available and burst disks, while are practical, result in a significant down time to replace and can cause financial penalties as most power plants are contractually required to meet specific availability numbers.

bbenedetti

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Attachment No. A13

2

So, the folks that are designing the system say “well, it looks like I need to use the 5 minute purge minimum because there is no better guidance”. I point to the 1.5 Equivalency clause and say that a properly calculated purge cycle provides the “equivalent” protection to a burst disk, but some folks are a bit uneasy about taking that route. All that background shared, the two possible suggestions for the committee to look at in the future are:

1. Create a new paragraph that discusses exhaust system purge (primarily associated with turbines, but can be applied to IC engines, my colleagues at GE Jenbacher in Austria are looking at this for their very large engines with ~40 inch diameter exhaust systems).

2. Expand the Paragraph 8.1.4 discussion to include “purge” as a valid method to assure the safety of the system.

I don’t feel compelled to submit as a TIA (we are not seeing explosions), but would like to put in the hopper for the next revision to give the community a solid guideline. Thanks and regards,


GE Power & Water

Power Generation Products T: (864) 254-4185 F: (864) 254-4228 D: 8*288-4185 E: [email protected] W: www.gepower.com 300 Garlington Rd. GTTC 200D GREENVILLE, SC 29615 GE GAS TURBINES, LLC GE imagination at work

SAFETY TECHNOLOGY

Beating the heatAnsul LVS wet agent fire suppression system knocks down equipment fires — and keeps them down

By Chad ElmorE

While the instructors of Tyco Fire Protection Products’ three-day Ansul Fire School

got the next prop ready, students took a break from the heat. For several min-utes a propane-fueled torch heated the block, manifold and turbocharger of a solitary diesel engine. Finally, with the break over and the engine’s surface temperature above 1300°F, the torch was turned off and a fine mist of diesel fuel settled around the turbo, then burst into a fireball that covered the top of the engine.

It was one of the few thermal events that the students would not have to extinguish themselves that day. Eight nozzles above and below the turbo automatically bathed the burning engine. In under a minute, the Ansul Liquid Vehicle System (LVS) knocked down the flames, lowered

the temperature to 700°F and blan-keted the fuel to cut off oxygen and prevent reflash.

“In all of our testing over the years the magic number we have found is 850°F,” said Kevin Siler, business development manager, Tyco Fire Pro- tection Products, Marinette, Wis. “Temperatures 850°F and above will auto-ignite anything on the machine — diesel fuel, hydraulic oil and even antifreeze once the water is baked off.

“Our goal with the system was to get the temperature to at least 800° F for a safety factor that could prevent a reflash for a lengthy period of time. If the engine is still running after a fire, it needs to be cooled so the fuel supply can be safely turned off.”

While the diesel engine prop would catch fire only once that day, it wasn’t its first conflagration, nor would it be its

last. The company has used it as well as others at the Fire Technology Center in Marinette for thousands of classes and tests over the years. Nearby, an old Michigan 275A tractor shovel would catch fire at least a dozen times that day. Each time, the engine fire was extinguished by students wielding 30 lb. Ansul Red Line cartridge-operated portable fire extinguishers, learning the theories and techniques of fighting equipment fires in real-life situations.

By preheating the engine, the in -structors created a worst-case sce-nario that’s appropriate to most diesel-powered markets. And it was very real for that particular summer class: the students were primarily managers and operators of equipment that haul pots of molten slag, one of the most dangerous jobs at a steel plant.

“You dip your machines into a

An old wheel loader experienced dozens of engine fires during the Ansul Fire School over the summer. Using this machine, attendees learn to put out equipment fires using 30 lb. hand portable fire extinguishers and discover firsthand that the 5 lb. stored-pressure extinguishers that are common in cabs are not likely to have a great impact on a pressure fire. Used for testing and educating, the company’s fire props are constantly updated. It plans to have a mine haul truck and a simulated hydraulic mining shovel installed soon.

96 DIESEL PROGRESS NORTH AMERICAN EDITION September 2013

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bbenedetti

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Attachment No. A13

SAFETY TECHNOLOGY

superheating situation all the time, preheating the entire machine like in an oven,” Siler reminded the group. A number of the students were there to glean enough information to show their bosses that it was time to convert their slag haulers from a dry chemical fire suppression system to LVS.

Ansul first developed LVS for the

September 2013 DIESEL PROGRESS NORTH AMERICAN EDITION 97

mining industry, as well as restau-rants and other stationary applica-tions. It was originally used along with a dry chemical system, which is still an important product for the Tyco brand. In a twin agent application, the powder smothered the fire while the liquid cooled the area. Those systems are common in large equipment, such

as haul trucks and hydraulic mining shovels. As the liquid system’s com-ponents evolved, internal and third-party testing showed LVS would also be effective in a single agent system.

“Dry chemical is an extremely pow-erful knockdown for fires,” Siler said. “But you now get that quality with LVS, and you get cooling too. Plus, liquid flows everywhere and sticks to everything to smother fires. For some, switching to LVS will be a complete culture change, but it is done with much of the same hardware we’re used to. The tanks look the same. They just hold different fluid.”

Ansul’s engineers continued to develop LVS primarily to combat the heat and fires generated by turbocharg-ers. “Our objective is to protect the engine compartment and cool high heat sources in order to mitigate or totally eliminate the chance for a reflash,” said Bill Klingenmaier, manager, Technical Services, Tyco. “An excavator’s engine is completely enclosed, so when a fire occurs it’s typically a result of wear and tear that causes a high-pressure hydraulic oil or fuel leak.

“Once a rupture starts spraying, you’re not going to know where it’s coming from or where it’s going to land. When that oil hits the turbo-charger it’s going to ignite. Even

The Ansul LVS wet chemical agent fire suppression system is available in a variety of sizes for a wide range of on- and off-highway equipment.

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continued on page 98

DPNA594.indd 2 8/29/13 9:56 AM

SAFETY TECHNOLOGY


Klingenmaier said. “That property of a liquid system lends itself well to ag machinery and especially forestry.

“There are areas in the Northeast and West where a lot of forestry work occurs where insurance agencies require fire suppression systems, and they’re in favor of wet chemical solu-tions. Waste and recycling equipment are also perfect applications for wet chemical systems.”

Ansul’s fire suppression systems are common in underground and surface mining equipment, where in many cases they are required.

“LVS gives us a product for market verticals we may not have considered before,” Klingenmaier said. “A lot of on-highway equipment is not protect-ed. While some of that has to do more with the added expense, we know dry chemical systems have been a hard sell there. Having a bus discharge its system on an eight-lane expressway would envelope it and everything close by in a cloud of dust. A wet chemi-cal system is much different in that respect. Hot surfaces will create steam but there’s not a cloud of anything.”

Wet chemical fire suppression sys-tems are essentially a hydraulic sys-tem and can simplify the distribution

fire-resistant hydraulic oil will burn when it hits something very hot.”

The liquid system’s flexible design and installation requirements allow it to accommodate on- and off-road vehi-cles of nearly any size, the company said, starting with a four-nozzle, 5 gal. LVS wet chemical agent unit. A variety of hose network options are available.

The proprietary wet agent is a blend of organic and inorganic salts that can protect in extreme heat and cold, with an operating range of -40° to 140°F. It is effective in suppressing Class A (ordinary combustibles, such as wood chips) and B fire types, which involve flammable liquids and gases. The company’s Checkfire SC-N (or the mine permissible MP-N) electric detec-tion and actuation system sets the sys-tem off when it detects a fire. The mod-ules resist shock and vibration and can be powered by an internal lithium bat-tery for 24-hour vehicle protection, the company said. Most of the system’s components are manufacturerd by the company in Marinette, which has been its home for 100 years.

While dry chemicals will extinguish a Class A fire, it’s good to have the ability to soak material in order to reach the heat source of a deep-seated fire. “That’s what LVS does,”

With eight nozzles (four on top and four aimed at the belly pan) and 15 gal. of LVS wet chemical agent, a fire caused by a superheated turbocharger was extinguished in under a minute. The liquid agent also lowered the engine’s surface temperature to 700°F, helping to keep the fuel from reigniting.

continued on page 100

DPNA594.indd 3 8/29/13 9:56 AM


network when compared to a dry agent, said the company, which is a pneumatic system that uses nitrogen to push the powder through the lines and out of the nozzles. The LVS system is also user friendly and easier to install, Klingenmaier said.

“Beyond fire suppression and cooling, OEMs like the design capability that LVS offers,” said Mark Neumann, director of product management, Pre-engineered Systems, Tyco. “The installation blends in with the normal flow of the vehicle as opposed to disrupting the design of the hydraulic system and other components. General maintenance can easily be accomplished without disassembling the system.”

The liquid agent has a 25-year shelf life while it’s in a warehouse. “Once it’s on a vehicle we say it has a 12-year lifespan,” said Siler, “and the only reason is because the systems must be tested in 12-year intervals, which is a good time to replace hoses, as well. Inspections should be done regularly to see the tanks are not crushed and all of the hoses are still connected.”

Historically, fire suppression systems have been an aftermarket item, installed in the field to meet spe-cific application requirements. Neumann sees that trend starting to shift as global organizations look for unifor-mity when it comes to fire suppression system design and installation.

Manufacturers and fleet managers have several options for installing them on mobile equipment. “Some don’t want the liability that can be involved with fire systems, so they will outsource all of that work to a local distributor,” Klingenmaier said. “That is one avenue a lot of OEMs are very comfortable with. The distributor will design and install the system and the equipment will be shipped with it factory-installed. In order to do their own design and installation, manufacturers must be trained by us or field technicians. Others will use our designs and will have an authorized distributor come to their facility to do the install. Still others do it all but will have a distributor verify the design and installation.”

Ansul products are distributed worldwide by hundreds of vehicle system distributors that have been factory trained to install and service fire suppression equipment.

How fire suppression systems in general will handle the new components and the increased heat of Tier 4 emissions systems is also going to drive a change in how they are designed. “Tier 4 engines involve a whole new thought process,” Klingenmaier said. “The better we are dialed in with where equipment manufacturers are going the better we can make sure our suppression systems are up for the challenge.

“That is key, and it’s a big task in some of the verticals we work in. There are a lot of pieces of equipment to stay in tune with as we transition to the new technology.” dp

www.ansul.com

SAFETY TECHNOLOGY

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DPNA594.indd 4 8/29/13 9:57 AM

1

Benedetti, Bob

From: Danner, Larry (GE Power & Water) <[email protected]>Sent: Wednesday, October 07, 2015 10:30 AMTo: Benedetti, BobSubject: Annex section A.11.3.1

Hi Bob, Some of the team members are under the impression that the suggested 38C (55F) fire detector set point above max operating temperature (at the end of the first paragraph of the section) is a “REQUIREMENT”. I am going to correct their thinking … As a general question to you, would you consider this SUGGESTION to be a consideration for an engine enclosure / room fire detector setting based on the space being “naturally ventilated” rather than “mechanically ventilated”? I would just like to at least unofficially confirm my suspicion … I know that the temperature in our turbine enclosures spikes a LOT higher than operating (200+F) if the ventilation is lost; even with an immediate engine shutdown so the setting suggested in 37 is essentially guaranteed to result in a fire system discharge if ventilation is lost regardless of an actual fire condition … that is a matter for the internal discussion. I also have concern for radiation as the detectors in the GT enclosure are often placed fairly close to the turbine combustion hardware that can reach surface temperatures in excess of 900F (with a bulk enclosure air temperature of 300 – 350F) so as to “quickly” detect a fire from a gas or liquid fuel leak at the combustion connections. We, as a committee, may want to expand the annex discussion to clarify where the suggested temperature margin is applicable and point out other considerations for defining the temperature setting. Thanks and regards,


GE Power & Water Power Generation Products T: (864) 254-4185 F: (864) 254-4228 D: 8*288-4185 E: [email protected] W: www.gepower.com 300 Garlington Rd. GTTC 200D GREENVILLE, SC 29615 GE GAS TURBINES, LLC GE imagination at work

bbenedetti

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Attachment No. A14

NFPA30A Committee

John Gray – OPW Retail Fueling

Subject: Differences between NFPA30A and NFPA30 with regard to hazardous locations of “Vent” and “Vent –

upward discharging”

Also submitted as online question 00033083 (6/11/2014)

Summary:

In about 2003 both NFPA30 and NFPA30A referred to two different types of tank vents: “Vents” and “Vents –

upward discharging” each with its own hazardous location created. In the 2008 or 2012 edition of NFPA30A, the

category of “Vents – upward discharging” was removed from the associated table while NFPA30 continued to

define this as a separate category.

I believe that the two types of ‘vents’ are an attempt to differentiate what UL2583 now calls “E-Vents” (emergency

vents) and “N-Vents” (normal vents). E-Vents are designed to automatically relieve excessive internal tank

pressures during fire exposure (used on AST). Generally N-Vents (also known as P/V vents or pressure/vacuum

vents)(used on both AST and UST) are upward discharging and are used to normalize a tanks pressure to

approximately atmospheric while controlling vapor emissions in everyday use.

With “Vent – Discharging Upward” removed from NFPA30A, all vents have the larger hazardous area. But since

NFPA30 continues to define “Vent – Discharging Upward” with a reduced hazardous area, there appears to be a

potential conflict regarding which hazardous area is allowed.

Recommendation:

Reinsert “Vent – Discharging Upward” back into NFPA30A Table 8.3.2 to match NFPA30 Table 7.3.3.

bbenedetti

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Attachment No. A15

NFPA30A 2015

Table 8.3.2

Tank, aboveground

Vent

Div/Zone 1: within 1.5m (5 ft)

Div/Zone 2: Between 1.5m and 3m (5 ft and 10 ft)

Tank, underground

Vent



No mention of “Vent – Discharging Upward”

NFPA30A 2012

Table 8.3.2

Tank, aboveground

Vent



Tank, underground

Vent



No mention of “Vent – Discharging Upward”

NFPA30A 2008

Table in Chapter 8

? I cannot find or access a copy of this revision

NFPA30A 2003

Table 8.3.1

Vent (with no distinction between aboveground and belowground)

Div 1: within 1.5m (5 ft)

Div 2: Between 1.5m and 3m (5 ft and 10 ft)

Vent discharging upward

Div 1: within 3 ft

Div 2: Between 3 ft and 5 ft

NFPA30A 2000

Table 8.3.1

Vent (with no distinction between aboveground and belowground)

Div 1: within 5 ft



Div 1: within 3 ft


NFPA30A 1993

Table 7


Div 1: within 3 ft


NFPA30 2015; 2012; 2008

Table 7.3.3

Tank – aboveground, fixed roof

Div 1/Zone 0: Are inside vent pipe or opening

Div 1/Zone 1: within 5 ft of open end of vent

Div 2/Zone 2: Between 5 ft and 10 ft of open end of vent


Div 1/ Zone 0: Are inside vent pipe or opening

Div 1/Zone 1: within 3 ft

Div 2/Zone 2: Between 3 ft and 5 ft

NFPA30 2003

Table 8.2.2

Tank – aboveground, fixed roof

Vent

Div 1/Zone 0: Are inside vent pipe or opening

Div 1/Zone 1: within 5 ft of open end of vent

Div 2/Zone 2: Between 5 ft and 10 ft of open end of vent


Div 1/ Zone 0: Are inside vent pipe or opening

Div 1/Zone 1: within 3 ft

Div 2/Zone 2: Between 3 ft and 5 ft

bbenedetti

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Attachment No. A16

1

Benedetti, Bob

From: Biggins, James <[email protected]>Sent: Thursday, July 09, 2015 9:17 AMTo: Benedetti, BobSubject: RE: NFPA 37/NFPA 85 Conflict?

Bob, Hoped to see you at the C&E to discuss 37. What is the status of selecting a new Chair? Jim James Biggins, PE CSP Managing Consultant – Chicago District Power Generation Practice Leader

Global Risk Consultants Corp. 111 West Washington Street, Suite 1815 Chicago, IL 60602 Direct: +1 (815) 478-0423 | Cell: +1 (312) 952-9417 | Office: +1 (312) 223-1523

From: Benedetti, Bob [mailto:[email protected]] Sent: Tuesday, May 19, 2015 10:05 AM To: Biggins, James Subject: RE: NFPA 37/NFPA 85 Conflict?

Hi, Jim: This slipped by me; my apologies. Can we set up a time to discuss. Another problem: We appointed Steve Wetter to the T/C last month. I sent him a welcome letter. Last week, his wife called to inform me that Steve had lost a battle with cancer and passed away in March. I will notify the Technical Committee. So, we need to return to our discussion about a chair. Bob Benedetti From: Biggins, James [mailto:[email protected]] Sent: Tuesday, March 31, 2015 3:26 PM To: Benedetti, Bob Subject: NFPA 37/NFPA 85 Conflict? Bob, Just wanted to point this out. Looking at the wording from Chapter 8 of NFPA 85, it looks like the standard scope has expanded with the statement “or other combustion turbine exhaust systems and their associated combustion turbines”.

bbenedetti

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Attachment No. A17

2

It looks like this was done in 2007, so as I was not Chair of 37, it got past me; but it seems to me there needs to be some definite interaction/coordination between the 2 committees as the NFPA 85 document is now taking responsibility for all exhaust system components, whether or not there is any fired component within the exhaust system. Also, as a minimum the 37 TC should at least point to NFPA 85 for the requirements for the exhaust systems. Regards, Jim James Biggins, PE CSP Managing Consultant – Chicago District Power Generation Practice Leader

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