report of the committee gerry e. misel, jr., georgia gas ... · allows enclosure by parapets, which...

Report of the Committee on

IAquef'md Petroleum Gases

E. E. Under, Chair Watsonville, CA IS E]

Theodore C. Lemoff, Secretar~ Nat'l Fire Protection Assn., MA

(Nonvoting)

Connor L. Adams, Gonnor Adams, Inc., FL [SE] Paul N. Bogan, Sea-3, Inc., NH [U] Ronald G. Brunner, Gas Processors Assn., OK [M]

Rep. (;as Processors Assn. John A. Cedervall, Deerfield, IL [SE] Carlos de Le6n, Flama Gas, S.A. de C.V., D.F., Mexico [1M]

Rep. Asociaci6n Mexicana de Distribuidores de Gas Luis Angel Gadea, YPF Gas S.A., Argentina [IM] William G. Haesloop, Ebara Int'l Corp., NV [M] Richard A. Hoffmann, Hoffmann & Feige Inc., NY [SE] Mike M. Israni, U.S. Dept. of Transportation, DC [E] Marshall Issen, Underwriters Laboratories Inc., IL [RT] Hugh F. Keepers, Texas A&M University, TX [SE] Charles C. Lamar, Lamar Consultants Inc., IL [SE] Jane I. Lataille, Industrial Risk Insurers, CT [I] Roger L. Maxon, BernzOmatic Division of Newell, NY [M]

Rep. Compressed Gas Assn. William B. McHeury, Pro-Gas Sales & Service Co., MI [IM]

Rep. Nat'l Propane Gas Assn. Samuel E. MeTier, MeTier Supply Co., IL [M]

Rep. Nat'l Propane Gas Assn. Frank J. Mortimer, Federal Mutual Insurance Co., MN [I]

Rep. The Alliance of 3unerican Insurers Leonard Pakruda, Alabama Liquefied Petroleum Gas Board, AL [E] Thomas D. Petru, LP-Gas Section, Gas Services Division, TX [El Henry W. Renfrew, Compliance and Response Mgmt., CT [E]

Rep. Fire Marshals Assn. of North America John L. Ritzmann, Washington Gas, VA [IM]

Rep. American Gas Assn. James H. Stannard, Jr., Stannard & Co., GA [SE] H. Emerson Thomas, Continental Tank Car Corp., NJ [IM]

Rep. Nat'l Propane Gas Assn. Kenneth 17,. Van Hook, Mitsubishi Caterpillar Forklift America Inc.,

TX [M] Rep. Industrial Truck Assn.

Frank R. Volgstadt, Perfection Corp., OH [M] Rep. Plastics Pipe Inst.

William J. Young, Plant systems Inc~, OH [M] HerbertF. Zepp, Smith & Norrington Engr Corp., NH [SE]

Alternates

John O. Bigelow, III, Bigelow Assoc., NJ [SE] (Alt. to J. H. Stannard)

Alessandro Calrnli, Agipliquigas S.A., Brazil [IM] (Alt. to L. A. Gadea)

John A. Davenport, Industrial Risk Insurers, CT [I] (Ah. to J. I. Lataille)

James p. Lewis, Project Technical Liaison Assoc., Inc., TX [SE] (Alt. tO C. L Adams)

Gerry E. Misel, Jr., Georgia Gas Distributors Inc., GA [M] (Alt. to S. E. MeTier)

Phani K. Raj, Technology & Mgmt. Systems Inc_, MA [SE] (Alt. to C. G. Lamar)

Mark F. Sutton, Gas Processors Assn., OK [M] (Alt. to R. G. Brunner)

Bruce J. Swiecicki, Nat'l Propane Gas Assn., IL JIM] (Air. to H. E. Thomas)

Ramon S. Miguel Villarreal Reza, Equipos Para Gas S.A. de C. V,- Mexico [IM] (Alt. to C. de Le6n)

Robert A. Zeman, Underwriters Laboratories Inc., IL [RT] (Alt. to M. Issen)

Nonvoting

Lucian (Lu) Lyall, R W Lyall & Co, Inc., CA Chappell D. Pierce, U.S. Occupational Safety & Health Admin, DC Donald W. Switzer, U.S. Consumer Product Safety Commission, DC

Staff Liaison: Theodore C. Lemoff

This list represents the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A key to classifications is found at the front of the book.

Committee Scope: This Committee shall have primary responsibility for documents on the design, construction, installation and operation of fixed and portable liquefied petroleum gas systems in bulk plants, commercial, industrial (with specified exceptions), institutional, and similar properties, truck transportation of liquefied petroleum gas; engine fuel systems on motor vehicles and other mobile equipment; storage of containers awaiting use or resale; installation on commercial vehicles; and liquefied petroleum gas service stations.

This portion of the Technical Committee Report of the Committee on Lquefied Petroleum Gases is presented for adoption.

This Report on Comments was prepared by the Technical Committee on Liquefied Petroleum Gases and documents its action on the comments received on its Report on Proposals on NFPA 58-1995, Standard for the Storage and Handling of Liquefied Petroleum Gases, as published in the Report on Proposals for the 1997 Fall Meeting.

The document when adopted will be redesignated as NFPA 58, Liquefied Petroleum Gas Code.

This Report on Comments has been submitted to letter ballot of the Technical Committee on Liquefied Petroleum Gases, which consists of 28 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report.

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(Log #CC14) 58- 1 - (Entire Documen t ) : Accept SUBMITTER: Technica l Commi t t ee on Liquefied Pe t ro l eum Gases COMMENT ON PROPOSAL NO: N / A RECOMMENDATION: Revise the Title of NFPA 58 to read:

Liquefied Pe t ro leum Gas Code SUBSTANTIATION: T h e Commi t t ee has reviewed the r equ i r emen t s of the d o c u m e n t a n d believes that it would be more appropr ia te to call it a Code as it conta ins Code requi rements . COMMITTEE ACTION: Accept . NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 27 N O T RETURNED: 1 Van Hook

(Log #CC7) 58- 2 - (1-4.1): Accept SUBMITTER: Technica l Commi t t ee on Liquefied Pe t ro leum Gases COMMENT ON PROPOSAL NO: 58-61 RECOMMENDATION: Revise 1-4.1 to read:

1-4.1 Stationary Installations. Plans for stat ionary installations utilizing s torage conta iners of

over 2,000 gal (7.6 m s) individual water cat~acity , or with aggregate water capacity exceeding 4,000 gal (15.1 m° ) , and all roof top installatioIl of/kSME tanks, shall be submi t ted to the author i ty having jur isdic t ion before the installat ion is started. [See also 3- 4.9.1 (e).] SUBSTANTIATION: The commi t tee believes that with the addi t ion of roof top installations in Section 3-2.5, addi t ional notif ication r equ i r e men t s are needed . COMMITTEE ACTION: Accept . NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 19 NEGATIVE: 6 ABSTENTION: 2 N O T RETURNED: 1 Van Hook

EXPLANATION OF NEGATIVE: LAMAR: I object mos t s t rongly to the following: I. Separat ion of my c o m m e n t s on 58-61 in R OC 5 / 1 5 / 9 7 by 46

pages f rom the 16 c o m m e n t s of o thers (pages 64-81) on this subject. My c o m m e n t s h a d Log Nos. 23 a n d 29 and thus shou ld have been with all of the related comments . Ins tead they were separa ted on pages 127-128 and 131-132. (Ted L emof f expla ined to me today tha t a typo on my entry for Sec t ion /Pa rag raph showed "A-2-2.6.4" thus for an append i x i tem, so it was p laced in tha t s equence even t h o u g h the COMMENT ON PROPOSAL showed 58-61 a n d all of the text was about new Section 3.2.5 - "lnstallafion of Conta iners on Roofs...")

2. In ROC 7 / 1 4 / 9 7 , all o ther related c o m m e n t s on 58-61 are g rouped in pages 33 t h rough 42 (Logs 2 t h rough 127) with act ions Of the Commi t t ee stated for each.

My Logs 23 and 29 on the o ther h a n d were no t inc luded in ROC 7 / 1 4 / 9 7 . and thus no action is stated abou t the m a n y hazardous condi t ions cited in my c o m m e n t s on 58-61.

Note tha t 3-2.5.6 in Log CC 6 states tha t "Conta iners shall be located in areas where the re is free air circulation, at least 10 ft (3.0) f rom bui ld ing open ings (such as windows and doors) , and at least 20 ft (6.1 m) f rom air intakes o f air condi t ion ing and venti lat ing systems". This word ing is identical with the wording in Section 3-4.9.1 (b) where LP-gas on a roof is l imited to 400 lbs. in one manifold, a n d no t h i ng is said abou t chang ing this limit.

N O T H I N G is said abou t locat ion o f overpressure relief devices in valves or in pressure regulators. T hus these relief devices can be as close as $ ft to a bui ld ing open ing or 5 ft to a source of ignitionl

No a t tent ion is paid to the f r equen t discharge f rom overpressure reliefs in pressure regulators which are now requi red in bo th first and second stage regulators with very h igh relieving capacity in the final stage regulator relief.

The overpressure reliefs in final s tage regulators may start to relieve at 18.7 in. water column, with a very l ight valve seating force of only 0.075 lbs. (seventy-five t housand t h s of a pound l )

The history of leakage f rom such relief valves is d o c u m e n t e d with m a n y cases of fires and explosions in this country w h e n ice seals the vents and gas flow into the b o n n e t caus ing grossly excessive pressure downst reaml

Debris in p ip ing can block regula tor valves open a n d cause serious con t inuous leakage. This has rarely been a serious hazard with conta iners and regulators at g r o u n d level and spaced away f rom buildings, bu t Section 3-4.9.1 (c) ( incorpora ted in Log 38) allows enclosure by parapets , which can help to funne l the high- densi ty gas of h igh Btu value into buildings. (Screening provisions of m a n y bui ld ing codes in this count ry will lead to pocket ing of escaping gas as stated in Logs 8, 31 and 115.

No at tent ion is paid to providing sprinklers for fire suppress ion in s t ructures below conta iners on roofs or cooling sprays for conta iners in case of a firel

The wording of 3-2.5.1 in Log 38 reads "With the prior approval of the author i ty having jur isdict ion, bui ldings complying with Type I 443 or 332 or Type. II., 222 construct ion shall be permitted, to have ASME con tamers installed, filled a n d used on roofs in accordance with the following...." This may have no value at all in many areas..." author i t ies having jur isdic t ion" may be completely unqual i f ied to make such a decision. Often they have no knowledge abou t proper t ies and hazards of LP-gas, or what is m e a n t by the bui ld ing types cited. Also, they may be subject to all sorts of persuas ion by persons seeking commerc ia l advantage, so this may be a farcel

El iminat ion o f the provision to prohib i t such installation wi~ere natural gas is available would potentially allow thousands of gallons of p ropane to be s tored on the roofs of downtown buildings in this countryl

The c o m m e n t s a n d warnings in the Logs listed above f rom many fire depar tments , f rom regional fire code authorit ies, f r o m U.So C o n s u m e r Produc t Safety Commiss ion, a n d f rom o ther knowledgeable persons dedica ted to safety have been ignored in order to weaken NFPA 58 to a c c o m m o d a t e practices in Mexico and Latin America and to have NFPA 58 adoo ted t h r o u a h o u t the hemisohe re l This is W R O N G - o t h e r countr ies shou ld state their own code except ions while adop t ed a ~ code which has prevented this sort of th ing for decadesl

The first s en tence in "SUBSTANTIATION" in m y Log 23 on Proposal 58-61 points out the prohibi t ion against p u m p i n g liquid LP-gas into conta iners on roofs:

Section 3-2.3.1 (c) states "THE TRANSFER OF LIQUID INTO CONTAINERS ON T H E ROOFS OF STRUCTURES SHALL BE

Section 3-4.2.6 (a) states "FILLING CONTAINERS ON ROOFS OR BALCONIES SHALL BE PROHIBITED. See 3-2.3.1 (c)."

These provisions show that for decades we have known that p u m p i n g liquid p ropane into conta iners on roofs o f buildings is inheren t ly too dange rous to be consideredl

The fact that no act ion was taken at the J u n e mee t i n g to change or delete these two sections (while developing new Section 3-2.5 to provide coverage for the Mexican practice of p u m p i n g an d storing on roofs) shows tha t no significant a t tent ion was pa id to the d o c u m e n t e d in Lol~ 23.

THERE IS NO REASON FOR US T O CURRY FAVOR WITH MEXICO BY DEGRADING O U R SAFETY STANDARD FOR LP- GAS STORAGE AND HANDLING. THE OBVIOUS DESIRE OF NFPA T O HAVE STANDARD 58 ADOPTED FOR THIS ENTIRE HEMISPHERE IS A BAD REASON FOR DEGRADING SAFETY PROVISIONS OF THIS STANDARDI

LET'S JUST SAY NO1 LATAILLE: In line with my posit ion on C o m m e n t s 58-48

t h r o u g h 58-61, the phrase conce rn ing rooftop installations shou ld be removed.

MORTIMER: Word ing shou ld r ema in the same as adding roof top installation o f ASME tanks does n o t h i n g to "improve or advance safety." RENFREW: I do no t suppor t add ing roof top installations to this code at this t ime. See o ther proposals on roof installations,

STANNARD: The revised wording of 3-2.5.1 of Proposal 58-49 shou ld be suff icient for tanks on roofs a n d the added language of C o m m e n t 58-2 is r e d u n d a n t and no t required.

ZEPP: Reject commit tee act ion a n d vote to leave 1-4.1 "as-is". EXPLANATION OF ABSTENTION:

PAKRUDA: See my Explanat ion o f Abstent ion on C o m m e n t 58- 48 (Log #18).

VOLGSTADT: I d idn ' t feel that I had the n e e d e d informat ion to vote otherwise on this i tem.

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N F P A 58 - - F 9 7 R O C

(Log #CC8) 58- 3 - (1-5): Accept SUBMITTER: Technical Committee on Liquefied Petroleum Gases COMMENT ON PROPOSAL NO: 58-1 RECOMMENDATION: Revise 1-5 to read:

Persons who transfer liquid LP-Gas, persons who are employed to transport LP-Gas, or whose primary duties fall within the scope of this standard, shall be trained in proper handling procedures-.

I The training shall be documented. SUBSTANTIATION: Revised to cover all persons, not just employees. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 27 NOT RETURNED: 1 Van Hook

58- 4 - (1-6): Reject (Log #5) SUBMITTER: Northeast Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: 58-3 RECOMMENDATION: Reconsider the committee action and accept theproposed wording. SUBSTANTIATION: The definition is commonly used by the industry and consumers and will assist the user of the code. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The committee does not believe that is appropriate to define a term not used in the standard. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 26 NEGATIVE: 1 NOT RETURNED: 1 Van Hook

EXPLANATION OF NEGATIVE: RENFREW: The Committee should include a definition of

cylinder exchange points and have more information in the standard covering these type locations.

58- 5 - (1-6): Reject (Log #9) SUBMITrER: Southeast Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: 58-2 RECOMMENDATION: Reconsider the committee action and reject the proposal. Keep the reference to ASME, US DOT and Transportation Canada specifications. SUBSTANTIATION: We support the negative comments of I.amar. Allowing the ahj to approve other cylinder construction specifications could provide an enforcement nightmare. Section 1- 1.4 of NFPA 58 already gives the ahj the authority to approve alternate materials, equipment and procedures, this section is redundant. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Committee Action on Comment 58-13 (Log #128). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #21) 58- 6 - (1-6): Reject SUBMITTER: Charles C. Lamar, I.amar Consultants, Inc COMMENT ON PROPOSAL NO: 58-2 RECOMMENDATION: Reject Proposal Log #CP5, "Cylinder. A portable container constructed to: U.S. Department of Transportation; Transport Canada; Other cylinder construction specifications acceptable to the authority having jurisdiction." Instead, RETAIN the present wording defining "Cylinder --" on

~ age 7 (mid-column 2) of 1995 edition. UBSTANTIATION: The Proposal misquotes the present text.

It conflicts with Sections 2-2.1.3 and 2-2.1.4. The Proposal to accept "other cylinder construction specifications acceptable to the Authority Having Jurisdiction" would be dangerous, subjecting public safety to the judgment or whim of unknown, unqualified persons subject to various persuasions with a highly flammable

fluid under high pressure. Also, such a cylinder could not be refilled under Section 2-2.1.4. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Committee Action on Comment 58-13 (Log #128). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: VOTE ON COMMITTEE ACTION:


28

(Log #26) 58- 7- (1-6): Reject SUBMITTER: John Cedervall, Deerfield, IL COMMENT ON PROPOSAL NO: 58-2 RECOMMENDATION: Revise as follows:

A portable container constructed to DOT or Transport Canada cylinder specifications." SUBSTANTIATION: Revision does not clarify the present definition, and is in conflict with requirements of 2-2.1.3 and 2- 2.1.4. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Committee Action on Comment 58-13 (Log #128). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITrEE ACTION:


(Log #61) 58- 8 - (1-6): Reject SUBMITTER: Bruce Swiecicki, Nat'l Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-7 RECOMMENDATION: Add new definition to Section 1-6

Cylinder Size. The desima criteria for DOT cylinders that addresses the head ratio.~cvlinder inside diameter and total water ~za~am SUBSTANTIATION: This definition is needed in order to establish the parameters for determining the dip tube lengths on cylinder valves fitted with an overfilling prevention device. Safety considerations warrant the use of uniform dip tube lengths for each size cylinder to avoid the possibility of cylinders becoming overfiUed. COMMITTEE ACTION: Reject. COMMrrTEE STATEMENT: The committee does not believe that the definition is needed. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #62) 58- 9 - (1-6): Accept in Principle in Part SUBMITTER: Bruce Swiecicki, Nat'l Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-7 RECOMMENDATION: Amend the NFPA Technical Committee's action as follows:

(new) Overfilling Prevention Device. A ~ device that is designed to provide an automatic means to prevent the filling of a container in excess of the maximum permitted filling limit comouted on the basis that the liauid temoerature will be at 40°F for above.round containers,

v

Volumetric Filling. Filling a container by determination of the volume of LP-Gas in the container. Unless a container is filled by fixed maximum liquid level gauge, or v;'c:.:!!~g . . . . . . . . :^- n-..~^ correction of the volume for liquid temperature is necessary. SUBSTANTIATION: (1) The maximum permitted filling point at which the device is designed to provide an automatic means of dclreventing overfilling of containers must be included in the OPD

efinition. (2) The current volumetric filling definition language should be

retained and not be amended to define the OPD as a primary filling device. COMMITrEE ACTION: Accept in Principle in Part.

Add a new definition of Overfilling Prevention Device to read: Overfilling Prevention Device. A safety device that is designed to

provide an automatic means to prevent the filling of a container in excess of the maximum permitted filling limit.

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N F P A 58 - - F 9 7 R O C

Accept the p roposed revisions to the definit ion of Volumetric Filling. COMMITTEE STATEMENT: The definit ion of Overfilling Prevention Device is revised by delet ing the proposed new text at the end because it is inappropriate text for a definition as it conta ined a design restrictive requirement . NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: PAKRUDA: I vote "NO" on the Committee Action for the the

overf i l lprotect ion device (OPD) Comments . The reasons I voted no for the overfill protect ion device comments are as follows:

Mandating the retrofit t ing of the OPD in DOT cylinders by the year 2002 is unenforceable. There are between 50 and 70 million LP-gas cylinders in use and the time frame proposed in retrofitt ing these cylinders is unrealistic. I submit that the OPD is cons idered to be a secondary shut-off device; a more reasonable time frame and enforceable approach would be to retrofit the existing cylinders either on the next recertification date of the cylinder or by the year 2010 whichever would occur first. The submitters of the OPD Proposal have clearly stated that the OPD is a secondary shut-off device and primary filling shall remain volumetric or by weight. Another concern I have is purging cylinders with the OPD, our office has received reports from the field and the committee has heard testimony f rom an LP-gas marketer that it takes about 25 minutes to complete a purge on each cylinder. The proposal exempts the OPD's f rom DOT cylinders used in welding gas service, it is my belief that consumers will exchange LP-gas cylinders at weld inggas company. . locations rather than pay the cost of making the retrofit to thetr cyhnder. I have a very deep concern that we are trying to mandate these types of requirements where there has been no public review of the retrofit provision. The retrofit provision of the OPD was added to the proposal as a public comment by the original submitter of the proposal. Apparendy the OPD when installed in cylinders may no t provide a 100 percen t shut off in all cases. I have been advised that a cylinder can be rota ted on its side to a specific position that could cause a 100 percen t liquid fill of the cylinder. The LP-GAS administrators group who are state regulatory LP-Gas enforcement officials have stated in writing to the committee that they are against the retrofit provision of the OPD due to the amoun t of cylinders involved and the lack of support ing documentat ion. In other words, ( the retrofi t is unenforceable; see Proposal 58-21). While the administrators are no t against the OPD, the group feels to make the retrofit provision of the OPD enforceable, the retrofi t needs to be accomplished in a longer, more reasonable time frame. COMMENT ON AFFIRMATIVE:

PETRU: Refer to L. Pakruda's Comments.

(Log #47) 58- 10- (1-6): Reject SUBMITTER: Wayne Wagner , Tennessee Fire Code Development Commit tee COMMENT ON PROPOSAL NO: 58-2 RECOMMENDATION: Reconsider the commit tee action and reject the proposal. Keep the reference to ASME, US DOT and Transporta t ion Canada Specifications. SUBSTANTIATION: The Tn Fire Code Development Commit tee support the negative of Lamar and the Southeastern Regional Fire Code Development Committee: Please replace the wording for Proposal 58-2 (1-6 Cylinder) with the following:

"The p roposed added wording, to allow "other cylinder constructions acceptable to the authority having jurisdiction" is dangerousl It would allow an unknown, unqua l i f i edpe r son to decide - even on a whim or persuasion - to legally authorize dangerous containers to be loaded with powerful fuel under high Pcressurel"

OMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Commit tee Action on Comment 58-13 (Log #128). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 27 NOT RETURNED: I Van Hook

(Log #120) 58- 11 - (1-6): Reject SUBMITTER: Vicki O'Neil, Florida Bureau of Liquefied Petroleum Gas Inspections COMMENT ON PROPOSAL NO: 58-2 RECOMMENDATION: Suggest adding58-11 (2-2.1.4) to this text to allow for t ransportat ion o fcy l inde r sback to the plant or other facility for the purpose of requalification. SUBSTANTIATION: The language is very broad and non-specific and, given the fact that LP gas authorities in many states are ~olitically appoin ted positions, would, as Mr. Lamar pointed out,

ave the potential o f allowing unqualified persons to make decisions no t based in s o u n d e n g i n e e r i n g practice°

Present language does no t allow cylinders to be transported, therefore a cylinder found at a consumer site may not legally be t ransported to a safe location for requalification if it is found to be out of requalification date. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The current text does no t prohibit t ransportat ion of empty cylinders back for requalification. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #CC9) 58- 12 - (1-6): Accept SUBMITTER: Technical Commit tee on Liquefied Petroleum Gases COMMENT ON PROPOSAL NO: 58-8 RECOMMENDATION: Delete the proposed definit ion of Redundan t Fail-Safe Product Control Measures (RFCPM). SUBSTANTIATION: The definition is no t needed as the term is de le ted from NFPA 58 in comments 58-37 (Log #CCI0), 58-41 (Log #C C l l ) , and 58-79 (Log #12). COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #128) 58- 13 - (1-6 Cylinder): Accept in Principle SUBMITI'ER: Steven T Gentry, Worthington Cylinder Corp COMMENT ON PROPOSAL NO: 58-2 RECOMMENDATION: Revise text to read as follows:

Cylinder. A portable container constructed in accordance to U.S. Depar tment of Transportat ion Transpor t Canada. Other cylinder construction specifications acceptable to the authority having jurisdict ion specifications (49 CFR). SUBSTANTIATION: 1. Cylinders identified by Transpor t Canada only cannot be filled or refilled and commercially t ranspor ted in the Uni ted States. This is in direct conflict with the requirements of the U.S. Depar tment of Transportat ion (49 CFR).

2. Expertise in cylinder design is at the cylinder manufacturer. I believe that the local authority having jurisdiction may no t be educated in cylinder design to the degree necessary to make the decision if "other cylinder construction" is safe and permit ted. I believe that the r ecommended change f rom the Technical Commit tee is unsafe and is in conflict with State and Federal law. COMMITTEE ACTION: Accept in Principle.

Revise the definition of cylinder to read: Cylinder. A container constructed in accordance with to U.S.

Depar tment of Transportat ion specifications (Tide 49, Code of Federal Regulations). COMMITTEE STATEMENT: Accepted with an editorial revision. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


COMMENT ON AFFIRMATIVE: LAMAR: This should read: "Cylinder: A container constructed in accordance w i ~ U.S.

Depar tment of Trans~3ortation specifications (Tide 49, Code of Federal Regulations) .

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N F P A 5 8 - - F 9 7 R O C

(Log #104) 58- 14 - (2-2.1.4(b)): Accept in Principle SUBMITTER= Gerry Misel, Georgia Gas Distributors, Inc. COMMENT ON PROPOSAL NO: 8-11 RECOMMENDATION: Revise text as follows:

xcb-)-2-2.1.5 ~ Cylinders shall ~ be refilled, continued in service,, o , and transported u~lczz ~,c 7 . . . . . . . . . ~ ~ r " v w " 1 ~ . . . . . . " * ~ " ~ 1 : ' : ^ ~ or . . . . . . l:~.^a c^. LP Ca: zcr'.'ce in accordance with ~ regulations under which *~he 7 were con~*.ructcd "~nd zccep~d Jurisdiction over the cvlinders. -SUBSTANTIATION: 1. The proposed 2-2.1.5 does not allow for a cylinder outside its qualification test date to be transported back to the plant for requalification, a practice which is authorized under DOT regulations. The proposal recommended above does not preclude such activity while still requiring containers under the jurisdiction of DOT regulations to be handled in accordance with those regulations.

2. The phrase "under which they were constructed and accepted" was not referenced in the ROP as new text. It does not appear in paragraph 2-2.1.4(b) in the 1995 edition of the standard. The proposal above replaces the phrase with one which more accurately describes the intent of the paragraph.

3. The above proposal states the requirements in the affirmative instead of in the negative. COMMITTEE ACTION: Accept in Principle.

I evise 2-2.1.5 to read: 2-2.1.5 Cylinders subject to the jurisdiction of Department of

Transportation regulations shall be filled, continued in service and transported in accordance with those regulations. COMMITTEE STATEMENT: The comment is accepted with editorial clarification. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: LAMAR: Comment 58-14, Log 104, objection the change

"Accepted in Principle". This change in Section 2-2.1.5 weakens NFPA 58 where it needs to be strong. It eliminates the strong prohibition "DOT cylinders shall not be refilled-- unless they are properly qualified or r e ~ for LP-gas service,". In spite of the present provision we still see many old cylinders being refilled with no attention being paid to the requirement for requalification.* This requirement needs to be emphasized, rather than deleted. Replacing the present prohibition onrefilling without requalification with the affirmative statement "Cylinders subject to the jurisdiction of DOT regulations shall be filled, continued in service anti transported in accordance with those regulations" is like replacing "Thou shall not KillI" with "keep on iivingl"

To meet the objections in Mr. Misel's "Substantiation", I suggest the following wording:

"Cylinders subject to the jurisdiction of Department of Transportation shall not be refilled unless they have been qualified or requalified for LP-gas service and other wise shall not be used or transported in violation of DOT regulations.

Note: Supporting material is available for review at NFPA headquarters.

(Log #129) 58- 15 - (2-2.1.5): Accept in Principle SUBMITTER: Steven T Gentry, Worthington Cylinder Corp COMMENT ON PROPOSAL NO: 58-11 RECOMMENDATION: Revise text to read as follows:

"DOT Cylinders shall not be refilled, continued in service, or transported unless they are properly qualified or requalified for LP-Gas service in accordance with DOT regulations under which they were constructed and accepted 49 CFR 173.34. SUBSTANTIATION: I. Cylinders are not requalified under the construction requirements of 49 CFIL

2. Cylinder construction and requirements are covered elsewhere in NFPA 58.

3. This subparagraph is discussing when to remove cylinders from service. Stating that cylinders in transport or use that are out of retest date must be removed from service is not consistent with DOT. Cylinders that were filled previous to the retest date can be transported and continued in service. Once empty, the cylinder must then be requafified. COMMITTEE ACTION: Accept in Principle.

COMMITTEE STATEMENT: Refer to Committee Statement on Comment 58-14 (Log #104). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: LAMAR: See my Explanation of Negative on Comment 58-14

(Log #104).

(Log #60) 58- 16- (2-2.6.4): Reject SUBMITTER: Ronald Jordan, U.S. Consumer Product Safety Commission COMMENT ON PROPOSAL NO: 58-131 RECOMMENDATION: Add the following statement to paragraph 2-2.6.4 of NFPA 58:

"The sample label located at Figure A-2-2.6.4 on page 58-73 of Appendix A will satisfy the requirements of the Federal Hazardous Substances AcL This warning labeling must comply with the type size, placement and conspicuousness requirements of 16 Code of Federal Regulations, Part 1500.121." SUBSTANTIATION: This refers the reader to Figure A-2.2.6.4 of the standard for guidance on warning label content that satisfies the Federal Hazardous Substances Act. The position stated herein is that of the Commission staff. It has not been reviewed or

O(~MMroved by the Commissioners. ITTEE ACTION: Reject.

COMMITTEE STATEMENT: The comment is rejected because the deletion of the label has been upheld. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


COMMENT ON AFFIRMATIVE: RENFREW: Sample Label. The issue of a proper warning label

is between CPSC and the LP-Gas Industry. They have been working closely together for years to ensure adequate safety labels for employees and the general public. The problem with adding the sample into the standard is that the standard allows for various different types of uses, indoor and out, and a sample label cannot account for all of these uses.

(Log #CC2) 58- 17- (2-2.6.4): Accept SUBMITTER: Technical Committee on Liquefied Petroleum Gases COMMENT ON PROPOSAL NO: 58-131 RECOMMENDATION: Revise 2-2.6.4 to read:

2-2.6.4 EffecfiveJanuary !, !993, A warning label shall be applied to all portable refillable LP-Gas cylinders of 100 lb (45.4 kg) LP- Gas capacity or less not filled on site. The label shall include information on file potential hazards of LP-Gas. SUBSTANTIATION: The requirement is now applicable to all cylinders. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #20) 58- 18 - (2-3.1.5): Accept in Principle SUBMITTER: Carlos de Le6n, Flama Gas, S.A. COMMENT ON PROPOSAL NO: 58-19 RECOMMENDATION: Committee Action: Add a new 2-3.1.5 to read:

Cylinders with 4 lb through 10 Ib propane capacity for vapor service, fabricated after March 31, 1998 shall be equipped or fitted with a listed overfilling prevention device. The device shall be part of the cylinder assembly.

Exception: All cylinders used in industrial truck service (induding forklift, truck cylinders) and industrial welding and cuttinggas service -;.a..'c~ ---re ~c. "~¢::.~fie~. SUBSTANTIATION: Substantive elements on this proposal have been clarified since the Technical Committee meeting in Mexico

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City, i.e., relief valve capacity of compac t cylinders, retrofit prohibi t ions on cylinders larger t h a n 40 lb, etc~, tha t cont r ibuted towards the deve lopmen t of the cylinder size range in Proposal 58- 19, Log 39a (and o ther related p r o p o s a l s ) . It is impor t an t to ma in ta in the cited cylinder sizes in the original proposal. COMMITTEE ACTION: Accept in Principle. COMMITTEE STATEMENT: Refer to Commi t t ee Action on C o m m e n t 58-20 (Log #63). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 26 NEGATIVE: 1 N O T RETURNED: 1 Van Hook

EXPLANATION OF NEGATIVE: PAKRUDA: See m y Explanat ion of Negative on C o m m e n t 58-9

(Log #62). COMMENT ON AFFIRMATIVE:

PETRU: Refer to L. Pakruda ' s C ommen t s .

(Log #44) 58- 19 - (2-3.1.5): Reject SUBMITTER: J o h n Danks , Texas P ropane Gas Association COMMENT ON PROPOSAL NO: 58-19 RECOMMENDATION: Add text as follows:

Refer to Subsect ion 9.307. Filling of D e p a r u n e n t of Transpor t a t ion Containers .

Note: Suppor t ing material is available for review at the NFPA headquar te rs .

The p roposed regula t ions m a n d a t i n g the use of Overfill Protect ion Devices (OPD) to be retrofi t ted on 4 to 40 lb. cylinders appear to be an effort to make a lot of extra m o n e y while =reproving by appearance the safety of our industry. Admittedly, TPGA has been on the pe r iphery of the issue since its incept ion, however, some of our key m e m b e r s have u rged tha t we take a posi t ion in opposi t ion to the OPD proposal. How m a n y more regulatory bells and whistles are n e e d e d before e n o u g h safety is achieved? In Texas, there now exist several r u l e s g o v e r n i n g the filling and overfilling of cylinders. In Texas, D O T conta iners of less t han 101 lbs. LP-gas capacity are filled by weight only. DOT cylinders of 101 lbs. LP-gas capacity or more m a y b e filled by ei ther a fixed liquid level gauge o r by weighing. In Mexico, 65 and 70 lb. cylinders are c o m m o n . Will this rule eventually cover retroactively those cylinders above 40 lbs.? Clearly, cylinder accidents due to overfills are few and far between. Even t h o u g h LP-gas adminis t ra tors suppo r t this proposal , they do no t suppo r t retrofits. In Texas, there are between 500,000 and 600,000 cylinders in use. With very few accidents there exist plenty of quest ions as to why we need a $6 piece of e q u i p m e n t and existing rules. In Texas we will cont inue to fill by weight and will lobby the Texas Railroad Commiss ion to allow the p rocedure in lieu o f OPDs.

Some addit ional thoughts . 1. The rat ionale is hooelesslv flawed a n d contradictory. This

proposal is based solely on the premise that our indus t ry canno t d e p e n d upon its opera t ing pe rsonne l to do their jobs correctly. If this is true, t hen the retrofit por t ion of this OPD proposal is flawed because it d epends on the very same opera t ing pe rsonne l to refuse to fill cylinders unti l cus tomers pay for new valves, install t h em properly, etc.

2. This oronosal will cost n rooane consumer s simaificantlv with no cost-benefit study.

3. A p receden t will be establ ished tha t conf i rms the no t ion that our industry canno t d e p e n d on our pe r sonne l to do thei r jobs, we are unable to train and supervise them, a n d that regula tors are unable to enforce the rules. Therefore , we can expect these same forces to use the same rationale to require residential conta iners to be retrofi t ted with OPDs.

4. Good bulk cus tomers will be a l ienated by p ropane marketers who refuse to fill their conta iners unti l the cus tomer pays for a new valve or goes to an exchange company where they will pay an upgrade fee.

5. n o t i o n s were n o t considered. The NPGA Board a n d the T & S Commi t tee were p resen ted with the main ques t ion "Should we or shou ld we no t m a n d a t e OPDs?" Marketers were in a very th in minor i ty on the task force tha t cons idered this quest ion. The ques t ion posed shou l d have been "How can we best improve cylinder safety?" T he T & S Commi t tee is only 1 / 3 marketers . Only two marketers voted for this.

6. Existin~ law orohibi ts overfilling. In Texas, the Railroad Commiss ion has rules govern ing the filling o f cylinders u n d e r and over 101 lbs.

Safety is no t the pr imary concern here. The well-being of the marketers is no t the pr imary concern either, there currently exist plenty of rules, regula t ions and e n f o r c e m e n t on cylinder filling to keep our indus t ry safe. I suggest tha t your commi t tee do a s tudy on accidents associated with cylinder filling. You'll see. We urge you to recons ider this decis ion based purely on the opposi t ion by professionally t ra ined marketers o f p ropane gas, the i n d e p e n d e n t

~ ropane marketers of America. UBSTANTIATION: OPD protec t ion is n e e d e d wh en existing

laws are silent. In Texas, overfill protec t ion is covered by the RRC docket. Acc ident da ta is available in Texas tha t bears this out. This is overkill. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Commi t tee S ta tement on C o m m e n t 58-20 (Log #63). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: LAMAR: 1. T ime requi red for retrofit is far too severe. It can ' t

be attained. 2. Refillers will rely on the OPD as the pr imary or sole l imiting

device in refilling. (Some of these devices will fail to pe r fo rm properly).

PAKRUDA: See my Explanat ion of Negative on C o m m e n t 58-9 (Log #62). COMMENT ON AFFIRMATIVE:

PETRU: Refer to L. Pakruda 's Commen t s .

(Log #63) 58- 20 - (2-3.1.5): Accept in Principle SUBMITTER: Bruce Swiecicki, Nat'l P ropane Gas Assn. COMMENT ON PROPOSAL NO: 58-19 RECOMMENDATION: Revise the NFPA Technical Commit tee ' s r e c o m m e n d a t i o n by m a k i n g Section 2-3.1.5 read as follows:

2-3.1.5 Pc~aS!c D O T Cylinders with 4 lb t h r o u g h ~7-~ 40 lb. p ropane capao ty for vapor servace . . . . . . . . . . . . . . . . . . . . . . . . . . . . shall ~ ~ . l u . v r . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~, v . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . t " . . . . . . . . ~ C , " ~2,3.9. i l l "

with the following: (a~ Cylinders fabricated after March 31. 1998 shall be equipped

or fitted with a listed overfillin~ nrevent iou device an d a f ixed m a x i m u m linuid level Lrau~e. ~flaese devices shall be har t of the conta iner assembly. T h e l eng th of the f ixed m a x i m u m licmid level ~an~e shall be d e t e r m i n e d usintz Table F-4.3.4.

(bl Cylinders reuualif ied (see 2-2.1.4 ( b ~ after March 31. 1998 and before Anril 2002. shall be equ ipped with an overfilling nrevent ion device and a fixed m a x i m u m liouid level gauge pr ior to bein~ filled. The lenlzth of the f ixed m a x i m u m liuuid level gauge shall be d e t e r m i n e d us inu Table F-4.3.4.

(c) As of Anril 2002. no cvlinder shall he filled unless it ifi equ ipped w i t an overfill ing prevent ion device igld a fixed m a x i m u m liuuid level ~au~e. The length of the fixed m a x i m u m liouid level ~au~e sha l l b e d e t e r m i n e d u s i u ~ Table F4.3.4.

(d) Cylinders reouired to have an overfilH-n~ nrevent ion device installed shall be equ ipped with ei ther a T vpe][~ 1-5/16 in ACME connec t ion or a CGA 810 connect ion, as descr ibed within ANSI z21.58 Cylinder Connec t ion Devices,

Exception: All cylinders used in industr ial t ruck service, ( inc luding forklift t ruck cylinders) a n d cylinders ideutif ied an d used for industr ial welding a n d cut t ing gases ~e:'.Sce w.h.:.ch 2.re ~v

shall be e x e m p t f rom these requ i rements . SUBSTANTIATION: 1. The NFPA Technica l Commi t tee action to change the effective date is acceptable. For editorial purposes , "Portable DOT" has been deleted.

2. T h e addi t ion of the phrase "which are so identified" is a compromise which the commi t t ee accepted to pe rmi t proprie tary industrial welding gases to be e x e m p t e d f r o m these requi rements , due to the inheren t ly h igher level o f control over those cylinders. The except ion has been revised to make it read easier.

3. The NFPA Technica l Commi t tee act ion to expan d the cylinder range f rom 4 lb. t h r o u g h 70 lb. is unacceptable . It is r e c o m m e n d e d to change the cylinder range back to 4 lb. t h ro u g h 40 lb as shown in the original proposal . The expans ion of the cylinder size range does no t reflect a demons t r a t ed need . Portable

2 0 8

N F P A 58 ~ F 9 7 R O C

cylinders of the 4 lb. through 40 lb. size, which are addressed in the NPGA proposal, have been:

Identified in third party contract work for the Consumers Products Safety Commission, cylinder and equipment manufacturers, insurance companies, expert witness consultants and propane marketers as the cylinders mat should be recipients of the OPD.

Targed as those that are most likely to be filled at small dispenser locations rather than at bulk plants.

NFPA 58 is nationally recognized standard for the United States. Although discussion has taken place for the adoption of NFPA 58

in other countries, the Committee needs to remain focused on the use and present adoption of the standard. Perhaps in the standard, NFPA should consider an internationalsecdon or geographical delineation. Such inclusions could be based on umque regional and cultural conditions which require extraordinary attention based on approval of the authority having jurisdiction. The many years of research and deliberation in the United States on this matter indicate that the 40# cylinder is the maximum capacity cylinder the standard should impact. The Committee is strongly urged to support the expertise, testing and experience in the UnitedStates andlimit the cylinder size to 40 lb.

No technical or historical substantiation has been provided to increase the cylinder size from 40 lb. to 70 lb. To the contrary, limiting the requirement for the installation of OPD's to cylinders no larger than 40 lb. is supported by the relief valve discharge capacity limitations of the compact valve. The need for increased relief valve surface area on 50 lb. through 100 lb. cylinders requires the heavy duty valve. Expanding the applicable range of the OPD requirement to 70 lb. necessitates supplying two models of valves with the OPD's. Many containers in the expanded range use a screwed cap that will not accept an OPD-equipped valve that utilizes a new-type connector.

Additionally, use of the heavy duty valve has the potential for compromising safety. It is too tall to be properly protected by many 4 lb. through 40 lb. cylinder guards and willcomplicate or prohibit a retrofit installation in qualified cylinders with older guard designs, especially when valve bodies are extended to incorporate the new cylinder connection devices.

4. Text appearing in subparagraphs (1, (2), (3) and (4) represents an attempt to incorporate the work of the Tst-1562 task force into the proposed comment. Of the seven items required by the NPGA Board of Directors to be addressed the the T&S Committee, parts (1), (2), (3) and (4) address two: the objective of limiting the number of valve service connections, and the full compliance date. The reference to a new table in Appendix F is to reduce the opportunity :for errors in dip tube length during the retrofit installataon process. In addition to providing a uniform dip tube length for cylinders undergoing requalification, the proposal will a lsopermit the safe installation of a used valve on another cylinder. Note: The major cylinder manufacturers are currendy verifying the dimensions in Table F- 4.3.3. It may be necessary to revise the table at the June meeting of the Technical Committee.

5. Regarding 2-3.1.5(4), the ANSI z21.81 Cylinder Connection Devices standard is currently being developed under the ANSI procedures for adoption as a new document. It is anticipated that the standard will be pubfished in April of 1997. In the event that the document is either not available by the time the 1998 edition of NFPA 58 is discussed at the 1997 Fall Meeting of NFPA, or is judged to be inappropriate for some other reason, NPGA directs its Technology and Standards Committee to make the final decision on how to address the matter. COMMITTEE ACTION: Accept in Principle.

1. Accept the proposed 2-3.1.5 2. Add a new 2-3.1.5 to read: (a)* Cylinders fabricated after March 31, 1998 shall be equipped

or fitted with a listed overfillingprevention device and a f ixed maximum liquid level gauge. These devices shall be part of the container assembly. The length of the fixed maximum liquid level gauge dip tube shall be in accordance with 4-3.4.

3. Add a new A-2-3.1.5 to read: See Table F-4-3.4. 4. Add a new (b) to read: (b) Cylinders requalified after March 31, 1998 shall be equipped

with an overfilling prevention device and a fixed maximum liquid level gauge dip tube prior to being filled.

5. Add a new (c) to read: (e) Effective April 1, 2002, no cylinder shall be filled unless it is

equipped with an overfilling prevention device and a fixed maximum liquid level gauge dip tube. The length of the fixed maximum liquid level gauge dip tube shall be in accordance with 4-3.4.

6. Add a new (d) and exception to read: (d) Cylinders required to have an overfilling prevention device

installed shall be equipped with either a CGA connection number 791 or a CGA connection number 810 as described in CGA Publication V-1.

Exception: All cylinders used in industrial truck service, (including forklift truck cylinders) and cylinders identified and used for industrial welding and cutting gases shall be exempt from these requirements. COMMITTEE STATEMENT: By the action taken in the ROP to require OPD's on newly manufactured cylinders the Committee recognized their significant contribution to public safety. Upon further consideration, the Committee determined that the 40 - 70 million currently in LP-Gas service without OPD's represent a continuing risk to public safety. Therefore, action is taken to require retrofitting of these cylinders in an orderly manner prior to fillinl~ with a goal of all covered cylinders being equipped with OPD s by the year 2002. The manufacturers, distributors and installers represented at the committee meeting have affirmed their ability to adhere to this deadline.

Other changes from the comment are editorial. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: LAMAR: See my Explanation of Negative on Comment 58-19

(Log#44). MORTIMER: While overfill protection devices are not without

merit, requiring them on all cylinders by the year 2002, is unrealistic and unwarranted. Currently, proper filling of a cylinder by ;weight or outa.~e gauge is. more than adequate, to properly fill cylinders. Reqmrmg all cyhnders to be equipped with an overfill protection device will have many dealers andcylinder filling facilities relying on the overfill protection device as a primary fill method. As it was never intended that this overfill protection device be a primary fill method, it should not be included in the standard as a requirement.

Firms wandng to produce such a device and sell it as an added safety feature of their container or their valve, could do so without having it be a mandatory item for all cylinders by the year 2002.

PAKRUDA: See my Explanation of Negative on Comment 58-9 (Log #62). COMMENT ON AFFIRMATIVE:

PETRU: Refer to L. Pakruda's Comments. RENFREW: I support adding an OPD device as a secondary

means of preventing overfills in cylinders. When this issue first was presented before the committee, the original language was really

~ ushing for the OPD to be a third accepted means of filling which have strongly disagreed with. Now, with that perspective in

check, the committee has added in a retrofit date which 1 think is unrealistic- I am supporting this comment in the interest of safety that OPD device willbring to preventing overfills in the future. Currendy with the different valves in the field and adding this one, some problems will occur, but wither proper training at the refill locations, the OPD will enhance safety. I support many of Mr. Pakruda's negative comments on OPDs.

(Log #75) 58- 21 - (2-3.1.5): Reject SUBMrYrER: Thomas D. Petru, LP-Gas Administrators COMMENT ON PROPOSAL NO: 58-19 RECOMMENDATION: The LP-gas administrators support the Technical Committee's recommended action on 58-19-(2.3.1.5), log #39~, SUBSTANTIATION: Additionally, at this time, the administrators' are against the proposal 58-19 being retroactive primarily due to the number of cylinders involved and the lack of supporting documentation to support a retrofit. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The comment does not contain a

ecific recommendation. BER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28

VOTE ON COMMITTEE ACTION: AFFIRMATIVE- 24 NEGATIVE: 3 NOT RETURNED: 1 Van Hook

EXPLANATION OF NEGATIVE: [2uMAR: See my Explanation of Negative on Comment 58-19

(Log #44).

209

N F P A 58 - - F 9 7 R O C

PAKRUDA: See m y Explanat ion of Negative on C o m m e n t 58-9

( ~_~N~I~W: T ~ , ~ , ~ x See m y C o m m e n t on 58-20 (Log # 6 3 ) i n which I suppo r t the Commi t t ee and Mr. Pakruda 's c o m m e n t on OPDs. I th ink the LP-Gas Adminis t ra tors are r ight abou t the retrofit t ime. COMMENT O N AFFIRMATIVE:


(Log #121) 58- 22 - (2-3.1.5): Reject SUBMITTER: J o h n D a n k s , Texas P ropane Gas Assn. COMMENT ON PROPOSAL NO: 58-19 RECOMMENDATION: T he proposed regula t ions m a n d a t i n g the use of Overfill Protec t ion Devices (OPT) to be retrofi t ted on 40 - 40 lb. cylinders appear to be an effort to make a lot of extra m o n e y while improving by appea rance the safety of our industry. Admittedly, TPGA has been on the per iphery of the issue s ince its inception, however, some of our key m e m b e r s have u rged tha t we take a posit ion in opposi t ion to the OPT proposal . How m a n y more regulatory bells a n d whistles are n e e d e d before e n o u g h safety is achieved? In Texas, the re now exist several rules govern ing the f i l l ing and overfilling of cylinders. In Texas, D O T containers o f less than 101 lbs. LP-gas capacity are filled by weight only. DO]- cylinders of 101 lbs. LP-capacity or more may be filled by ei ther a fixed liquid level gauge or by weighing. In Mexico, 65 an 70 lb cylinders are c o m m o n . Will this rule eventually cover retroactively those cylinders above 40 lbs.? Clearly, cylinder accidents due to overfills are few and far between. Even t hough LP-gas adntinis trators suppo r t this proposal, they do no t suppor t retrofits° In Texas we will con t inue to fill by weight and will lobby the Texas Railroad Commiss ion to allow the p rocedure in lieu of OPDs.

Some addi t ional thoughts . 1. The rationale is hovelesslv flawed and contradictory. This

proposal is based solely on the premise that our indust ry canno t d e p e n d u p o n its opera t ing pe rsonne l to do their jobs correctly. If this is true, t h e n the retrofit por t ion of this OPT proposal is flawed because it d e p e n d s on the very same opera t ing personne l to refuse to fill cylinders until cus tomers pay for new valves, install t h em properly, etc.

2. This prOposa~ will cost Drovane ¢onsun)ers significar~t|y with no cost-benefit study.

3. A p receden t will be establ ished that conf i rms the no t ion tha t our inrJustry canno t d e p e n d on our pe r sonne l to do their jobs, we are unable to train and supervise them, a n d that regulators are unable to enforce the rules. Therefore , we can expect these same forces to use the same rat ionale to require residential containers to be retrofi t ted with OPDs.

4. Good bulk customer~ will be a l ienated by p ropane marketers who refuse to fill their conta iners until the cus tomer pays for a new valve or goes to an exchange company where they wiUpay an upgrade fee.

5. Or t i ons were no t considered. The NPGA Board and the T&S Commi t t ee were p resen ted with the ma i n ques t ion "Should we or shou ld we no t m a n d a t e OPDs?" Marketers were in a very th in minor i ty on the task force that considered this quest ion. The ques t ion posed shou ld have been "How can we best improve cylinder safety?" The T&S Commit tee is only 1 / 3 marketers . Only two marketers voted for this.

6. Existing law prohibits overfilling. In Texas, the Railroad Commiss ion has rules govern ing the filling of cylinders u n d e r a n d over 101 Ibs.

Safety is no t the pr imary concern here. The well-being of the marketers is no t the pr imary concern either. The re current ly exist plenty o f rules, regula t ions and en fo rcemen t on cylinder filling to keep our indust ry safe. I suggest tha t your commit tee do a s tudy on accidents associated with cylinder filling. You'll see. We urge you to recons ider this decis ion based purely on the opposi t ion by professionally t ra ined marketers of p ropane gas, the i n d e p e n d e n t p ropane marketers of America.

Note: Suppor t ing material is available for review at NFPA headquar te r s . SUBSTANTIATION: OPT protec t ion is n e e d e d when exis t ing laws are silent. In Texas, overfill protec t ion is covered by the RRC docket. Acc ident da ta is available in Texas that bears this out. This is overkill. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Commi t t ee S ta tement on C o m m e n t 58-20 (Log #63). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28

VOTE ON COMMITTEE ACTION: AFFIRMATIVE: 25 NEGATIVE: 2 N O T RETURNED: 1 Van Hook

EXPLANATION OF NEGATIVE: LAMAR: See m y Explanat ion of Negative on C o m m e n t 58-19

(Log #44). PAKRUDA: See my Explana t ion of Negative on C o m m e n t 58-9



(Log #122) 58- 23 - (2-3.1.5): Reject SUBMITTER: O. L. Garre tson , Garre tson Engr Co. COMMENT ON PROPOSAL NO: 58-19 RECOMMENDATION: Add new text as follows:

T h e use of the OPD of any des ign now available, would be a major backward step in LP Gas safety. The small cylinders, ie: 20 lbs p ropane capacity are taken every where by every body a n d filled by the user, by the extra he lpe r with 10 seconds oral instructions, a f r iend who wants to give his f r iend a "bakers dozen" a n d others "in the dark" and no t safe or legal to drive a car at the time. Over filling is with intent very often, as well as lack of at tent ion, an error du r to bose tension lifting the cylinder, over looking the weight of contents vefore the start of filling and m a n y others. Th e "OPD" as now discussed will ~ to big and small accidents. A scale weight check will become rare, as this is no way to take excess p ropane out, and filling people will mos t of ten be even less t ra ined or adults. Filling to 80 percen t at all t empera tu res will be s tandard and a s sumed to be allowed by many. Filling to the OPD level and add ing p ropane to ge t to 20 lb weight will be c o m m o n at all t empera tu res above 40 degrees F.

There ' s a new type o f "stop fill" that fills by weight., i.e., "filling density"' regardless of the p ropane t empera tu re of Sp.G. It is also inside the cylinder, is s imple in principle, few parts and shou ld prove to give m o r e cons tan t fill weight t han we now get with scales. It shou ld be on the market in the USA later in 1997. It appears to be a big step ahead in safety a n d it will also please all interested in weights a n d m e a s u r e s .

An "over f i l l ingpro tec t ion device" that allows " topping Off" to 100 pe rcen t l iqu idfu l l is like a fire a rm with a safety device that doesn ' t work. T h e s imple act o f laying a cylinder on it side to fill it l iquid full in spite of oan OPD, makes the OPD deceptive.

At a very m i n b i m u m , Appendix F, pa rag raph F4.2.1 (see 58-133, Log #39f, page 297 of the ROP, shou ld read "--prevention device (if it operates on a vo lummet r ic basis) is designed, or the variable

~ age is set, to--" UBSTANTIATION: Eng inee r ing degree and 40+ years in the LP a~ industry.

MMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Commi t tee Action on C o m m e n t 58-9 (Log #62). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: LAMAR: See my Explanat ion of Negative on C o m m e n t 58-19

(Log #44). PAKRUDA= See my Explanat ion of Negative on C o m m e n t 58-9

(Log #62). COMMENT O N AFFIRMATIVE:

PETRU: Refer to L. Pakruda 's Comments .

(Log #130) 58- 24 - (2-3.1.5): Accept in Principle SUBMITrER: &even T Gentry, Wor th ing ton Cylinder Corp COMMENT ON PROPOSAL NO: 58-19 RECOMMENDATION: Revise text to read as follows:

"2-3.1.5 Portable DOT cylinders with 4 lb t h r o u g h 70 lb 40 lb,

g ropane capacity..." UBSTANTIATION: 1. In discussing and modify ing this topic,

the Technical Commi t t ee did no t discuss the issue tha t some cylinders over 40 lb LP-Gas capacity may conta in l iquid vapor valves. In order to equip the cylinder with an OPD, an addit ional open ing would have to be placed in all cylinders greater than 40 lb LP-Gas capacity. This would potential ly require that all cylinders

2 1 0

N F P A 58 ~ F 9 7 R O C

41 lb through 70 Ib LP-Gas capacity be rebuilt or scrapped to accommodate the OPD. I have not been convinced by the Technical Committee that a problem exist with these cylinders and that safety would be enhanced by expanding the requirement from the original submitters request.

2. To accommodated the 70 lb LP-Gas requirement, cylinders using liquid vapor valves would have to be completely redesigned so that the cylinder could not be filled through the outlet connection. To my knowledge, there is no such device for use in LP-Gas.

:5. Although I agree dlat is would be nice to have NFPA 58 adopted by many countries throughout the world, we need to focus that it is an ANSI standard. The Technical Committee increased the cylinder size from 40 lb to 70 lb to accommodate metric size cylinders used outside the United States. I believe that the standard should reflect the requirements of the United States and the additional countries that adopt the standard should be handled as exceptions or additions once that specific country adopts the standard. COMMITTEE ACTION: Accept in Principle. COMMITTEE STATEMENT: Refer to Committee Action 58-20 (Log #63). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: LAMAI~ See my Explanation of Negative on Comment 58-19

(Log #44). PAKRUDA= See my Explanation of Negative on Comment 58-9


PETRU: Refer to L. Pa~uda's Comments.

(Log #33) 58- 25 - (2-3.1.5 (New)): Accept in Principle SUBMITTER: Bruce Swiecicki, Nat'l Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-20 RECOMMENDATION: Comment: Reject the proposal. SUBSTANTIATION: _Substantiation: Refer to the reasons stated in the ROP under the negative ballots. COMMITTEE ACTION: Accept in Principle.

I ccept the comment and revise 2-2.1.4 (a) to read: (a) A container shall not be filled if it-the container assembly is

not suitable for continued service. COMMITTEE STATEMENT: Revision of 2-2.1.4 (a) clarifies requirements for container safety. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


focus that it is an ANSI standard. The Technical Committee increased the cylinder size from 40 lb to 70 lb to accommodate metric size cylinders used outside the United States. I believe that the standard should reflect the requirements of the United States and the additional counudes that adopt the standard should be handled as exceptions or additions once that specific country adopts the standard. COMMITTEE ACTION: Accept in Principle. COMMITTEE STATEMENT: Refer to Committee Action on Comment 58-27 (Log #64). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: PAKRUDA: See my Explanation of Negative on Comment 58-9



(Log #64) 58- 27 - (Table 2-3.3.2(a)): Accept SUBMITTER: Bruce Swiecicki, Nat'l Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-21 RECOMMENDATION: 1. Change sub-paragraph 2 of the proposal to read See 2-3.3.2 (a) fS) and delete t~ from the cell.

2. Delete sub-paragraph 3 and add a new Section 2-3.3.2 (a) (5) as follows: 2-3.3.2 (al (5) Overfilling prevention devices and fixed maximum liquid level gauges shall b~erequired on cylinders having 4 lb. through 40 lb. propane capacity for vapor service. See 2-3.1.5.

3. In Row F, column 1, revise as follows: g 0 / R / . See 2-3.3.2 (a) (5)~

SUBSTANTIATION: (1) The new format is consistent with the action taken by the Committee on Proposal 58-24.

(2) The NFPA Technical Committee action to expand the cylinder range from 4 lb. through 70 lb. is without foundation. Refer to details in the reason for comment on Log #39a.

(3) The reference to 2-3.1.5 is added for clarification of the OSMMilicability of this new note.

TTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:





(Log #131) 58- 26 - (2-3.3.2(a)): Accept in Principle SUBMII~I'ER: Steven T Gentry, Worthington Cylinder Corp COMMENT ON PROPOSAL NO: 58-21 RECOMMENDATION: Revise text to read as follows:

2-3.3.2(a) Note 13 Overfilling prevention devices shall not be required on cylinders with less than 4 lb or more than 70 lb 40 Ib, propane capacity. SUBSTANTIATION: I. In discussing and modifying this topic, the Technical Gommittee did not discuss the issue that some cylinders over 40 lb LP-Gas capacity may contain liquid vapor valves. In order to equip the cylinder with an OPD, an additional opening would have to be. placed in all cylinders greater than 40 lb LP-Gas capacity. This would potentially require that all cylinders 41 lb through 70 lb LP-Gas capacity be rebuilt or scrapped to accommodate the OPD. I have not been convinced by the Technical Committee that a problem exist with these cylinders and that safety would be enhanced by expanding the requirement from the original submitters request.

2. To accommodated the 70 lb LP-C, as requirement, cylinders using liquid vapor valves would have to be completely redesigned so that the cylinder could not be filled through the outlet connection. To my knowledge, there is no such device for use in LP-Gas.

3. Although I agree that is would be nice to have NFPA 58 adopted by many countries throughout the world, we need to

(Log #19) 58- 28 - (2-3.3.2(a).2): Accept in Principle SUBMITTER: James H. Stannard, Jr., Stannard & Coo COMMENT ON PROPOSAL NO: 58-12 RECOMMENDATION: Revise as follows:

Exception: An actuated liquid withdrawal valve shall not be required on any size container when the container is equipped with a bottom outlet valve and an excess flow valve for liquid withdrawal ax:d mz cxcc~ ficw ;'al;'c. SUBSTANTIATION: Amended statement clarifies the intent. COMMITTEE ACTION: Accept in Principle.

Revise the exception to 2-5.3.2(a) 2 to read: Exception: An actuated liquid withdrawal excess-flow valve shall

not be required on containers equipped for liquid withdrawal with both a liquid outlet shutoff valve and an excess flow valve. COMMITTEE STATEMENT: The comment is accepted and modifed for clarity. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMI'VrEE ACTION:


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N F P A 58 ~ F 9 7 R O C

(Log #34) 58- 29 - (2-3.3.2(b) (1) and 2-3.3.2(b) (2)): Accept SUBMITTER: Bruce Swiecicki, Nat'l Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-28 RECOMMENDATION: i t " o e • Typo, change s e c o n d " b " to "a'. SUBSTANTIATION: None. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


. (Log #65) 58- 30 - (2-3.4.1 and 2-3.4.2): Accept SUBMITTER: Bruce Swiecicki, Nat'l Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-29 RECOMMENDATION: C o m m e n t # l : Amend the NFPA Technical Committee action by retaining the current Section 2- 3.4.1 and editorially insert "maximum liquid" after "Fixed" in the second sentence, as follows:

2-3.4.1 Liquid level gauging devices shall be provided on all containers filled by volume. Fixed maximum liquid level gauges or variable gauges of the slip tube, rotary tube, or float types (or combinations of such gauges) shall be permit ted to be used to comply with th isprovis ion.

NPGA P r o n o s e d C o m m e n t #2: Revise the NFPA Technical Commit tee ' s r ecommenda t ion by making Section 2-3.4.2 read as follows:

2-3.4.2 Every ~v.r~r'~r ~p'-~'a:~ container constructed after December 31. 1965 and designed to be filled on a volumetric basis, shall be equipped with a fixed maximum liquid level d ~ c - e ~ or an c.;'z,'.=!!ing p rzvcndcn dz;'cc to indicate the maximum filling level(s) for the service(s) in which the

is to be used (see 4-4.3.3). This shall be oermit ted to be accomnlished either by usin~ a did tube of aDnroDriate length or by thepos i t ion of the ~auL, in-~ device in the container. T h e following shall also apply to fixed maximum liquid level gauges: SUBSTANTIATION: C o m m e n t #1

Notwithstanding the provisions of Section 2-3.4.2, which are directed to the use of f ixed maximum liquid level gauges devices, Section 2-3.4.1 addresses all containers filled by the volumetric method. Rather than filling volumetrically with the use of a fixed maximum liquid level gauge, some of these containers utilize other types of liquid level gauging devices. The delet ion of Section 2- 3.4.1 would disenfranchise many containers that have these other types of acceptable liquid level gauging devices.

Comment #2 (a) The data should be retained to provide an historical

reference po in t on the change of requirements for containers. (b) In order to avoid compromising the safety of the volumetric

filling method, it is necessary that a fixed maximum liquid level gauge continue to be required on containers manufactured after the referenced date.

(c) Note that Section 2-3.1.5 already requires the OPD for cylinders having capacities of 4 lb. through 40 lb. Not referrinf~ to the OPD in Section 2-3.4.2 will emphasize that the device is to b e considered a backup to conventional filling methods. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #112) 58- 31 - (2-3.4.2): Reject SUBMITTER: Henry Renfrew, Dept of Public Safety COMMENT ON PROPOSAL NO: 58-29 RECOMMENDATION: Add new text as follows:

2-3.4.2* Every DOT cylinder designed to be filled on a volumetric basis, shall be equ ipped with a f ixed maximum liquid level gauging device and oe an overfilling prevention device to indicate the maximum filling level(s) for the service(s) in which the cylinder is to be used (see 4-4.3.3). The following shall also apply to fixed maximum liquid level gauges.

2-3.4.2 The primary methods of filling cylinders will remain the volumetric filling m e t h o d or the filling by weight method. The overfilling prevention device is des igned to be a back up to reduce the risk of overfilling of the cylinders.

Added to appendix: 2-3.4.2 The primary methods of f i l l ingcylinders will remain the

volumetric filling me t hod or the f i l l ingby weight method. The overfilling prevention device is designed to be a back up to reduct the risk of overf i l ingof the cylinders. SUBSTANTIATION: It is no t clear in the requirements added for Overfill Prevention Devices that the primary methods of filling cylinders remains the volumetric filling m e t h o d or the filling by weight method. The overfilling prevention device is designed to be a back up to reduce the risk of overfilling of the cylinders and no where in any of the proposals is that made clear. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Commit tee Action on Comment 58-30 (Log #65). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:





(Log #13) 58- 32- (2-4.1.1): Reject SUBMITTER: James H. Stannard, J r . , S tannard & Co. COMMENT ON PROPOSAL NO: 58-30 RECOMMENDATION: Delete entire section. SUBSTANTIATION: Material may be found in most handbooks and does no t belong in safety standard. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The commit tee believes that users of the s tandard need the material. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #55) 58- 33 - (2-4.1.1(b) and Appendix J): Accept in Principle in Part SUBMITTER: Bruce Swiecicki, Nat'i Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-30 RECOMMENDATION: Revise text as follows:

1. In response to NFPA staff request, the following tables should be copied f rom the National Fuel Gas Code into NFPA 58: Tables 10-25, 10-27, 10-32.

2. Editorial Comment: The last sentence to Section 1-1.3.1 (f) NOTE must be changed editorially to recognize the change in scope of the National Fuel Gas Code.

3. Delete Tables 2, 4A and 4B as shown in the ROP. These tables were inadvertently proposed for NFPA 58 but they fall outside the scope of the standard.

4. Revise the proposal as follows in order to provide more complete information on sizing LP-gas piping systems between the container and the final stage pressure regulator. The language p roposed below is based on current language appearing in NFPA 54/ANSI z223.1 National Fuel Gas Code.

Insert new Section 2-4.2, r enumber existing subsequent sections as necessary.

2-4.2 Sizin~ of LP~as Piping Systems 2-4.2.1 LP-~as nit)in~ systems shall be of such size arid so

installed as to provide a suoDIv of ~as sufficient to meet the maximum d e m a n d without u n d u e l o s s of pressure.

2-4.2.2 The volume of ~as to be nrovided (in cubic feet her hour) shall be determine~d in accordance with the provisions contained in NFPA 54/ANSI z223.1 National Fuel Gas Code for the eau iomen t bein~ served.

2-4.2.3" Gas n i t ) in~and tubin~ shall be sized in accordance with: (a) The t~bie'in ~,ppendix J,-gr (b) Methods based on accentable em~ineering nractices.

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N F P A 58 ~ F 9 7 R O C

SUBSTANTIATION: This commen t responds to requests to provide suitable text to reference the sizing tables in A p p e n d i x J and to establish a m e thod for sizing pipe• The proposal above will provide the ne e de d informat ion and be consistent with the National Fuel Gas Code. COMMITTEE ACTION: Accept in Principle in Part.

1. Relocate Tables 1, 2, 3, 4a, and 4b to a new chapter 11, Pipe and Tubing Sizing Tables.

2. Add tables 10-25, 10-27, 10-32, 10-33 and 10-34 from NFPA 54 into Chapter 11.

3. Revise the title of NFPA 54 Table 10-33 to "Polyethylene plastic tube sizing, Sizing between first stage and second stage regulator".

4. Revise the last sentence of the Note to 1-1.3.1 (f) to read: For those systems within its scope, the National Fuel Gas Code is

applicable to those port ions of a system downstream of the outlet o f the final nressure regulator, exclusive of line ~as regulators first-

5. Add a new 3-2.8 Sizing of LP-Gas Vapor Piping Systems. 3-2.8 Sizing of LP-Gas Vapor Piping Systems. 3-2..8 1 LP-Gas vapor, piping systems . . . . downstream of the first stage

pressure shall be sized so that all apphances operate vathm their manufacturers specifications.

3-2.8.2 The size of gas piping shall be in accordance with acceptable engineer ing practices or the Tables in Chapter 11. COMMITTEE STATEMENT: The proposed text is accepted and reworded for editorial clarity. I tem 3 in the comment is not accepted as the tables are needed . NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: RITZMANN: 1 do no t feel that sizing tables should be a part of

the text, especially when a choice is given in the s tandard (...in accordance with acceptable engineer ing practice or the tables in Chapter 11.) The text gives requirements that must be followed. I feel that the sizing tables should be a part of a non-mandatory A p p e n d i x J as originally proposed as it is informat ion available f rom numerous handbooks.

(Log #108) 58- 34 - (2-4.5.5): Accept in Principle SUBMITTER: Richard G. Fredenburg , Dept. of Agriculture, Nor th Carolina COMMENT ON PROPOSAL NO: 58-70 RECOMMENDATION: Add a new Section 2-4.5.5 to read: Emergency shutoff valves shall be kent in Droner working order at all times in accordance with the manufacturer 's instructions and annlicable sections of this code. S[JBSTANTIATION: To establish a requ i rement for ESVs to be operational at all times so they can be relied on dur ing an emergency. Inspections indicate a main tenance level insufficient to meet this recjuirement~ Additionally, when an ESV does not opera teproper ly , the "fix" at least for the short term, seems to be to wire the valve handle in the open position thereby making the remote emergency shutoff station essentially inoperative. This presents a real danger for those in the area in the case of failure of a componen t dur ing transfer operations.

. COMMITTEE ACTION: Accept in Principle. Add a new 3-2.8.10 (c) to read:

] (c) Emergency shutoff valves shall be mainta ined in working [ order.

COMMITTEE STATEMENT: The proposal is accepted with editorial revision and relocated to Chapter 3. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: McHENRY: While ESV equipment should be in operating

condit ion at all times, the Commit tee Action on this Comment would:

Reouire a Euarantee that installed emergency shutoff valves are in p roper working order 100 percent of the time.

Place an imnossible compliance bu rden on operators. Characterize the Standard as p roposed policy and therefore,

place all o f its provisions unde r suspect as meaningless. Taken to its absurd extreme, one can envision the phrase "must be

operating at all time" appended to every paragraph in the Standard which describes the installation of equ ipment and appurtenances?

In addit ion to a mult i tude of o ther mandates, the Standard, under certain conditions requires the use of ESWs. Even if ESWs were checked for integrity before initiating product transfers, it is impossible for the devices to be considered trouble free and operative at all times. The Commit tee Action on Comment 58-68 (3-2.8.10(3) (c) is a more appropriate me t hod of dealing with such issues.

Proposals for safety improvements that address the transfer of liquefied pet ro leum gas must receive a more deliberate review. There is a bet ter way to achieve the goal of this Committee Action, and an effort that end is currently progressing through the NPGA T&S Committee.

(Log #53) 58- 35 - (2-5.1.3(e)): Reject SUBMITTER: Min-ChungLi , IMPCO Technologies COMMENT ON PROPOSAL NO: 58-35 RECOMMENDATION: IMPCO does no t agree with the recommenda t ion for change on Secdon 2-5.1.3 of NFPA 58 by the Technical Commit tee on LPG for the following reasons:

(a) The recommenda t ion does no t clarify where engineer ing plastics may be used.

(b) IMPCO strongly supports the use of engineer ing plastics for upper casings, lower casings and bodies of high-pressure (312 psi) regulators.

(c) IMPCO also supports that engineer ing plastics should be permit ted to be used in the construction of low-pressure (less than 20 psig inlet pressure) and secondary regulators.

We r e c o m m e n d the phrasing be changed as follows: Section 2-5.1.3(e) should be rephrased as "NON-metallic

materials shati--n~ ~1.~.~ be used for upper and lower casings of regulators. Non-metallic re~-ulators shall comply with applicable UL standards for en~ineerin~ nlastie nressure comnonentsA SUBSTANTIATION- In the-past ten'years or so, engineer ing

lastics have emerged as pr ime alternatives for metallic materials. comparison with metallic materials, plastics have advantages of

light weight, low cost and enhanced performance in durability, fatigue resistance and corrosion resistance. In today's cost- sensitive automotive industry, engineer ing plastics have been extensively used under the hood where weight, high-temperature performance, stiffness, s trength and corrosion resistance to automotive fluids are major concerns. Successful application of engineer ing plastics in the engine compar tment a n d chassis are listed in Table 1.

Note: Support ing material is available for review at NFPA headquarters.

Recently, IMPCO conducted research on our products by using engineer ing plastics. One of t h e p r o d u c t investigated was VFF-30 fuel lock-off. VFF-30 is ra ted at 312 psi which is the same as the rated pressure of LPGIow pressure regulators p roduced by IMPCO. Design was modif ied for engineer ing plastics. The design concept is shown in Figure 1. This design was modif ied for engineer ing plastics. The design concept is shown in Figure 1.

Design Concept for a Plastic VFF-30 Fuel kockoff • Fuel regulot lng rnechonism some

os o ~ design • l O g smoller, - -40X lighter • Consider Zytel, Hiqh-Tsnlparoture

Zytel end Ryton • Oes~jn hos been verified by o

flnRe e ~ m e M onolylfi~

~ let e Q ~ - . J ~

LP. fov~"

• * m r t o ~ e ~ v e ~ Opwm~ ~vw

~ - '2"2d.'J ""

213

N F P A 58 - - F 9 7 R O C

This design reduce weight by 44 pe rcen t and number of parts by 25 percent . It also utilizes a bet ter seal mechanism at the high- pressure side. Three materials f rom the Nylon family~ Zytel 70G33L, Zytel 70G43L and Zytel HTN51G45HSL; and Ryton R-4 which is a polyphenylene sulfide (PPS) material were investigated in this project. Mechanical propert ies are listed in Table 2. Figure 2 is the UL yellow card information of some Nylon materials. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The commen t would remove the requi rement for metallic regulator componen t s without providing information on alternates. T h e commit tee has been provided with no information on what would substitute for the metallic components . NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #35) 58- 36 - (2-5.7.2): Accept SUBMITTER: Bruce Swiecicki, Nat'l Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-40 RECOMMENDATION: The Committee 's action should be over turned and the proposal rejected. SUBSTANTIATION: The action taken on Proposal 58-39 dele ted Section 2-5.7.2. COMMITTEE ACTION: Accept. NUMBER OF COMblITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #CC10) 58- 37 - (2-7, 3-11 (New)): Accept SUBMITTER: Technical Commit tee on Liquefied Petroleum Gases COMMENT ON PROPOSAL NO: 58-41 RECOMMENDATION: 1. Delete the p roposed addit ion of a new Section 2-7.

2. Add a new Section 3-11, alternate Provisions for Installation of tanks over 2000 gal to read: 3-11 Alternate Provisions for Installation of ASME Containers. 3-11.1 Application. 3-11.1 This section provides alternate provisions for the location and installation of ASME containers that incorporate the use o f r edundan t fail-safe product control measures and low emission transfer concepts for the purpose of enhancing safety and to mitigate distance and special protect ion requirements . 3-11.2 Spacing Requirements. 3-11.2.1 Minimum distances for unde rg round and m o u n d e d ASME containers of 2001 th rough 30,000 gallon water capacity incorporat ing all the provisions of Section 3-11 shall be permit ted to be reduced to 10 ft. Distances for all unde rg round and m o u n d e d ASME containers shall be measured f rom the relief valve and the filling connect ion. No pat o f an underg round ASME container shall be less than 10 ft f rom a building or line of adjoining property that may be built upon, and no part of a m o u n d e d ASME container that is installed above grade shall be less than 5 ft f rom a building or line of adjoining property that may be built upon. 3-11.3 ASME Container Appurtenances. 3-11.3.1 The following provisions shall be required for ASME containers of 2001 th rough 30,000 gallon water capacity referenced in is section:

(a) All liquid withdrawal openings and all vapor withdrawal openings that are 1-1/4 in. or larger shall be equipped with an internal valve with an integral excess flow valve or excess flow protection. The internal valves shall remain closed except dur ing periods of operation. As required, the internal valves shall be equipped for remote closure and automatic shutoff th rough thermal (fire) actuation.

(b) In addit ion, a positive manual shutoff valve shall be installed as close as practical to each internal valve.

(c) All liquid and vapor inlet openings shall be equipped in accordance with (a) and (b) above or shall be e q u i p p e d w i t h a bacldlow check valve and a positive manual shutoff valve installed as close as practical to the backflow check valve.

3-11.4 Facility Piping Requirements. 3-11.4.1 The following r edundan t fail-safe product control measures are r e q u i r e d f o r systems covered in this section:

(a) At cargo tank and railroad tank car transfer points, protect ion shall be provided in accordance with 3-2.8.10 using approved emergency shutoff valves or bacldlow check valves or a combinat ion of the two.

(b) Automatic system shutdown of all primary valves (Internal valves and emergency shutoff valves) shal l be provided through thermal (fire) actuation and in the event of a hose pull-away.

(c) Remote shutdown capacity, including power supply for the transfer equ ipment and all primary valves (internal a n d e m e r g e n c y shutoff) s h a l l b e provided as follows:

1. A remote shutdown station shall be installed within 15 ft of the point of transfer.

2. At least one additional remote shutdown station shall be installed not less than 25 ft nor more than 100 ft f rom the transfer point.

3. Emergency remote shutdown stations shall be identified as such by a sign incorporat ing the words "Propane" and "Emergency Shutoff ' in block letters of not less than 2 in. in height, on a background of contrasting color to the letters and shall be visible from the point of transfer, 3-11.5 Low Emission Transfer. 3-11.5.1 With the application of the following provisions the transfer distance requirements of Table 3-2.3.3 and paragraph 3- 9.4.3 shall be permit ted to be reduced by one half. 3-11.5.2 Transfer into cylinders and ASME containers on vehicles shall meet the following provisions:

(a) The delivery valve and nozzle combination shall mate with the filler valve in the receiving container in such a manner that when they are uncoupled following a transfer of product, not more than 4 cc of product (liquid equivalent) shall be released to the atmosphere.

(b) Fixed maximum liquid level gauges shall not be used to de termine the maximum permit ted filling limit at a low emission transfer site. The maximum permit ted filling limit shall be de te rmined by an overfilling prevention device or other approved means. Where fixed maximum liquid level gauges.are installed, a label shall be placed near the .~xc~ mz.xlm~m !iqu:~ level gauge providing the following instructions: "Do not use this f ixed maximum liquid level gauge at Low Emission Transfer Stations." 3-11.5.3 Transfer into stationary ASME containers shall meet the following provisions:

(a) Where transfer is made through a hose of nominal 1 in. size or smaller, the delivery valve and nozzle combinat ion shall no t contain an interstitial volume greater than 4 cubic centimeters.

(b) Where transfer is made th rough hose larger than 1 in. : nominal size, no more than 15 cc of LP-Gas (liquid equivalent) I shall be released to the a tmosphere dur ing the transfer operation. This includes uncoupl ing the transfer hose(s).

(c) Fixed maximum liquid level gauges on low emission transfer systems shall be installed and used to verify the (function) accuracy of l iquid level gauges or other liquid level gauging devices. Fixed

[ maximum liquid level gauges shall not be used in the routine [ filling of low emission transfer systems. The use of a float gauge or [ o ther approved non-venting devise, for containers of 2,001 gallons ] w.c. or larger shall be permi t ted to be the sole means for I de termining the maximum filling limit. The maximum filling limit ' for containers of less than 2,001 gallons w.c. in low emission

transfer systems shall be control led through the use of an overfilling prevention device or o ther device approved for this service.

Table 3-2.2.2 (Log #58-44) Modify new 3-2.2.2(0 to read the same as proposed new revised paragraph 3-11.2.1.

Modify the last sentence of 3-2.2.2(h) to read: "Under no condit ion shall the distances to the building wail be

less than those specified except when the provisions of Section 3- 11.3 and Section 3-11.4 are r e e l These distances shall be permit ted to be reduced by one half for ASME containers of 2,001 through 30,000 gallon water capacity used in systems complying with Section 3-11." 3-2.2.4 Add a new second paragraph to read:

I "The separation distance between groups of ASME containers p r o t e c t e d b y hose stream only shall be permit ted to be reduced by one half when the provisions of Section 3-11.3 and 3-11.4 are met." *Table 3-2.3.3 (Log #58-44) In Table 3-2.3.3, add an asterisk to the right of the present "min imum horizontal distance" requirements in lines 2, 3, 4, 5, 6(b), and 10. Below the table add an asterisk followed by the statement:

"New 2-2.3.3(d) The distances in Table 3-2.3.3, Lines 2, 3, 4, 5, 6(b) and 10 shall be permit ted to be reduced by one half where the

214

N F P A 5 8 - - F 9 7 R O C

I system employs the provisions of low emission transfer as provided in Section 3-11.5."

Delete the present wording in the Report on Proposals covering Table 3-2.3.3 in Log #58-44 and use the above recommended language.

*Revise the first line of Table 3-2.2.4 to read: "Hose streams only - see 3-2.2.4 and 3-10.2.3 (remainder

unchanged). SUBSTANTIATION: This new section is added, andproposed new Section 2-7 is deleted to simplify the concept. In the new Section all requirements for reduced distances for ULET vehicle dispensing are located in one section. This will make it clear that they all must be complied with, rather than having them appear in different chapters with cross references which are easily ignored. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: MORTIMER: This section would require that an overfill

protection device be the only means of filling carl{o tanks or tank cars over 2,000 gal capacity. This make no provision for containers currently filled byuse of a fixed liquid level gauge, and yet if we refer to Chapter 2, 2-3.4.1 Wtxed liquid level gauges.., shall be permitted to be used to comply with this provision", the adding of this section would do nothing for increased safety.

RENFREW: See my Comment on 58-78 (Log #105). I disagree with the closer distances and I think 3.11.4(c)2. should be 20 ft not 25ft.

(Log #1) 58- 38 - (Chapter 3): Hold SUBM1TTER: Jeff Murray, Mississippi LC. Gas Board COMMENT ON PROPOSAL NO: N/A RECOMMENDATION: Add new text:

~A proposal to require a minimum separation of LP Gas containers from other compressed gas containers (such as anhydrous ammonia) which contain !products which are corrosive to the copper and brass fittings used m LP Gas containers."

I would recommend a minimum separation of 50 ft. SUBSTANTIATION: There exists a problem when LP Gas containers are located near anhydrous ammonia containers. Ammonia vapors are frequently released to the atmosphere in transfer operations. If these vapors come in contact with any brass or copper material, rapid destruction of these valves will occur. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: The comment contains new material that has not had public review. NIJMBER OF COMMITFEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITIT..E ACTION:


(Log #72) 58- 39 - (Chapter 3): Accept in Principle SUBMITI'ER: P.E. Duus, Steel Plate Fabricators Association Inc. COMMENT ON PROPOSAL NO: 584 RECOMMENDATION: Revise to agree with changes in NFPA 58 Chapter 9, including Appendix E. SUBSTANTIATION: Requirements in NFPA 59 and NFPA 58 should be consistent. COMMITTEE ACTION: Accept in Principle. COMMITTEE STATEMENT: Refer to Committee Action on Comment 58-100 (Log #CC1). NUMBER OF COMMITI~E MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #36) 58- 40 - (3.2.2.2 and Table 3-2.2.2): Accept SUBMITTER: Bruce Swiecicki, Nat'l Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-43 RECOMMENDATION: Revise the Committee proposal as follows:

3-2.2.2 (b) Cylinders installed alongside of buildings shall be located and installed so that the discharge from the cylinder pressure relief device is at least 3 ft horizontally away from any building opening that is below the level of such discharge mad-

~erce~t vf 'm perimeter. Cylinders shall not be located and installed underneath anv buildin~ unless the soace is not enclosed for more than 50 vercent of its nerimeter. (Remainder unchanged.)

3-2.2.2 (c) Delete current recommended text and replace with the following: The distance measured horizontally from the pQha~ of discharge of a container pressure relief valve to any building ouenin~ below the level of such discharge shall be in accordance with Table 3-2.2.2 (dL

3-2.2.2 (d) Delete current recommended text and replace with the following: The distances measured in any dir¢ct-jor~ from the point of discharge of a container t3ressure relief valve, the vent of a fixed maximum]iouid level ~aut~e on a container, or the installed location of the filli'n~ connection of a container, to any exterior source of itmition, ovenin~s into direct-vent (sealed combustion svstem) anvliances, or mechanical ventilation air i n t ac t , sh~Jl be in accordance with Table 3-2.2.2 (dL

Container Type

Exchange or Filled on Site

TABLE 3-2.2.2 tdt Distance

Horizontally FromRelief

Valve Discharge

To Opening Below

Discharge

Discharge From Relief Valve,

Vent Discharge, and Filling

Connection to Exterior Source

of Ignition, Openings

IntoDirect-Vent pliances, chanical

VentilationAir Intakes

Cylinder Exchange 3 ft. 5 ft. Cylinder Filled on 3 ft. 10 ft.

Site ASME F'dled on 5 ft. 10 ft.

Site

SUBSTANTIATION: This comment represents a reorganization of the material to provide more coherent requirements. It is essentially editorialin nature. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: Comment 58-40, Log 36 is actually a reorganization of

material now in Section 3-2.2.2. However, rather than perpetuate the permission for LP-gas containers to be located under buildings under certain conditions, I recommend that this Proposal be held and returned to the Committee to ~£.q.]ai.b~ locating LPwas containers and their pressure-relieving appurtenances (valves and pressure regulators reliefs) from being under buildings, under any circumstances. Certainly this is a hazard we should not permit.

(Log #CC11) 58- 41 - (Table 3-2.2.2, Note (d)): Accept SUBMITTER: Technical Committee on Liquefied Petroleum Gases COMMENT ON PROPOSAL NO: 58-44 RECOMMENDATION: Revise Note (d) to Table 3-2.2.2 to read:

Note (d): Minimum distances for mounded or underground containers of 2,001 to 30,000 gal water capacity incorporating ULET provisions and the optional requirement of Section 3-11, shall be permitted to he reduced to 10 ft. Distances for all underground and mounded containers shall be measured from the relief valve and filling connection, except that no part of an underground container shall be less than 10 ft from a building or

215

N F P A 58 - - F 9 7 R O C

line of adjoining proper ty that may be built upon and no part of a m o u n d e d container, installed above grade, shall be less than 5 ft f rom a building or line of adjoining property which may be built upon. SUBSTANTIATION: The proposed text is revised to delete the term FRCPM and to substitute reference to the new Section 3-11. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #14) 58- 42 - (3-2.2.8): Reject SUBMITTER: James H. Stannard, J r . , Stannard & Co. COMMENT ON PROPOSAL NO: 5848 RECOMMENDATION: Revise as follows:

3-2.2.8 I m p o u n d m e n t in accordance with Section 9-2 shall be installed a round refrigerated LP-gas containers and ~ o s e containin~ Butane and its isomers. SUBSTAI~TIATION: The Note accompanying 3-2.2.8 Clearly represents the behavior of propane. However, there would be little, if any, flash when butane is released to the a tmosphere - particularly during periods of low ambient temperature. Thus, in those areas of the country that are subject to the accumulat ion of snow cover, a butane spill dur ing the winter months would behave as a f lammable liquid spill that could spread over the g round if no t impeded. On the o ther hand, the substantial tempera ture difference between the g round and liquid p ropane would assure its early evaporation.

Butane is dear ly on the edge of the behavior def ined for liquefied gases. In fact, butane in the winter will behave much the way that pen tane will behave in the summer and pen tane is considered as a Class I liquid in NFPA 30 and as such requires containment . The present r equ i rement for the conta inment of butane and its isomers came about as a compromise with the API when NFPA 58 p reempted API 2510 for Marine terminals.

It is my belief that the delet ion of this requ i rement will be perceived as a denigrat ion of safety by the Committee. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The commit tee has no evidence that this will improve safety, and does no t believe that a p rob lem exists with butane tanks. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 24 NEGATIVE: 3 NOT RETURNED: I Van Hook

EXPLANATION OF NEGATIVE: RENFREW: I agree completely with Mr. Ritzmann and Mr.

Stannard: RITZMANN: I believe safety is compromised by no t requiring

dikin, g a round Butane tanks. This requirement., was. removed madver tendy and should be restored unul mtentmnal ly removed by the committee.

STANNARD: As stated in my original Proposal, the elimination of the impounding requ i rement for butane will denigrate safety and will compromise the credibility of the entire document .

(Log #37) 58- 43 - (3-2.2.10): Accept SUBMITTER: Bruce Swiecicki, Nat'l Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-47 RECOMMENDATION: Comment : Reverse the commit tee action and delete Section 3-2.2.10. SUBSTANTIATION: Substantiation: The committee 's solution is r edundan t to Proposal 58-43, which moves Note (b)2. of Table 3- 2.2.2 to the text in Section 3-2.2.2(d). COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #56) 58- 44 - (Table 3-2.3.3): Accept SUBMITTER~ Bruce Swiecicki, Nat'l P ropane Gas Assn. COMMENT ON PROPOSAL NO: 58-50 RECOMMENDATION: Revise new Part 11 to read: "Flammable and Class II combustible liquid containers, aboveground and underground." SUBSTANTIATION: The in tent is more clearly expressed in this manner . In addit ion, Ms. Lataille's commen t in the ROP can be addressed by recalling the sequence of actions taken by the Committee. Proposal 58-55 was acted on ~ to 58-50. Proposal 58-50 was the result o f a comment in tending to correlate Section 3- 9.4.3 with Table 3-2.2.30 COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #111) 58- 45 - (Table 3-2.3.3 and 4-2.3.2(a)): Reject SUBMITTER: Edgar L. Martin, Jr., FL DACS, Bureau of LP Gas Insp. COMMENT ON PROPOSAL NO: 58-51 RECOMMENDATION: 4-2.3.2(a) would remain the same. Part 6 (a) of Table 3-2.3.3 would be changed to read 15 ft min imum horizontal distance. SUBSTANTIATION: 4-2.3.2(a) indicates that internal combustion engines within 15 ft of a point of transfer shall be shut down while such transfer operat ions are in progress, but Part 6 (a) o f Table 3-2.3.3 allows a vehicle to be on a public street or thoroughfare within 10 ft so there is a conflict and this is the reason for my proposed change. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The comment is identical to the proposal. No new information is provided for t he committee to reconsider its action. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMrFrEE ACTION:


(Log #113) 58- 46 - (Table 3-2.3.3 and 4-2.3.2(b)): Reject SUBMYrTER: Edgar L Martin, Jr., FL DAGS, Bureau of LP Gas lnsp. COMMENT ON PROPOSAL NO: 58-52 RECOMMENDATION: Revise text as follows:

4-2.3.2(b) would remain the same. Part 6(a) of Table 3-2.3.3 would be changed to read 25 ft m i n i mum horizontal distance.

Separate sidewalks into another heading as other public ways would only need 15 ft setback. SUBSTANTIATION: 4-2.3.2(b) indicates that smoking shall not be permit ted within 25 ft of a point of transfer, but Part 6(a) of Table 3-2.3.3 allows 10 ft f rom a public sidewalk and we cannot control smoking on a public sidewalk. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The commen t is identical to the proposal. No new information is provided for the committee to reconsider its action. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #48) 58- 47 - (3-2.4.1): Reject SUBMITYERa Wayne Wagner , Tennessee Fire Code Development Commit tee COMMENT ON PROPOSAL NO: 58-56 RECOMMENDATION: Revise text:

3-2.4.1(c) To minimize the possibility of damage to systems or DOT or ASME container(s) installed in any location exposed to vehicular traffic, such as in or near parking lots, entrances to driveways, streets or construction sites, the systems and containers shall be protected fi 'om ~ motorized ~ and other motorized equ ipment including but no t l imited t cranes, fork lift operations

2 1 6

N F P A 5 8 ~ F 9 7 R O C

a n d o ther c o m m o n hazards by m e a n s of one or m o r e of the following:

(1) noncombus t ib l e per iphera l fence, gua rd r a i l /pos t o f meta l or concrete , bui ld ing walls, or na tura l or m a n m a d e barr iers enclos ing conta iners a n d piping.

T h e p resence of such pro tec t ion f rom d a m a g e shall n o t create s ignif icant hazards such as pocket ing of LP-Gas, in te r fe rence with appl icat ion of cool ing water by fire depar tments , redi rect ion of t lames against conta iners a n d i m p e d i n g egress o f pe r sonne l in and emergency. S U B S T A N T I A T I O N : T h e TN Fire Code Deve lopmen t Gommit tee feel t he t e rm Motor ized Vehicle or E q u i p m e n t is suff icient and can be d e t e r m i n e d by any compe t en t AHJ. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The commit tee believes tha t the pro tec t ion f rom vehicle impac t is d e p e n d e n t on the weight and speed of the vehicle a n d topography. T h e c o m m e n t does n o t address this impor t an t issue. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 V O T E ON COMMFTTEE ACTION:


EXPLANATION OF NI:;GATIVE: RENFREW: T h e Commi t t e e shou l d recons ider this c o m m e n t in

suppor t of Proposal 58-56 in the Repor t on Proposals. The cur ren t wording in this sect ion is vague a n d unenforceable . (c~ Where physical damage to LP-Gas containers , or svstems of which they are a Dart. f rom vehicles is a oossibilitv, n recau t ions shall be taken a~ainst such damage . Wha t ' a r e vehicles - does tha t inc lude "other motor ized equij~ment inc luding bu t no t l imited to cranes, for life opera t ions ". w h a t is precaut ions taken. Because of a cour t case in Connec t icu t which declared the cu r r en t wording vague and unenforceab le this sect ion is be ing revised at a state level.

(Log #18) 58- 48 - (3-2.5): Accept in Principle in Par t SUBMITTER: J ames H. Stannard, Jr . , S tannard & Co. COMMENT ON PROPOSAL NO: 58-61 RECOMMENDATION: Revise 58-61 as shown: 3-2.5 Installat ion of conta iners on roofs or terraces of buildings. /rr ' l ~ . . ; I A | ~ m . . . . l . , , : . . . . . : ' . k " T ' . - - ^ T , t . l c / ~ _ ~ t ~ t o - - - , q r ' . _ ^ i I o o o

cc.r~'_-~c*-"vr., ASM~ conta iners shall be permi t ted to be installed, filled a n d used 911 the roofs or terraces o f b u i l d i n ~ with the approval of the author i ty having jur isdic t ion in locations where p iped fuel gas is n o t available ~nd where there is no adjacent l and available for the installation of e i ther bur ied or a b o v e ~ o u n d ggnta iners with the following condit ions: 3-2.5.1 The bui ld ing shall be of steel or re inforced masonrv construct ion, shall be essentially f i revroof and the roof s t ructure shall be des ianed an cons t ruc ted to laave sufficient s t rength to ~ p p o r ~ the conta iner filled with water. 3-2.5.2 The occunancv of the building, shall be l imited to the classifications (as 'snecif ied in the LifeSafe tv Code NFPA 101~ of Residential. Business. Industrial . or Storage. 3-2.5.3 ~ ~ or two-family dwelline, the bui ld ing shall be complete ly sprinklerecl, 3-2.5.4 N e ~ b 7 ;;=!l~ ~p t c a ?2~'~ucc c.f ~ r...ctcr~ ( I0 ft), m"~t 5c cc~zztructcd ~f ~cncs:..~'~'z*-hlc : . .v.tcH'~. located uoon a terrace or oaraDet, the conta iner shall be located at least 10 f t ' (3 ril s) f rom the wall o f the uppe r floors and shall be at l¢~ast 25 ft (8 m) measu red horizontal ly to the side o f any window. balcony or door that is located on my wall l a t in E or above the t,~rrace or naraoet . 3-2.5.5 The conta iner shall be secured to the structural m e m b e r s of the bui ldin~ to nrevent shif t ing or over turning of the container d~lrinE i~ seismic event. "]'he suppor t s t ructure of the conta iner shall be desKmed to the same seismic criteria as the bui ldin~ and t.be desltrn shall consider s loshin~ of the contents and shall be

v

checked for bo th full and empty condit ions. 3-2.5.6 (Extracted f rom NFPA 59A 4-1.3.8) Shop-buil t conta iners des igned a n d cons t ruc ted in accordance with the ASME Boiler and Pressure Vessel Code, and thei r s u p p o r t systems, shall be des igned for the dynamic forces associated with horizontal a n d vertical accelera t ions as follows:

(a) Horizontal force V = Z~ (W) where:

Z~ = the seismic coefficient f rom Table 3-2.5.fi W = the total weight of the conta iner a n d its contents.

(b) Design vertical force P = 2 / 3 c (W)

* T h e seismic coefficient shall be permi t ted to be calculated in accordance with the nonbu i i d ing s t ructures provisions of the U n i f o r m Bui lding Code, us ing an Impor tance Factor I o f 1.25. The m i n i m u m coefficient f rom Table 4-1.3.8 shall be used if the natura l per iod of vibration, T, is less than .3 seconds.

Table 3-2.5.6 Zone Coefficient Z c Seismic Coefficient for Shop-Buil t Conta iners

Effective Peak 1 0.09 Horizontal Accelerat ion EPA - %G

7.5 2A 0.17 15.0 2B 0.23 20.0 3 0.34 30.0

4 0.44 40.0

NOTE 1: Source: Un i fo rm Building Code seismic zone map. NOTE 2: T h e EPA (%G) is equivalent to the seismic zones and can be used to de t e rmineZ¢ in areas where seismic zones are no t available.

3-2.5.7 The conta iner and its suppor t s shall be 0es igned for the r~sul tant seismic forces in combina t ion with th~ Opcratin~ loads, us in~ the allowable stresses increase shown in the code or s t andar0 used-to desima the conta iner or its support#, 3-2.5.8 Conta iners shall be installed in external locations only, with ample natural ventilating. 3-2.5.9 All conta iner connect ions, except relief valve a n d fixed m a x i m u m liuuid level gau~es, in addi t ion to manua l valves located as close as practical to the conta iner nene t ra t ion , shall be euuioDed xvith internal valves with excess flow. thermal , a n d local

° - -

a n d remote actuation. One of the remote actuator stations shall be at the no in t of access to the roof. one o ther no in t o f actuat ion shall I~$ nea r g r o u n d level and readily available i~t the poin~ of connec t ion a n d t ransfer d u r i n g l o a d i n ~ operat ions. 3-2.5.10 The fill connec t ion o f the conta iner shall be eouiDoed with a n au tomat ic stomfiil device tha t shall l imit the conta iner fill vo lume to 85 %. Tha t stop-fill device shall provi0¢ ~ llneans Of bY- pass to he rmi t the expans ion of the l iauid in the filling transfer v

3-2.5.11 A AgME- conta iner installed on the roof of a bui lding shall always be filled by two operators, one a t the controls of the vehicle supplying LPG, and ano the r at the controls o f the tank. 3-2.5.12 Gontainers shall be installed on a reasonably level location.

2.5.5 The r c c f c.n -;'.Wck ".~hc ccn'..92ner ": !cc.~tcd, ~hr_2! bc aSlc to

3-2.~..13 Containers on roofs s~all no t be located closer t h a n 10 ft f rom any vent, stairway or elevator shaft or o ther open ing into the building. 3-2.5.14 Locat ion shall permi t the easy access to all valves an d controls, a n d m u s t have provide e n o u g h area to pe rmi t the requ i red ma in tenance . 3-2.5.15 the Location of the conta iner shall have f ixed stairs or o ther safe m e t h o d to read it. 3-2.5.16 If the installation requires the use of more than one container , the dis tances o f Table 3-2.2.2 shall apply. 3-2.5.17 If the location is h igher than 7 meters f rom the floor-street level, or the filling hose can be observed by the operators in its entire length, the conta iner shall have a pe rmanen t ly installe0 filling line cons t ruc ted to withstand liquid transfer, and shall have the following appur tenances :

Filling valve, cap, two control valves, hyrdrostatic relief, vent ing line with control valve. 3-2.5.18 The liquid filling line shall be pa in ted in r ed for at least 6 in. (0.15 m) at the t ransfer point , a n d at the container. 3-2.5.19 If a vapor r e tu rn l ine is installed, it shall be pa in ted yellow. SUBSTANTIATION: The installat ion of LP-Gas Conta iners on the roofs of bui ldings presents some significant potential hazards. W h e n such an instaI lauon proves to be necessary, the safety related. r equ i r emen t s shou ld be sufficiently s t r ingent to assure the h ighes t possible level of safety. COMMITTEE ACTION: Accept in Principle in Part.

] Add a new 3-2.5.5 to read:

2 1 7

N F P A 58 - - F 9 7 R O C

3-2.5.5 The conta iner shall be secured to the bui ld ing structure. I The suppor t of the conta iner shall be des igned to the same seismic criteria as the building,

2. Revise 3-2.5.10 to read: 3-2.5.10 If t h e ~ location is h igher t han 7 meters f rom

gLg.lL~floor- level, or the filling hose can no t be observed... Filling valve, cap, two control valves, hydrostat ic relief, ven t ing

line with control valve. The l iquid a n d vapor fill connec t ions shall be conspicuously

marked or labeled. COMMITTEE STATEMENT: Refer to Commi t tee Action on c o m m e n t s 58-57 (Log #CC6) and 58-49 (Log #38). T h e p roposed 3-2.5.6 is n o t accepted because it is applicable to the des ign o f LNG tanks which have an i nne r and outer tank. It is no t

ble to p r o p a n e tanks. R OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28

VOTE ON COMMITTEE ACTION: AFFIRMATIVE: 20 NEGATIVE: 5 ABSTENTION: 2 N O T RETURNED: 1 Van Hook

EXPLANATION OF NEGATIVE: LAMAR: See my Explanat ion o f Negative on C o m m e n t 58-2 (Log

#CC7). LATAILI~: LP-Gas conta iners on roofs expose m u c h m o r e of a

bui ld ing to gas leaks t han conta iners at g r o u n d level. They also expose m o r e of a bui ld ing to fire shou l d a leak be ignited, a n d they would cause more damage shou ld the gas explode. Fu r the rmore , r e s p o n d i n g to LP-Gas p rob lems on a roof is slower, m o r e difficult a n d m o r e dange rous than on the g round .

LP-Gas conta iners on roofs can also be exposed to fires in ad jacent buildings, in the bui ld ings on which they are installed a n d in o ther e q u i p m e n t on the roof, like cooling towers, fans, elevator e q u i p m e n t rooms a n d m e c h a n i c a l p e n t h o u s e s . Even if an installat ion is no t initially exposed by any o ther equ ipmen t , the s tandard would no t prevent instal l ing new e q u i p m e n t later.

Meet ing every r e q u i r e m e n t now proposed in the s tandard will no t necessari ly assure t ha t a roof top LP-Gas installat ion is safe. Making such an instal lat ion safe also requi res a risk analysis specific to the facility. Keep ing the instal lat ion safe requires in tegra t ing the LP-Gas installat ion into the facilities' p rog rams for preventive ma in t enance and m a n a g e m e n t of change. Because a s t andard like NFPA 58 canno t possibly specify all tha t would be needed , it shou ld no t pe rmi t these installations.

RENFREW: See my Explanat ion o f Negative on C o m m e n t 58-57 (Log #CCt) .

STANNARD: I received, today, the "Circulat ion of Ballot Results for NFPA 58 F97 ROC. Inc luded in tha t mai l ing was an explanat ion of the new Section 5-2.5. W h e n I originally reviewed the all too complex ballot, I h a d come to the conclus ion tha t m u c h m o r e of the ROP 58-61 and my al ternate proposal had been retained. Even now, I a m unable to dupl icate s taf fs version in the Ballot Circulat ion D o c u m e n t f r om the record f o u n d in the ballot.

I a m convinced tha t m a n y o ther Commi t t ee m e m b e r s are unsu re of the language tha t they voted for or against. 1 believe that m a n y safety features tha t were incorpora ted in the two original proposals have been lost and approval of the version p r e p a r e d b y staff will

en the f lood gates to far too m a n y such installations in the Red States. I agree tha t there may be an occasional n e e d for

such installations, bu t the r equ i r emen t s shou ld be so onerous tha t few installations will ever be a t tempted . Fu r the rmore , those stiff r equ i r emen t s shou ld be spel led ou t a n d no t left to the imagina t ion of some author i ty having jur i sd ic t ion with little or no unde r s t and ing of the in ten t of the Commit tee .

Finally, I would add tha t the m e t h o d of p resen t ing such an a rgumenta t ive proposal will only open the door to a p ro longed floor f ight at Kansas City. Such a floor f ight will only lead to a genera l loss of conf idence in the Commi t t ee a n d the documen t .

I can only r e c o m m e n d tha t this issue be resubmi t ted to the entire Commi t t ee a n d tha t 58-48 and 58-49 be rebal loted on the basis of a single a n d comple te v e r s i o n of the p roposed Section 3-2.5.

ZEPP: Reject commi t tee act ion and reject addi t ion of p roposed original pa r ag raph 5-2.5 and p r o p o s e d modif ica t ion thereto. COMMENT O N AFFIRMATIVE:

MAXON: The #2 Commi t tee Action text is believed to refer to the ROP 58-61, 3-2.5.17, no t 3-2.5.10 as indicated:

The new 3-2.5.17 would read: 302.5.17 If the c o n ~ n e r location is h i ghe r t han 7 meters f rom

the gr_0__U_l~ ~ r ~'~eet level, or the filling hose can ~ be observed by the opera tors in its ent i re length, the con ta ine r shall have a p e r m a n e n d y installed filling line cons t ruc ted to wi ths tand l iquid transfer, and shall have the following appur tenances : Filling valve, cap, two control valves, hydrostat ic relief, vent ing line with

control valve. The l iouid a n d vanor fill connec t ions shall be consnicuouslv marked a n d labeled. EXPLANATION OF ABSTENTION:

PAKRUDA: I vote "Abstain" on the Commi t t ee Action for the following conta iner on roof top comments :

I recognize tha t in some cases the re is a valid n e e d to install containers on roof tops and tha t present ly the author i ty having

jur isdic t ion can make that exception. However, I feel tha t these type of installations in m o s t cases will cause a fire suppress ion p rob lem in the event of an accident .

VOLGSTADT: See my Explana t ion of Abs ten t ion on C o m m e n t 58-2 (Log #CC7).

(Log #38) 58- 49 - (3-2.5): Accept in Principle SUBMITTER: Bruce Swiecicki, Nat 'l P ropane Gas Assn. COMMENT ON PROPOSAL NO: 58-61 RECOMMENDATION: Revise text as follows:

3-2.5 Installation of conta iners on roofs or terraces of buildings. In bui ldings complying with Type I . . . . . . approval of the author i ty h a w n g j u n s d i c t a o n m ioca tmns . . . . . . . r - r . . . . . . t, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . • . . . . . . . . . . . m accordance w~th the orovisions of this section.

A p p e n d the following to Section 3 - 2 . 5 . 2 : The fill line to the conta iner m u s t be located entirely outside the buildinu. Th e fill connec t ion shall no t be accessible for t a m n e r i n u a n d shall be lgcated at least 8 ft ~bove groull(;t level.

Change Section 3-2.3.1(c) as follows: 3-2.3.2(c) The t ransfer of l iquid into conta iners on the roofs of

s t ructures shall b e prc.hlbitzd permit ted , provided that the installation conforms to the r eou i r emen t s conta ined in 3-2.5 and 3- 4.9.

Delete Section 3-4.2.6(a). SUBSTANTIATION: The existence or nonex i s tence of p iped gas is irrelevant to the safety of a specific installation. A restriction based on the availability of a specific fuel can consti tute a restraint of trade.

The change to require the fill line to be outside the bui lding is consis tent with cu r r en t r equ i r emen t s elsewhere in the s tandard.

The r e q u i r e m e n t for a m i n i m u m he igh t for the fill connec t ion is i n t ended to de ter tamper ing.

The chan~es to Sections 3-2.3.1(c) and 3-4.2.6)a) are necessary for correla t ion purposes . COMMITTEE ACTION: Accept in Principle.

1. Revise 3-2.5 to read: 3-2.5 Installation of conta iners on roofs of buildings. 3-2.5.1 With t h e p r i o r approval of the author i ty having

jur isdict ion, bui ldings complying with Type I, 443 or 332, or Type 11, 222 const ruct ion shall be permi t ted to have ASME containers installed, filled and used on roofs in accordance with the following.

2. Revise 3-2.5.2 by adding the following: Where a fill line to the conta iner is required, it shall be located

entirely outside the building. The fill connec t ion shall be located at least 8 f t above g r o u n d level.

3. Revise Section 3-2.3.1(c) as follows: 3-2:3.1(c) The t ransfer of l iquid into containers on the roofs of

s t ructures shall be permit ted , provided tha t the installation conforms to the r equ i r emen t s con ta ined in 3-2.5 a n d 3-4.9.

4. Delete Section 3-4.2.6(a). COMMITTEE STATEMENT: The proposal is accepted with editorial revisions. NUMBER OF COMMITTEE M ~ E R S ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 19 NEGATIVE: 6 ABSTENTION: 2 N O T RETURNED: 1 Van Hook

EXPLANATION OF NEGATIVE: LAMAI~ See my Explanat ion of Negative on C o m m e n t 58-2 (Log

#CC7). LATAILLE: See my Explanat ion o f Negative on C o m m e n t 58-48

(Log #18). MORTIMER: Allowing the installation of conta iners on roofs of

bui ldings does no th ing to advance or improve safety in any way. Cur ren t wording of 3-2.3.2 (see) shou ld be reta ined. Switching prohib i ted to permi t ted drastically changes this sect ion c o n t e n t

and does n o t h i n g to p romote or improve safety. RENFREW: See my Explanat ion of Negative on C o m m e n t 58-57

(Log #CC6).

2 1 8

N F P A 58 - - F 9 7 R O C

STANNARD: See my Explanation of Negative on Comment 58-48 (Log#18).

ZEPP: See my Explanation of Negative on Comment 58-48 (Log #18). EXPLANATION OF ABSTENTION:

PAKRUDA: See my Explanation of Abstention on Comment 58- 48 (Log #18).

VOLGSTADT: See my Explanation of Abstention on Comment 58-2 (Log #CC7).

(Log #50) 58- 50 - (3-2.5): Reject SUBMITTER: Ronald Jordan, U.S. Consumer Product Safety Commission COMMENT ON PROPOSAL NO: 58-61 RECOMMENDATION: Reject new Section 3-2.5, "Installation of containers on roofs or terraces of buildings" to NFPA 58 which was accepted in principle at the November 18, 1996 meeting of the National Fire Protection Association Technical Committee on Liquefied Petroleum Gases. This provision would allow installation of ASME-type LP-gas containers on the roofs or terraces of buildings of fireproof construction. SUBSTANTIATION: The staff of the Consumer Product Safety Commission opposes adoption of this provision into NFPA 58. An ASME LP-gas tank installed on a roof or terrace would pose the following hazards to occupants of the building;

1. If a leak occurs, LP-gas could possibly enter buildings with roof designs or conditions that include:

(a) parapet walls which could trap leaking LP-gas and funnel it into the building,

(b) openings, such as roof vents, elevator shafts, or opened windows, which could fimnel LP-gas into the building,

2. Section 2.5.8.2 of NFPA 58 requires installations to be equipped with pressure regulators with full-capacity relief valves, increasing the potential of a large amount of propane being released on the roof or terrace of a building,

3. Current specifications for minimum distances of tanks from buildings would be more likely to be ignored,

4. In the event of a fire, a tank located on the roof or terrace is a greater risk of being over-heated by flames below or adjacent to it.

Staff understands theprovision is intended to accommodate special installation needs in Mexico. Although theprovision is worded so that these installations would conflict with model and local building codes, and therefore would not be acceptable in the United States, there are many parts of this country where building codes are not adequately enforced. The position stated herein is that of the Commission staff. It has not been reviewed or

by the Commissioners. MITTEE ACTION: Reject.

COMMITTEE STATEMENT: Refer to Committee Statement on Comment 58-58 (Log #2). NUMBER OF COMMrVrEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 20 NEGATIVE: 5 ABSTENTION: 2 NOT RETURNED: 1 Van Hook

EXPLANATION OF NEGATIVE: LAMAR: See my Explanation of Negative on Comment 58-2 (Log

#CC7). LATAILLE: See my Explanation of Negative on Comment 58-48

(Log #18). MORTIMER: This comment should be approved as the

substantiation provided by Ronald Jordan is technically correct. RENFREW: See my Explanation of Negative on Comment 58-57

(Log #CC6). ZEPP: Reject committee action and accept original proposal.

EXPLANATION OF ABSTENTION: PAKRUDA: See my Explanation of Abstention on Comment 58-

48 (Log #18). VOLGSTADT: See my Explanation of Abstention on Comment

58-2 (Log #CC7).

(Log #io3) 58- 51 - (3-2.5): Reject SUBMITTEPa Leonard Pakruda, Liquefied Petroleum Gas Board COMMENT ON PROPOSAL NO: 58-61 RECOMMENDATION: I recognize that some cases there is a valid need to install all containers on rooftops but I feel this should be handled by special exception. SUBSTANTIATION: L~ontainers on rooftops give much more exposure to buildings because of gas leaks. Containers on roof's

could not allow for minimum distance requirement that have been establish by the NFPA 58. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The requirement that installation of containers on rooftops are subject to the approval of the Authority Having Jurisdiction is the same as a special exception. By having specific requirements in the code, guidance is provided to the Authority Having Jurisdiction. NUMBER OF COMMITITEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:




(Log #18). MORTIMER: Comment should be approved as substantiation

given is correct. RENFREW: See my Explanation of Negative on Comment 58-57




58-2 (Log #CC7).

(Log #110) 58- 52- (3-2.5): Reject SUBMITTER: Mike Israni, Office of Pipeline Safety/RSPA/DOT COMMENT ON PROPOSAL NO: 58-61 RECOMMENDATION: Proposed Section 3-2.5 should be rejected and authorities that adopt NFPA 58 should take their own exceptions. SUBSTANTIATION: LPG containers on rooftops presents more hazard. Code should not be weakened to make it acceptable in other countries. However, other countries could always adopt the "code" with some exceptions appropriate for their own countries. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Committee Statement on Comment 58-58 (Log #2). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:




(Log #18). MORTIMER: Comment should be approved as substantiation

given is correct. RENFREW: See my Explanation of Negative on Comment 58-57




58-2 (Log #CC7).

(Log #115) 58- 53- (3-2.5): Reject SUBMITTER: Paul Maldonado, Austin Fire Deparmlent COMMENT ON PROPOSAL NO: 58-61 RECOMMENDATION: Delete the new Section 3-2.5, Installation of Containers on roofs or terraces of buildings. SUBSTANTIATION: The proposal to allow the installation of stationary LP-Gas containers on the roof of buildings creates a new safety threat to firefighters and the occupants of buildings. It also violates NFPA 53, Section 3-2.3.1(c). This section states:

The transfer of liquid into containers on the roof of structures shall be prohibited. Lemhoff states in the LP-Gas Handbook. 4th edidon that. This prohibition prevents the permanent installation of containers on the roof of buildings. This option is not needed in the United States of Canada as densely populated cities does not

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N F P A 5 8 - - F 9 7 R O C

use LP-Gas as a residential fuel. In o ther parts of the worlds it is a common practice to locate containers on the roofs of buildings. If an LP-Gas container must be located on a roof, it must be refilled by exchange with a full cylinder.

The committee 's approval o f this proposal is a direct conflict with a existing requ i rement of the standard and increases the risk of fire and explosion to the public and firefighters based on the s ta tement published in the The Handbook is correct in that the availability of o ther forms of energy does no t require or warrant the committee 's approval of a proposal that would allow the installation of stationary LP-Gas containers on the roofs of buildings.

The proposed requi rements contain a number of flaws and assumptions which jeopardize the safety of the public and firefighters in densely popula ted urban areas, including

1.. Many planning and land use codes require building utilities, air handl ing equ ipment and other equ ipmen t installed on building roofs to be screened or otherwise h idden f rom the public's view. These screen walls are constructed for aesthetic purposes. While such a screen would conflict with Section 3-2.2.9, Exception No. 1 may result in their construction. The Standard clearly states in a note the this section that:

The presence of such structures can create significant hazards, e.g., pocket ing of escaping gas, in terference with application of cooling waters by fire depar tments , redirect ion of flames against containers, and impeding egress of personnel in an emergency.

The committee 's decision to allow the installation of stationary container containers on roofs will no doubt result in the construction of screen walls or o ther obstructions which will increase the threat of injury to firefighters, especiaUy if such a screen wall is constructed without the AHJ's approval.

2. The National Propane Gas Association publishes the document , Guidelines for Conduct ing a Fire Safety Anal~is. Section 3.3 states:

Experience reveals ra ther exclusively that a container is in danger of aBLEVE after about 10 minutes of intense flame impingement on the unwetted por t ion of the shel l This time span will often coincide ra ther closely with the t ime it takes fire depar tments to get streams into operation. The instant the inidal stream of water contacts the container is usually the most dangerous m o m e n t in the entire operation.

This particular sect ion was written assuming that a container is installed at grade level, where it can be accessed within a reasonable time per iod by the Fire Department . The committee 's decision to allow the installation of stationary ASME containers on the roo f of buildings d id no t include a limitation on the building's he ight or fire protect ion features. This provision now allows the installation of a 1,000 gallon w.c. LP-Gas container on the roof of a nonspr inklered 35-story high-rise building. Considering the time of Fire Depar tment notification, it is no t u n c o m m o n that to dispatch, respond, deploy and place attack streams in operat ion on the roof of a high-rise structure can take 10-20 minutes. This response time requires an immediate fire depa r tmen t notification a n d t h e set-up times are heavily inf luenced by the engine company's staffing, the number of apparatus dispatched on the 1st alarm and the design of the s tandpipe system. Based on the statements publ ished by the National Propane Gas Association, this proposal basically sets up firefighters with a losing situation where their safety will be seriously compromised, possibly to the point of death or injury..

3. The use of two employees to perform the filling operation offers very little safety to the filling operation. The time it any take the 1st operator to notify the 2nd operator to stop the transfer of liquid could be of a sufficient durat ion to result in the overfilling of the container.

4. These provisions do no t address the methods a LP-Gas supplier would employ to remove the liquid f rom the container installed on the roof of a building using the liquid withdrawal valve specified in Section 2-2.3.3.

5. The separation distances specified in Section 3-2.5.6 of the proposal do no t include separation f rom sources of ignition. The proposal approved by the Commit tee would permit the installation of a stationary LP-Gas container adjacent to a air condi t ioner chiller plant with electrical equ ipment which does not mee t the classified electrical location requirements in the N a t i o n ~ Electrical Code.

The Austin Fire Depar tment has exper ienced a number of multi- family dwelling fires where LP_Gas containers were s tored n violation of Section 3-4.9.2. In one incident, a BLEVE of a 20 pound container accelerated the fire's growth so rapidly that it ex tended into an adjacent apar tment building. This proposal now requires firefighters to contemplate BLEVEs fi-om stationary containers installed on building roofs. Such a BLEVE can create

overpressures that will collapse a building and turn a building fire into the scene of a catastrophic building failure. The NFPA 58 committee should consider the points presented and reverse its approval of this proposal. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Committee Statement on C ommen t 58-58 (Log #2). In addition, approval by the Authority Having Jurisdict ion provides for local conditions, such as screen walls that do n o t p e r m i t dispersion of vapors.

With regard to the safety provided by two operators, note that a shutoff valve is required at the roof level so that the operator at the roof can shut o f f t h e flow of gas when needed. N U M B E R OF C O M M I T T E E M E M B E R S ELIGIBLE T O VOTE: 28 V O T E O N COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: I_AMAR: See my Explanation of Negative on Comment 58-2 (Log


(Log #18). MORTIMER: C ommen t should be approved, I agree with

substantiation given by Paul Maldonado. RENFREW: See my Explanation of Negative on Comment 58-57

(Log #CC6). ZEPP: Reject commit tee act ion and accept original proposal.

• EXPLANATION OF ABSTENTION: PAKRUDA: See my Explanation of Abstention on Comment 58-

48 (Log #18). VOLGSTADT: See my Explanation of Abstent ion on Comment

58-2 (Log #CC7).

(Log #125) 58- 54- (3-2.5): Reject S U B M r r r E R : J o h n K. Gillette, Ill, Denton, TX, Fire Dept. CO MMENT ON PROPOSAL NO: 58-61 RECOMMENDATION: Delete Section. S U B S T A N T I A T I O N : The proposed addit ion is creating a dangerous environment. Several problems include fire suppressions tactics, fuel ing transfer, p roduc t piping in and a round buildings, building fire resistivity, and fire suppression. When a fire occurs involving the tank, fire resistivity buys time for fire suppression at a facility. Water supplies and fire depar t lnent access to multi-level structures are critical to fire depar tment access to multi-level structures are critical to fire suppression Pdersonnel. Most roofs have no water supplies and currently

angerous for fire depar tment personnel without LP Gas tanks installed. Manual fire ext inguishment is need to suppress roof fires.

In addition, existing facilities will no t be brought up to fire codes for building fire suppression and fire resistivity purposes for a new tank installation. Roofs have very little fire resistivity and usually no water supplies. Where these tanks are to be installed, building

~ rotection must b e p r o v i d e d to prevent extension of the fire eneath and a r o u n d a r e a to the tank. Single family dwellings are

still dangerous because of the lack of protect ion to be installed beneath the tank and fire extension in the attic creating multiple hazards. We oppose these dangerous changes to N.F.P.A. 58. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Committee Statement on Comment 58-58 (Log #2). N U M B E R OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 28 VO TE O N COMMITTEE ACTIO N:


EXPLANATION OF NEGATIVE: I.AMAR: See my Explanation of Negative on Comment 58-2 (Log

# c c 7 ) . LATAILLE: See my Explanation of Negative on Comment 58-48

(Log #18). MORTIMER: C ommen t should be approved, refer to

substantiation given for C ommen t 58-49. RENFREW: See my Explanation of Negative on Comment 58-57

(Log #CC6). ZEPP: Reject commit tee action and accept original proposal.

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N F P A 58 m F 9 7 R O C



58-2 (Log #CC7).

(Log #126) 58- 55 - (3-2.5): Reject SUBMITTER: Chappell D. Pierce, OSHA COMMENT ON PROPOSAL NO: 58-61 RECOMMENDATION: Reject Proposed New Section 3-2.5

Reject proposal which would allow the installation and filling of LP-gas containers (with no specified quantity limit) on roofs of buildings. SUBSTANTIATION: NFPA 58 already contains provisions which addresses LP-gas containers on the roofs of buildings. Section 3- 2.3.1c prohibits the transfer of liquid LP-gas into containers on roofs. We believe the proposal would weaken NFPA 58 by allowing practices that could result in serious hazards, particularly since LP-gas is, of course, heavier than air. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Committee Action on Comment 58-58 (Log #2). The concern over unlimited container size is addressed in Comment 58-57 (Log #CC6). NUMBER OF COMMITFEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:




(Log #18). RENFREW: See my Explanation of Negative on Comment 58-57

(Log #CC6). EXPLANATION OF ABSTENTION:


VOLGSTADT: See my' Explanation of Abstention on Comment 58-2 (Log #CC7) o

(Log #127) 58- 56- (3-2.5): Reject SUBMITTER: Kim R. Mniszewski, Varley-Campbell & Assoc. COMMENT ON PROPOSAL NO: 58-61 RECOMMENDATION: Delete the proposed text. SUBSTANTIATION: The proposed action to allow LPG containers on roof or terraces of buildings will be a serious weakening in fire safety;, many new fire/explosion scenarios will be introduced by this due to the probable, (1) exposure of those tanks to fire, and (2) probable downward leakage of gas from such tanks into buildings. COMMrFrEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Committee Statement on Comment 58-58 (Log #2). _ _ _ _ NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:




(Log#18). MORTIMER: Comment should be approved, refer to

substantiation given for Comment 58-49. RENFREW: See my Explanation of Negative on Comment 58-57




(Log #CC6) 58- 57- (3-2.5): Accept SUBMITTER: Technical Committee on Liquefied Petroleum Gases COMMENT ON PROPOSAL NO: 58-61 RECOMMENDATION: 1. Add a new 3-2.5.1 to read:

3-2.5.1 LP-Gas containers installed on roofs or terraces shall be 2000 gallons water capacity or less. The aggregate water capacity of LP-Gas tanks installedon the roof or terrace of one building shall not exceed 4000 gallons. Exception: Additional installations shall be permitted where located 50 ft apart.

2. Revise 3-2.5.6 to read: 3-9.5.6 Containers shall be located in areas where there is free air

circulation, at least 10 ft (3.0 m) from building openings (such as windows and doors), and at least 20 ft (6.1 m) from air intakes of air conditioning and ventilating systems.

3. Add a new 3-2.5.2 to read: 3-2.5.2 The fire department shall be advised of each installation

of propane tanks on a roof. SUBSTANTIATION: The committee recognizes an omission of a maximum container size for rooftop installation. The revisions to 3-2.5.6 make this consistent with 3-4.9.1 (b).

Notification of the fire department is mandated. COMMITTEE ACTION: Accept. NUMBER OF COMMI'[TEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:




( ~ 1 ' ~ : I can ~ " " ~ not support this Proposal to allow such large size containers on the roofs of buildings. Currently, Section 3-4.9.1 permits smaller portable containers on roofs. If larger size containers are needed, then Section 1-1.4 can be used for these type installations. I recently traveled with the Committee in Mexico and saw hundreds of theproposed type installations and the methods and procedures usedto fill these larger containers on roofs several floors above ground level. Based on my observations and discussions, containers on roof is a normal or typical installation method in Mexico. It has to be needed because of a lack of other fuels being available such as natural gas in both dense population areas and in remote locations. Mexico is a very warm climate and these containers are used primarily to store fuel for cooking. I have been assured that the safety record in Mexico regarding these installations is excellent. A rejection of this proposal can not be based on these installations being unsafe given the sheer number of installations. But there are safer generally accepted methods of installation already in the standard. Adding this provision to the standard will increase these type installations whereas it should only be considered as an alternate to the existing methods already outlined in the standard. NFPA 58 is a nationally and internationally accepted standard for LP-Gas installations and throughout the world countries handle installations differently. The Committee is trying to develop more international use of this standard and incorporate general practices in countries other than the United States. I support that idea but feel thisproposal is premature at this time and the committee shouldei ther (1) promote the existing requirements internationally or (2) study several other countries and uses and prepare a report. If anything, this proposal should be an alternate to generally accepted BEST methods of installing containers. I also agree with many of the comments by Mr. Lamar in Comment 58-57a (Log #23).

ZEPP: Reject committee action and reject addition of proposed Paragraph 3-2.5.1, 3-2.5.6 and 3-2.5.2. EXPLANATION OF ABSTENTION:



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(Log #23) 58- 57a- (3-2.5): Reject 5UBM1TTER: Charles C. Lamar, Lamar Consultants, Inc COMMENT ON PROPOSAL NO: 58-61 RECOMMENDATION: Reject Proposal which provides for installation and filling of LP-gas containers of unl imited capacity on roofs of buildings of any type occupancy. This Proposal would accommodate the Mexican LP-ffas industry practices where such installations are widespread.

Instead, r e c o m m e n d that Mexican code adopt NFPA 58 "as is" while stating its own exceptions (as is done by many states in U.S.) and taking responsibility for these exceptions. SUBSTANTIATION: This Proposal would seriously weaken NFPA 58 which stricdy prohibits transfer of liquid LP-gas into containers on roofs of structures, both in Section 3-2.3.1(c) and in Section 3-4.2.6(a) in the 1995 text and in equivalent sections in the 1979 text. This Proposal would allow unlimited amounts of LP-gas to be pumped, at pressures up to 250 prig, into containers on rooftops. This practice involves many serious hazards. (Note that 4 containers of 1,000 gallons each were observed on top of a 10- story roof of the Crown Plaza Hotel in Mexico City, not fastened securely, but simply sitting on concrete blocks in an earthquake- prone location with bot tom connect ions subject to fracture or breaking off completely in an earthquake. (These containers were manifolded together with bot tom connect ions for liquid and with vapor connections.)

Storage of large quantities of LPwas on the roof, and p..Emp_ilig liquid into it presents very serious hazards to building occupants and to fire-fighting personnel . A fire below or near such containers could cause a BLEVE (Boiling Liquid Expanding Vapor Explosion) with extremely serious consequences. This could be a TOWERING IHFERNO for hotel levels immediately adjacent in the Crown Plaza Hotel, extending upward 8 or 10 stories. (The Proposal does not require sprinkler protect ion of f lammable structures below the tanks.)

The Proposal does no t require notification of the fire depar tment , as required in Section 3-4.9.1(e) of NFPA 58-1995 and Section 3380(g) of 1972. These requirements allow not more than 120 gallons o f liquid lin a portable container, "permanently installed on the roof," with refillin~ nrohibitedl

v _

Section 3-4.9.1 also ~rohibits enclosure by parapets unless they are b reached for vennlation, and unless any openings into the building are above the level of the parapet. (There is no ment ion of parapets in p roposed Section 3-2.5, and no requ i rement to anchor the tanks securely in place.)

Proposed Section 3-2.5.6 allows containers on roofs to be located as close as 10 feet to "anyvent, stairway or elevator shaft or o ther open ing into the buildingl" The hazard of LP-gas vapor (more than 1.5 times as heavy as air) enter ing a building from above is extremely serious.

Beginning with the 1995 Edition, NFPA 58 requires two-stage pressure regulation for piped, fixed installation. The first stage regulator must now have integral overpressure relief, which was not required heretofore. Second stage regulators are now required to have integral high capacity overpressure relief devices with capacity to relieve enough gas to a tmosphere so that downstream pressure will no t exceed 2 psig with supply pressure of I0 psig w ~ the regulator seat disc removedl (See Section 2-5.8.2(a) o f NFPA 58-1995.) I)ebris in the piping system can block regulator valves open, (first stage or second stage or both) , causing excessive pressure and copious discharge of LP-gas.

Section 3-2.6.5 of NFPA 58-1995 reads: 3-2.6.5 "The poin t of discharge f rom the required pressure relief

device on regulating equ ipmen t installed outside of buildings in fixed piping systems shall be located no t less than 3 ft (1 m) horizontally away f rom any building open ing below the level of such d ischarge- the point of discharge shall also be located not less than 5 ft (1.5 m ) in any direction away f rom any source of ignition, openings into direct-vent (sealed combustion system) appliances, or mechanical ventilation air intakes."

Proposed Section 3-2.5 is silent about location of pressure relief devices, on tanks or on pressure regulators in relation to openings into building, so provisions of 3-2.6.5 would be expected to apply. This is far too dangerous for a roof top installation. Provisions of 3-2.6.5 were developed for ground-level installations, where a 1,000

~ allon tank and its first-stage regulator are requi red to be at least 5 ft away f rom the building. They were also developed when

rel ief devices were no t required on first-stage regulators, and when rel ief devices on final stage regulators had lower relieving capacity. Also, at g round level, it is more likely that persons wou ldno t i ce the odor of LP-gas leaking, and take corrective action, then would

be the case with a roof-top installation no t normally visited very often.

I have investigated numerous serious accidents, with severe burn injuries and some deaths, due to blockage of vents by ice, where seepage past the relief valve caused pressure to build up in the regulator bonne t (spring case), causing grossly excessive pressure downstream.

A very significant factor in the seepage or leakage is that the overpressure relief valve is v¢ry lightly spring loaded against the diaphragm surface which serves as a soft seat, but it is no t very soft, no t very thick and not perfectly smooth. More than 20 years ago the lower limit for start-to-discharge of such relief devices was 22" water column (the specified range for s-t-d was 200 percent to 300 percen t of nominal 11" w.c.). About 20 years ago a manufacturer asked for a change to 170 percent for the lower limit, and this was adopted, so that the min imum start-to-discharge pressure is now 18.7" water column.*

For a relief valve having a circular ridge of 3/4" d iameter (0.44 square inch area) this gives a seating force of 0.298 ib when the regulator is out of service. However, with ou t le tp ressure of 14" w.c. as provided in NFPA 58, this leaves only 4.7 w.c. or 0.17 Ib per square inch as the ne t seating pressure, and this means a seating force of 0.075 lb.l By comparison, automatic valves in gas appliance controls having seating forces of 0.5 lbs. or more, and most or all of them are or iented so as to close in the direction of gas flow. so that they seat more strongly with increasing pressure. The rubber-like seat in such automatic valves is also far softer and thicker and smoother than the d iaphragm material which serves as the seat in the relief devices of final stage LP-gas regulators. It is no wonder that these relief devices seep or leak substantially when debris lodges there.

Another problem developed in Texas a few years ago when pressure regulators designed with plastic cams were binding in hot weather so the regulators would not lock up, causing copious flow out the relief vents. So much gas was released that tanks were "bled dray" in a number of cases. On a roof-top installation, such relieving would present a serious hazard, even if caused by debris in the piping system.

In view of all these fac tors ,p roposed Section 3-2.5 should be rejected with the recommenda t ion to Mexican code authorities that they adopt NFPA 58 while stating their own e~:ceptions, many of which should be phased out as soon as feasible.

Please note that there was discussion of possibly including coverage of filling containers on roofs as an exception in NFPA 58

ecifically for use in Mexico and other Latin American countries. is was re jected by NFPA Standards Council because it would

allow a less safe provision for certain countries. Instead, the proposed Section 3-2.5 would be an exceotion for

our country, to be allowed only where g round area is insufficient for tanks with their spacings, and where "the local authority having jurisdiction" would approve. This is dangerousl Our country has many nice tropical islands along coasts and in rivers where gas is no t available by pipeline, and luxury buildings with ample parking would be desirable, and where local authorities could be persuaded to approvel JUST SAY NOI

P.S. Please note that in Mexico, ranch buildings (with plenty of g round level area for LP-gas tanks) often have large LP-gas tanks on their roofs- probably to prevent tamper ing or pilferingl

P.P.S When fire engulfs containers of LP-gas, persons at ground level have a far bet ter chance of escaping injury or death than would persons in a multi-story building with LP-gas containers on the rood

* 1 lb per sq in. = 27.7 in. water column. COMMITI'EE ACTION: Reject. COMMITTEE STATEMENT: Refer to Commit tee Statement on C ommen t 58-2 (Log #58) and Commit tee C ommen t 58-57 (Log #CO0). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFHRMATIVE: 23 NEGATIVE: 3 ABSTENTION: 1 NOT RETURNED: 1 Van Hook

EXPLANATION OF NEGATIVE: LATAILLE: See my Explanation of Negative on Commen t 58-48

(Log #18). My first ballot d idn ' t have this item, so I d id no t enter a vote on the earlier ballot.

MORTIMER: C ommen t should be rejected, placing LP gas containers on roofs does noth ing to improve or increase safety.

RENFREW: See my Explanation of Ne-gative on Comment 58-57 (Log #CC6).

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N F P A 58 w F 9 7 R O C

EXPLANATION OF ABSTENTION: VOLGSTADT: See my Explanation of Abstention on Comment

58-2 (Log #CC7).

(Log #2) 58- 58 - (3.2.5 (New)): Reject SUBMITTER: Northeast Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: 58-61 RECOMMENDATION: The committee should reject this proposal and return to the original language already in the code. SUBSTANTIATION: The restriction of this section being allowed only when piped fuel gas is not available is not appropriate and indefensible. NFPA 58 should address the safe installation of these containers. The limitation of 10' from any opening doesn't make sense when product is leaking from a tank on the roof it will seek the lowest point. Fire exposure to a propane container on the ground is a challenge fi)r any fire suppression force, this challenge will be greater when these containers are on a roof, as well as, the exposure of the container to a fire in the building itself. We agree with the negative comments of the committee members.

The enforcement of some of the requirements such as structural requirements is not within most fire enforcement authority. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The committee appreciates the concerns of fire officials over this.

The committee has received reports of experience of rooftop installations from countries where it has been permitted. In Mexico it has been reported that there is 55 years experience with rooftop tanks due to the lack of space at ground level. In Mexico City the Central de Fugas (Propane leakage emergency response service) reports that there have been no BLEVE's. Also, it is reported that in the earthquake of 1985 there were no fires cause by propane rooftop installations.

The construction in Mexico is essentially non-combustible and the proposed new text in NFPA 58 limits rooftop installation to Type I and II buildings, which are essentially non-combustible types of construction with specific fire resistance ratings of building structural members.

Other comments have noted that propane vapor is heavier than air and that this presents a danger for rooftop installations. Propane disperses readily, as do all gases. The movement of propane vapor can be influenced by such factors as air currents, relative temperatures and air velocity. Propane vapor should be treated with the same caution as is applied to other flammable gases.

The committee recognizes the sensitivity to significant change, and has made the application of this new provision subject to the authority havlng jurisdicxion. NUMBER OF COMMrlYrEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMrIWEE ACTION:




(Log #18). MORTIMER: Comment should be approved, substantiation is

technically correct. RENFREW: See my Explanation of Negative on Comment 58-57



(Log #8) 58- 59 - (3-2.5 (New)): Reject SUBMITrER: Southeast Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: 58-161 RECOMMENDATION: The Committee should reject this proposal and return to the original language already in the code. SUBSTANTIATION: The restriction of this section being allowed only when piped fuel gas is not available is not appropriate and indefensible. NFPA 58 should address the safe installation of these containers. The limitation of 10' from any opening doesn't make sense when product is leaking from a tank on the roof it will seek the lowest point. No roof is gas tight, nonconventional openings are potenffal openings for gas entry into the building. . Fire exposure to a propane container on the ground is a challenge for

any fire suppression force, this challenge will be greater when these containers are on a roof, as well as, the exposure of the container to a fire in the building itself.

We agree with the negative comments of the committee members. The enforcement of some of the requirements such as structural requirements is not within most fire enforcement authority.

This new text would allow containers over the 400 lb limits established in Section 3-4.9 of NFPA 58. There would be no limit in the size of the container allowed in the proposed wording and would conflict with Section 3-4.9. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Committee Statement on Comment 58-58 (Log #2). Section 3-4 applies only to cylinders. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


FY~LANATION OF NEGATIVE: LAMAR: See my Explanation of Negative on Corrmlent 58-2 (Log

#cc7). LATAILLE: See my Explanation of Negative on Comment 58-48

(Log#18). MORTIMER: Comment should be approved, refer to


(Log #CC6).

(Log #25) 58- 60 - (3.2.5 (New)): Reject SUBMITT]~R: J o h n Gedervall, Deerfield, IL COMMENT ON PROPOSAL NO: 58-61 RECOMMENDATION: Delete proposed new 3.2.5. Installation of containers on Roofs or Terraces of buildings. SUBSTANTIATION: Problems and substantiation same as submitted by Charles C. Lamar, comments dated 3/20/97. COMMITrEE ACTION: Reject. COMMITrEE STATEMENT.. Refer to Committee Statement Comment 58-58 (Log #2). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:




(Log #18). MORTIMER: Comment should be approved, refer to


(Log #CCt).

(Log #31) 58- 61 - (3-2.5 (New)): Reject SUBMITrER: Gregory G. Victor, Glendale Fire Department COMMENT ON PROPOSAL NO: 58-61 RECOMMENDATION: Reject the Proposal. SUBSTANTIATION: The proposal is in conflict with other portions of the Standard [3.2.3.1(c)], the LPG Handbook, the practices of the propane industry in the U.S. and good common sense. The submitter provides no information in his substantiation regarding the fire history surrounding this type of installation. It is unacceptable to make a statement that "requires" the AHJ to allow this type of installation (3.2.5). Screening walls required by most zoning codes for roof mounted equipment will allow pocketing of LP Gas, an unsafe condition and one that is discussed in this Standard.

The threat of gas leaking into a building and the exposure to the containers to fire are greatly enhanced. This proposal puts the occupants of the building, the surrounding community and the responding firefighters at great risk. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Committee Statement on Comment 58-58 (Log #2). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


2"23

N F P A 58 - - F 9 7 R O C

EXPLANATION OF NEGATIVE: LAMAR: See my Explanat ion of Negative on C o m m e n t 58-2 (Log

#CC7). LATAILLE: See my Explanat ion o f Negative on C o m m e n t 58-48

(Log #18). MORTIMER: C o m m e n t shou ld be approved, refer to

substant ia t ion given for C o m m e n t 58-49. RENFREW: See my Explanat ion of Negative on C o m m e n t 58-57

(Log #CC6).

(Log #CC3) 58- 62 - (3-2.7(e)): Accept SUBMITTER: Technica l Commi t t ee on Liquef ied Pe t ro leum Gases C O M M E N T ON PROPOSAL NO: 58-31 RECOMMENDATION: Add a new 3-2.7 e) to read:

(e) Cor ruga ted stainless steel p ip ing systems shall be l imited to vapor service n o t exceeding 5 psi. S U B S T A N T I A T I O N : Paragraph 3-2.7 is revised to limit the use of cor ruga ted stainless steel tu[fing to vapor service up to 5 psi, the pressure l imit of t he material . COMMITI 'EE ACTION: Accept . NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON C O M M I T T E E ACTION:


(Log #CCA) 58- 63 - (3-2.8.8): Accept SUBMITTER: Technica l Commi t t ee on Liquef ied Pe t ro l eum Gases C O M M E N T ON PROPOSAL NO: 58457 RECOMMENDATION: Revise the p roposed 3-2.8.8 (c) to read:

(c) The factory-assembled riser shall be sealed a n d leak tested by the manufac tu re r . Field-assembled riser shall be suppl ied only in kit fo rm with all necessary hardware for installation. J ney shall be sealed and pressure tested by the installer. Field assembled riser kits shall be des ign certified. They shall be assembled a n d installed in accordance with the riser manufac tu re r s instruct ion. SUBSTANTIATION: T he pa ragraph is revised for darity. COMMITTEE ACTION: Accept . NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON C O M M I T T E E ACTION:


(Log #17) 58- 6 4 - (3-2.8.10): Accept in Principle SUBMITTER: J a m e s H. Stannard , J r . , S t annard & Co. C O M M E N T ON PROPOSAL NO: ~18-70 RECOMMENDATION: Add new text to read:

"A clearly identif ied a n d easily accessible manua l ly opera ted remote emergency shu tof f vfflve- ac tuator shall be located n o t less than 20 ft no r m o r e than 100 ft f rom the !cc.7.:2cn :c cq= '~Fcd. emer~encv shut-offvalve. It "~.g.:l! ~c l~.~..tc~ ":= "~.c a..aArzcS.?.r: e f

S U B S T A N T I A T I O N : Exper ience has shown tha t a r emote capability for ESD's would add significantly to the safety o f a facility. Fu r the rmore , it is impor tan t to specify what is "remote." COMMITI'EE ACTION: Accept in Principle.

[ Add a new 3-2.8.10 (3) (d) read: [ (d) All new installations, a n d by March 31, 1999 exist ing [ installations, shall have at least one clearly ident i f ied and easily [ accessible manua l ly opera ted r emote emergency shu tof f device. I The device shall be located n o t less t han 20 ft no r more t h a n 100 ft [ in the pa th of egress f rom the emergency shut-offvalve.

COMMITTEE STATEMENT: T he c o m m e n t is accepted with editorial revisions for clarity, a n d to specify tha t the remote operator be located in the pa th o f egress.

T h e commi t tee believes tha t the lack o f a specific location for the ESV opera tor has de t rac ted f rom safety. This addi t ion is of sufficient impor tance to p reven t release of gas to requi re that all facilities be retrofi t ted promptly.

Addit ional r emote opera t ion points are no t requi red b u t can be installed at the discret ion o f the plant . NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON C O M M I T T E E ACTION:


C O M M E N T O N AFFIRMATIVE: LINDER: Suggest the last sen tence of 3-2.8.10(3)(d) be changed

to read, "The d~vice shall be located no t less t han 30 ft no r more t han 100 ft in the pa th of egress f rom the e m e r g e n t " =~utcff;~!; 'e po in t of transfer."

Reason: I believe this is what the commit tee m e a n t to say. It is far more appropr ia te to use the t ransfer p o i n t as the po in t of reference in tha t the ESV migh t actually be a n internal valve in a tank or an ESV, e i ther of which could be 35 ft f rom the po in t of transfer. Note tha t the text says, "20 ft of lineal pipe f rom the nea res t end of the - - . " 20 ft p lus 15 ft of t ransfer hose already has an operator 35 ft f rom an ESV. With the above scenario, it is possible tha t the neares t po in t of the emergency shutof f station migh t have to be 55 ft f rom the po in t o f transfer a n d I am certain this is no t what the commit tee in tended .

RENFREW: This is a very impor t an t step to p r o m o t e safety at new and existing larger s torage and transfer locations. In mos t of the locations I have seen, the manua l ly opera ted remote emergency shutof f device is too dose to the t ransfer location, somet imes it can be measu red in inches or a few feet. I have always believed tha t r emote is to be "remote" and now the commit tee finally considers it to be no t less t han 20 ft n o r m o r e t han 100 ft in the pa th of egress f rom the emergency shutof f valve. Those reading these C o m m e n t s shou ld no t e that this r eq u i r em en t is retroactive for existing installations a n d m u s t be comple ted by March 31, 1999.

(Log #49) 58- 65 - (3-2.8.10): Accept in Principle SUBMITTER: Henry Renfrew, Dept of Public Safety C O M M E N T ON PROPOSAL NO: 58-70 RECOMMENDATION: Add new 3-2.9.10(c) to read:

3.2.9.10(c)* Emergency shutof f valves shall have cables or o ther devices

connec t ed to manua l ly actuate the valves at a po in t n o t less than 20 ft no r more than 100 ft located in the di rect ion of egress f rom the area and be clearly identif ied a n d easily accessible locations as requi red by Section 2-4.5.4.

Add to Append ix A: A-3-2.9.10(c) Emergency shu to f f valves in Section 2-4.5.4(b)

requires m a n u a l ac tua t ion f rom a remote location. Th e in ten t of this sect ion is to ensure the safety o f pe r sonne l working in the immedia te a rea of t ransfer opera t ions a n d to initiate immedia te emergency controls measures in the event of a leak or spill. S U B S T A N T I A T I O N : Section 3-2.8.10 addresses bulk storage an d railroad t ransfer systems requi r ing an emergency shutof f valves or backtlow check valves to stop the flow of p roduc t in m e event ot an emergency. T h e proposal re jected by the commi t tee was to clearly idenufy a n d have easy access to a manua l ly opera ted "remote" emergency shutoffvalve no t less t han 20 f t n o r m o r e t h an 100 ft f rom the locat ion so equipped.

As current ly worded in the code, there is no r euu i r em en t for any remote access or way to shutof f emergency valves.

As I read this section, basically you c~n have a emergency shutoff valve r equ i red to be installed within 20 ft of the lineal p iping f rom the neares t end of the hose. . . .and a t empera tu re sensitive e l ement connec ted to actuate the valve no t more t han 5 ft f rom the nearest end of the or swivel-type piping. T h a t is it. Clearly the code needs to at least manda t e someth ing .

Regard ing the t housands o f EMERGENCY VALVES installed, Section 2-4.5.4 covering emergency shutoffvalves requires in (b) "manual shu tof f f rom a REMOTE location". 3-2.8.10 is completely silent.

I looked up REMOTE in the dict ionary and f o u n d tha t it m ean s ~far f rom others in space, t ime or relat ionship: "Idoim" at a distance". The proposal considers "not less t h a n 20 ft as the start ing poin t for remote as a dis tance a n d I agree. Th e key here is MANUAL S H U T O F F IMPLYING SOMEONE 1N THE IMMEDIATE AREA.

The commi t tee focused on the word "remote" as be ing no t adequa te for m a n y large p ropane plants. I believe it the in ten t of 2-4.5.4 and the proposal is to m a n d a t e emergency protec t ion for individuals working in the area of t ransfer AND IMMEDIATE MEASURES T O C O N T R O L AN EMERGENCY. Two examples , filling two 30,000 tanks a n d a hose breaks (Sandford NC) - the driver/f i l ler can leaving the immedia te area shu t the remote EmVs 20 to 100 ft exit ing the area. At a large bulk p lan t with rail transfer, a s u d d e n leak is observed a n d while exit ing the area, the EV can be shu t r u n n i n g away f rom the arem I would assume tha t larger facilities would have "remote" au tomat ic shu tdown in protec ted areas a n d opera t ions centers bu t these valves still r eq m re m an u a l sbutoffs.

224

N F P A 58 ~ F 9 7 R O C

T h e revised wording p roposed would ensu re tha t individuals working a n d / o r f i l l ing/ t ransfer r ing IProduct in the immedia te area would be able to take immed ia t e ac tmn to control the emergency. T h e commi t tee shou ld consider m a n d a t i n g this r e q u i r e m e n t based on r e c e n t incidents such as Sanford NC. Based on my inspect ion of several facilities, the idea o f m a n u a l r emote shutof f has n o t been proper ly address at m a n y locations and is an impor t an t safety c o m p o n e n t of any bulk facility. COMMITTEE ACTION: Accept in Principle. COMMITTEE STATEMENT: Refer to Commi t tee Action on C o m m e n t 58-64 (Log #17). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITrEE ACTION:


(Log #106) 58- 66 - (3.2.8.10(c)): Reject SUBMITTER: Richard G. F r e d e n b u r g , Dept. of Agricul ture, Nor th Carol ina COMMENT ON PROPOSAL NO: 58-70 RECOMMENDATION: A dd a new Section 3-2.8.10(c)* to read: A remote emergency shu tof f for all emergency shu to f f valves within the bulk n lan t shall be accessible f rom outside the bulk n lan t security fence. I t shall be in the area o f the c o m m o n exit f rom the bulk p lan t and be clearly marked , visible while exiting and f rom o ~ } ~ e the fence, a n d include activation i n s t r u c t i o n s f n u s h or pull), If the security fence is an unreasonab le dis tance f rom the IQ~Oii~ a n d un load ing facilities, the remote emergency shutof f Ill~,y be witahin the security fence bu t shall be directly a iong the ua th of etrress f rom the area and be clearly and obviously marked. (Determina t ion of the unreasonab le dis tance and location of the remote shu tof f shall be made Jointly by nlant- gas comnanv, and local fire d e o a r t m e n t personnel , with d i sagreements settled by the author i ty having iurisdictionA The remote emergency shutof f shall 9uera te at all t imes regardless of weather condi t ions a n d the effects of frozen water. SUBSTANTIATION: At m a n y bulk plants the r emote emergency shu to f f is located within the confines of a narrow, conges ted arem Too often, when an inc iden t r equ i r ing emergency response occurs, the emergency r e sponder s do n o t allow entry into the affected area of ten with jus t i f ied reasons. Since the fence of ten def ines the l imit o f permi t ted access, a r emote emergency shu tof f accessible f rom outside the fence could provide the only permi t ted m e a n s of s topping flow. The mark ing a n d visibility r equ i r emen t s are for p roper react ions u n d e r emergency situations. T he r e q u i r e m e n t for operat ion at all t imes is based on the treed for the system to be able to close ESVs at any t ime and the results of inspect ions showing deficiencies in des ign a n d m a i n t e n a n c e to m e e t this requ i rement . COMMITTEE ACTION: Reject. COMMITI'EE STATEMENT: T he proposa l does no t anticipate the variety o f actual installations. T he commit tee believes tha t its act ion on C o m m e n t 58q~4 (Log #17) provides a significant improvemen t in safety. Locations outside the fence are no t ohibited

ER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 27 N O T RETURNED: 1 'Van Hook

(Log #109) 58- 6 7 - (3.2.8.10(c)): Reject SUBMITrER: Richard G. F r e d e n b u r g , Dept. o f Agriculture, Nor th Carol ina COMMENT ON PROPOSAL NO: 58-70 RECOMMENDATION: Add a new Section A-3.2.8.10(c) to read:

Each installat ion where l iouid LP-Gas t ransfer occurs is uniflue. ~owever. they usuallv share a basic a r r a n g e m e n t and similar " distances f rom transfer points to the security fence. For the usual irlstallation the loca t ion 'o f the remote emergency shu tof f station is def ined. Recognizin~ the un iuueness , this sect ion the of s t anda rd allows the parties mos t likelv to be involved in resDonse to an emergency si tuat ion a t the installation to de te rmine the mos t appropr ia te place to locate a r emote emergency shu to f f station for ilclstallations tha t have a larger than usual dis tance to the fence, it

also olaces the u l t imate author i ty to de t e rmine the location of the remote station with the au thor i tv having iurisdiction. S U B S T A N T I A T I O N : Much has been said about the location of r emote emergency shu tof f stations. Since the commit tee does no t want to specify actual distances to the r emote s tat ion Section 3- 2.8.10(c) a n d A-25.2.8.10(c) recognize tha t each instal lat ion is un ique and ~ives specific gu idance on how to locate the remote emergency shu tof f station without specifying distances. These sections also def ine how the r emo te stat ion shall be located at unusua l installations a n d who has the ul t imate responsibili ty to resolve differences. COMMITI'EE ACTION: Reject. COMMITI'EE STATEMENT: The rejection of C o m m e n t 58-66 (NL~#10fi) makes this unnecessary.

BER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITrEE ACTION:


(Log #CC5) 58- 68 - (3-2.8.10 (3) (c)): Accept SUBMITTER: Technica l Commi t t ee on Liquefied Pe t ro l eum Gases COMMENT ON PROPOSAL NO: 58-70 RECOMMENDATION: Add the following to 3-2.8.10(3)(c) p roposed in Log #108.

Emergency shutoff valves and check valves requi red in this section shall be tested annual ly for p rope r operat ion. The results of the tests shall be documen ted . SUBSTANTIATION= The commi t tee believes tha t annua l testing of these impor t an t safety devices is needed .

Tes t ing of emergency shutof f valves is n o t i n t ended to include test ing of the thermal e lement . COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #54) 58- 6 9 - (3-2.13.1(b)1 a n d 2): Accept in Principle SUBMITTER: Bruce Swiedcki , Nat'l P ropane Gas Assn. COMMENT ON PROPOSAL NO: 58-725 RECOMMENDATION: Revise as follows:

3-2.13.1 (b) l . T h e bypass valve or recirculat ing device to l imit the k 9 K I ~ norma l opera t ing discharge pressure t.~ ~:.~ me.r- ~ . ^ - ~ ~:i

shall thscharge ei ther into a storage conta iner or into the p u m p s ~ - g o ~ i a l ~

(b) 9. If this pr imary device is equ ipped with a shutoff valve, a secondary device des igned to opera te at n o t m o r e t h a n 400 psi or 50 nsi above the onerat in~ oressure, whichever is less. shall, if n o t integral with the p u m p , be inco rpora t ed in the p u m p piping. This secondary device shall be des igned or installed so tha t it canno t be r ende red inoperative and shall d ischarge ei ther into a storage conta iner or into t he p u m p suc- fo~ in le t . SUBSTANTIATION: 1. The use of the t e rm "inlet" is more appropria te .

2. The removal of 350 psi is in recogni t ion of action taken on Proposal 58-74.

3. T h e incorpora t ion of a 50 psi u p p e r limit on the operat ing pressure of the secondary device is n e e d e d to address those systems opera t ing at less t han 350 psi. COMMITTEE ACTION: Accept in Principle.

1. Accept (b) 1. 2. Revise (b) 2 to read: (b) 9. f f t h i s pr imary device is equ ipped with a shutof f valve, a

secondary device des igned to operate at no t more than 400 psi or. for systems with an desicna pressure above 350 psi. 50 psi above the ooera t ing pressure shall, ff no t integral with the p u m p , be incorpora ted in t h e p u m p piping. This secondary device shall be des igned or installed so that it c anno t be r ende red inoperative and shall discharge ei ther into a storage conta iner or into the p u m p s-¢-6o~ i01~. COMMITTEE STATEMENT: Accepted with a clarification for ease of use. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


2 2 5

NFPA 58 - - F97 ROC

(Log #39) 58- 70 - (332.13(b)(1)): Accept SUBMITrER: Bruce Swiecicki, Nat'l Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-74

I RECOMMENDATION: In.Section 3-2.13(b)1, delete the phrase r~¢^--t.h..I. ...... | ..... ~:_^_ ~ ..... a.:~t..t. .... a..^. :. t.~:--~

( P . . . . . . . i . . . . . y r . . . . . . . . . . . . . . . . . . . . . . . . . . . v . . . . . . . . . . . . .

~T~d~TANTIATION: To be consis tent with act ion t&ken on Proposal 58-73. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #3) 58- 71 - (333.3.3): Reject SUBMITTER: Northeast Regional Fire Code Dev. Commit tee COMMENT ON PROPOSAL NO: 58-75 RECOMMENDATION: The commit tee should reject this

~ roposal and re turn the wording to the existing code language. UBSTANTIATION: The p roposed language does no t provide

any specific guidance over the existing language. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The text is revised in Comment 58- 72 (Log #40). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION: AFFIRMATIVE: 27 NOT RETURNED: 1 Van Hook

(Log #40) 58- 72 - (333.3.3): Accept in Part SUBMITTER: Bruce Swiecicki, Nat'l Propane Gas Assn. COMMENT ON PROPOSAL NO: 5875 RECOMMENDATION: In Section 3-3.3.3, revise the second sentence as follows: 4Mtequ,a~

Clearances from..." Add the following sentence to the paragraph: Barriers shall be

provided at the ends of rallrgad sidings and approache~. SUBSTANTIATION: The editorial group of the Technical Commit tee a t tempted to address a problem with the word "substantial", but in the process wound up losing an impor tant requ i rement to provide a barrier at the ends of sidings. Rewording the second sentence would remove ambiguous language and still retain the safety aspects of the current section. The addition of the last sentence wouldre ins ta te the need for barriers. COMMITTEE ACTION: Accept in Part.

Add to 3-3.3.3 as p roposed in the ROP: Barriers shall be provided at the ends of railroad sidings.

COMMITTEE STATEMENT: Barriers are no t needed on F gaches

R OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #107) 58- 73 - (333.3.8(a)4): Hold SUBMITTER: Richard G. Fredenburg , Dept. o f Agriculture, Nor th Carolina COMMENT ON PROPOSAL NO: 58-70 RECOMMENDATION: Add a new Section 3-3.3.8(a~4 49 read: A strainer or o ther screening device to prevent th~ introduction of foreK, n debris and with openings no t lar~er than 0.25 in nominal shall-be orovided in the liouid transfer piping into the l~olk plan~; between the first valve and the Point of transfer, preferably so t h ~ when the hose is removed, the debr is is visible and can be removed f rom the screenin~ device. SUBSTANTIATION: As a result of the actual failure of a transfer hose assembly and a backflow check valve that allowed thousands of gallons of LP-Gas to escape from a bulk plant testing initiated to confirm proper operat ion of such backflow check valves showed a high failure rate of almost one valve in ten. The reasons for these failures are still being de termined, but can b e p u t into two categorise: mechanical failure of the valve a n d d e b r i s (gravel,

parts o f pump vanes, broken screws, etc.) blocking the valve disk open. A simple screening device to prevent the introduct ion of debris can significantly improve the reliability of these valves and reduce the possibility of a repeat of this type of release. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: The comment contains new material that has no t had publ ic review. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #16) 58- 74 - (3-8.4.2(0): Accept in Principle SUBMITTER: James H. Stannard, Jr . , S tannard & Co. COMMENT ON PROPOSAL NO: [58-84 RECOMMENDATION: Revise 3-8.4.2(f) to read:

3-8.4.2(0 Provision shall be made in all appliance installations to ensure an adequate supply of outside air for combust ion. SUBSTANTIATION: I would object to the removal of the word "adequate" as an u n n e e d e d modifier. On the contrary I believe the s ta tement should be s t reng thened by adding the word "complete" before ~combustion." COMMITTEE ACTION: Accept in Principle.

I Revise 3-8.4.2(r) to read: 3-8.4.2(0 Provision shall be made in all appliance installations

for a supply of outside air for complete combustion. COMMITTEE STATEMENT: Accepted with editorial modification. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #41) 58- 75 - (3-9.3.4): Reject SUBMITTEP¢ Bruce Swiecicki, Nat'l Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-86 RECOMMENDATION: Editorial Comment :

The Commit tee Statement is incorrect. The differential valve stops the flow of liquid when the p u m p is n o t operating. SUBSTANTIATION: None. COMMITTEE ACTION: Reject. COMMITI'EE STATEMENT: The comment does no t provide a specific r ecommenda t ion as required by the regs. Add arl editorial correction to the ROC to correct the ROP as

indicated. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #6) 58- 76- (3-9.4.3): Reject SUBMITTER: Northeast Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: 58-88 RECOMMENDATION: Reconsider the committee action on this

~ roposal and reject this proposal. UBSTANTIATION: The distance should be maintained at 10 ft.

By the committees own admission in the commit tee statement this proposal is clearly missing significant parts. COMMITrEE ACTION: Reject. COMMITTEE STATEMENT: The commit tee s ta tement published in the ROP is in error. The committee agrees with the substantiation provided by the submitter publ ished in the ROP. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: RENFREW: The Commit tee should coordinate and agree to

uniform requirements involving other vehicles fuel systems. The use of p ropane as a major alternate fuel source will no t be successful until all the fueling requirements for the different fuels

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is coordinated. I suppor t the Commen t by Southeast Regional Fire Code Dev. Commit tee on 58-77 (Log #10).

58- 77 - (5-9.4.3): Reject (Log #10) SUBMITTER: Southeast Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: 58-88 RECOMMENDATION: Change the 10 foot distance to 20 feet. SUBSTANTIATION: The current provision of 10 feet does not correlate with NFPA 30A 4-2.8 which requires a 20 feet separation distance. Without this correlation the enforcement community

ets conflicting distances causing confusion. OMMITTEE ACTION: Reject.

COMMITTEE STATEMENT: The committee agrees that a discrepancy exists and that NFPA 30A should be corrected. Experience in the US ~md Canada has demonstra ted that the 10 ft separation distance is sufficient. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: RENFREW: See Conunent 58-76 (Log #6). If 20 ft is the standard

for other fuels, then propane dispensers should be 20 ft.

(Log #105) 58- 78- (5-10.2.3): Reject SUBMITTER: Henry Renfrew, Dept of Public Safety COMMENT ON PROPOSAL NO: 58-90 RECOMMENDATION: Delete existing 5-10 and substitute the following:

3-10 Fire Protection 3-10.1 Application This section contains provisions for fire protect ion to augment

the leak control and ignition source control provisions in this standard.

5-10.2 General 5-10.2.1 The wide range in size, arrangement , and location of LP-

Gas installations covered by this s tandard precludes the inclusion of detailed fire protect ion provisions completely applicable to all installations. Provisions in this section are subject to verification or modification th rough analysis of local conditions.

3-10.2.2" The planning for effective measures for control of inadvertent LP-Gas release or fire shall be coordinated with local emergency handl ing agencies, such as fire and police departments . Such measures require specialized knowledge and training no commonly present in the training programs of emergency handl ing agencies. Planning shall consider the safety of emergency personnel .

3-10.2.3. Each industrial plant, bulk plant, and distributing point shall be provided with at least one approved portable fire extinguisher having a irfinimum capacity of 18 Ib (8.2 kg) of dry chemical with a B:C rating. (Also see NFPA 10.)

3-10.2.4 Emergency controls shall be conspicuously marked, and the controls sha|l be located so as to be readily accessible in emergencies.

5-10.3 Fire protection shall be provided for installations having storage containers with an aggregate water capacity of more than 4,000 gal (15.1m3). The mode of such protect ion shall be de te rmined through a competen t fire safety analysis (see 3-10.3).

. 5-103.1 Fire Safety Analysis . The fire safety analysis shall evaluate:

(a) product control systems including emergency internal and shutoff valves having remote and shutoff capability and pultaway protect ion,

(b) accessibility of the facility to trespass and damage, (c) the effectiveness of the responding fire depar tment including

the availability of water and suitable roadways or other means of access for emergency equipment ' and

(d) exposures sur rounding the facility. 5-10.3.2 If the fire safety analysis indicates that a hazard exist, the

p roduc t control measures (PCM) in 5-10.4 shall apply. 3-10.4 Product Control Measures. (a) All vapor and liquid withdraw openings on containers shall

be equ ippedwi th an internal valve with an integral excess flow valve or excess flow protection. The internal valves shall be des igned to remain closed except dur ing operat ing periods and shall be equipped with a means of remote closure. The internal

valves shall also be equipped with automatic shutoff th rough thermal (fire) actuation. In addit ion, a positive manual shutoff valve shall be installed as close as practical to each internal valve.

(b) All vapor and liquid inlet openings on containers shall be equipped in accordance with the provisions of 5-1-4(a) above or shall be permi t ted to be equipped with a backflow check valve with a positive manual shutoff valve installed as close as practical to the backflow check valve.

(c) At cargo tank and railroad tank car transfer points, protect ion shall be provided in accordance with 3-2.8.10 using approved emergency shutoff valves or backflow checl~ valves or a combinat ion of the two.

(d) Automatic system shutdown of all primary valves (internal valves and emergency shutoff valves) th rough thermal (fire) actuation shall be provided.

(e) Remote shutdown capability, including power supply for transfer equ ipment and all pdmary valves (internal and emergency shutoff) sha l l be provided as follows:

1. A remote shutdown station shall be installed within 15 ft of the point of transfer.

2. At least one additional remote shutdown station shall be installed no t less than 25 ft nor more than 100 ft from the transfer point:

3. Emergency remote shutdown stations shall be identified as such by a sign incorporat ing the words "Propane" "Emergency Shutoff ' in block letters of not less than 2 in in height, on a background of contrasting color to the letters and shall be visible from the point of transfer;

(f) Pullaway Protection: In addit ion to meet ing the requirements of (c) above systems falling within the scope of 3- 2.8.10 shall provide for automatic closure of all emergency shutoff valves and internal valves connec ted to the transfer system in the event of a hose pullaway.

5-10.5 Special Protections. If container exposure to fire creates a possibility of failure of the container, the container shall be protected by one of the following:

(a) moni tor nozzles located and arranged so that all container surfaces likely to be exposed to fire will be wetted, such systems shall otherwise comply with NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection, and shall be automatically actuated by fire responsive devices and also have a capability for manual actuation.

(b) fixed water spray system complying with NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection. Such systems shall be automatically actuated by fire responsive devices and shall also have a capability for manual actuation.

(c) insulation capable of limiting the container temperature to not over 800°F (427°C) for a min imum of 50 min. as de te rmined by test with insulation applied to a steel plate and subjected to a test flame substantially over the area of the test plate. The insulation system shall be inherently resistant to weathering and the action of hose streams. (See Appendix.)

(d) any other means listed for this purpose. ADD TO APPENDIX 3-10.3.1 The purpose of the fire safety analysis is to reduce fire

An effective product control system with emergency es significandy reduces the potential for exposure to fire

conditions. LP-Gas fires shall not normally be extinguished until the source of the burning gas has been shut off or can be shut off.

Mounding of containers as outl ined in Section 5-2.4.7, protects the containers from fire exposure and eliminates the need for fire protect ion of the containers.

Burial of containers as oud ined in Section 3-2.4.8, protects the containers from fire exposure and eliminates the need for fire protect ion of the containers.

Experience has indicated that hose stream application of water in adequate quantities as soon as possible after the initiation if flame contact is an effective way to prevent container failure from fire exposure. The majority of large containers exposed to sufficient fire to result in container failure have failed in from 10 to 30 min. after the start of the fire where water was not applied. Water in the form of a spray can also be used to control uniginted gas leakage. SUBSTANTIATION: The proposal as submit ted is an out s tanding effort by the industry to provide specific information and guidelines for the safety of storage and transfer locations.

I believe the intent of the proposed RFPCM is to provide specific requirements to replace the existing special provisions which have been a problem for years. In fact, the existing wording has caused numerous problems and has not taken into account the advances in product controls and safety equipment .

I have a t tempted to rewrite all of this in what I consider a more meaning way. As written in the proposal, I think every code

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official will automatically j u m p into RFPCM as manda ted which is no t the intent of the proposal.

Using this new 3-10 the fol lowingis accomplished. #1 Guidelines for conduct ing a Fire Safety Analysis are provided.

the appendix reference stresses "effective product control system emergency valves significantly reduces the potential for exposure to fire conditions" and recognizes mound ing and burial "protects the containers f rom fire exposure and eliminates the need for fire protect ion of the containers".

#2 Product Control Measures instead of the RFPCA4s are needed only when a serious hazard exists. With effective product control systems in most cases it should only be a hazard present at the facility.

#3 Special Protection is still included but specific for "If container exposure to f i r e creates a possibility of failure of the container" - by design, p roduc t control system and in serious hazard situations with Product Control Measures - again in most cases the need for special protect ion will no t be there because there is no exposure to fir creating possibility of container failure. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The commit tee believes that the comment is editorial, and that the p roposed text is preferred. N U M B E R OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 28 V O T E O N COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: RENFREW: The Commit tee rejected my Proposal which was simply a rewrite of 3-10 adding the change in 58-90 (Log #105). The original proposal as submit ted is an outstanding effort by the industry to provide specific information and guidelines for the safety of storage and transfer locations.

I believe the in tent o f the p roposed RFPCM is to provide specific requi rements to replace the existing special provisions which have be~n a p rob lem for years. In fact, the existing wording has caused numerous problems and has no t taken into account the advances in product controls and safety equipment .

I have a t tempted to rewrite all of this in what I consider a more meaning way. As written in the original proposal, I think every code official will au tomat lca l ly jump into RFPCM as manda ted which is no t the in tent of the proposal.

Using this new 3-10 I have drafted, the following is accomplished. 1. Guidelines for conduct ing a Fire Safety Analysis are provided.

The appendix reference stresses ~effective product control system with emergency valves significantly reduces the potential for exposure to fire conditions" and recognizes mound ing and burial ~protects the containers f rom fire exposure and eliminates the need for fire protect ion of the containers".

2. Product Control Measures instead of the RFPCMs are needed only when a serious hazard exists. With effective product control systems in most cases it should only be a hazard present at the facility.

3. Special Protection is still included but specific for " I f container exposure to fire creates a possibihty o f failure of the container"- by des i~ . , p roduc t control system and in serious hazard situations v~th Product Control Measures - again in most cases the need for special protect ion will no t be there because there is no exposure to fire creating possibility of container failure.

(Log #CCI 2) 58- 79- (3-10.2.3): Accept SUBM1TTER: Technical Commit tee on Liquefied Petroleum Gases COMMENT O N PROPOSAL NO: 58-90 RECOMMENDATION: Revise 3-10.2.3 to read:

3-10.2.$ The first consideration in any such analysis shall be an evaluation of the total product control system including emergency shutoff and internal valves having remote and thermal shutoff capability and pullaway protection, and the optional requirements of Section 3-11, if used. SUBSTANTIATION: The p roposed text is revised to delete the term RFPCM and to substitute reference to the new Section 3-11. COMMITTEE ACTION: Accept. N U M B E R OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 28 V O T E O N COMMITTEE ACTION:


EXPLANATION OF NEGATIVE:

RENFREW: See my Explanation of Negative on Comment 58-80 (Log #11). COMMENT O N AFFIRMATIVE:

LINDER: Suggest the following editorial change: "The first consideration in any such analysis shall be an evaluation of the total product control system including internal valves and emergency shutoffvalves having remote and thermal shutoff capability and pull-away protect ion, and the optional provisions of Section 3-11, if used.

(Log #CC15) 58- 80 - (4-2.2.1): Accept SUBMrI*rER: Technical Commit tee on Liquefied Petroleum Gases CO MMENT ON PROPOSAL NO: 58-97 RECOMMENDATION: Additions to current NFPA 58 text are noted in ~ and deletions are no ted in s~goout+ 4-2.2.1 In the interest of safety, transfer of LP-Gas to and-Dora- a gg_tLqD_g~ container shall be accomplished only by the container 's owner 9r uoon authorization of the container 's owner. Transfer of LP-Gas fi:qm ~ container shall be accomplished onlv after notifving the container 's owner that such action will be taken. Transfer of LP- Gas to or from a container shall be accomDlished only by qualified persons trained in p roper handl ing and operat ing procedures meet ing the requirements of Section 1-6 and "~n c:'..crgcn~"

SUBSTANTIATION: By way of background, many stationary containers installed on consumer premises are no t owned by the consumer, hut are instead leased to the consumer by the retail gas marketer. Since 1946, NFPA 58 had required that containers be filled only by the owner of the container or with the owner's consent. The in tent beh ind this provision was to foster the safe main tenance and use of the container and the gas distribution system, since the owner would be responsible for maintaining his own equipment .

In 1991, the NFPA Standards Council approved a Tentative Interim A m e n d m e n t (TIA) that would permi t a n y p e r s o n or company to fill any container. This TIA was i s sued in response to a challenge to Section 4-2.2.1 in the 1989 edit ion of NFPA 58, which read: ~Containers shall be filled only by the owner or upon the owner's authorization." The Utah Attorney General had challenged this section on the basis that it violated federal antitrust laws.

Subsequent to the issuance of the TIA, on April 15, 1992, the Utah Federal District Court, Central Division, issued a declaratory j u d g m e n t specifying that the ownership phrasing of NFPA 58 Section 4-2.2.1 was an appropriate c o m p o n e n t of the Standard that provided an important e n h a n c e m e n t of safety which transcends all o ther considerations. No appeal was filed on the Court action.

The following organizations are regularly involved with liquefied pe t ro leum gases storage and handl ing issues and strongly concur with the emphasis on safety handed down by the Utah Federal Court:

Major insurers of the LPG industry (Continental Insurance Company, Nobel Insurance Company, and Ranger Insurance Company)

Underwriters Management Associates, Inc. The National Association of State Fire Marshals U.S. Consumer Product Safety Commission Staff U.S. Depar tment of Transportat ion U.S. Occupational Safety & Health Administrat ion Most authorities having jurisdiction The Compressed Gas Association The National Propane Gas Association. However, and in spite of a number of appeals by the propane

industry, the 1992 edit ion of NFPA 58 was pr in ted with the language as it currently appears in Section 4-2.2.1. This is the background on the current language.

The p roposed language will enhance safety while removing any imped iment to the normal change of suppliers when desired by a consumer or customer. The addit ion of the sentence dealing with the evacuation of a container will more explicitly sanction, ff no t promote , a long standing proper action that is common practice in many locations, ff a customer becomes dissatisfied with his (her) current supplier, a new supplier o f the customer's choice is permit ted to transfer any product owned by the customer into another container and set the original container aside for pick-up by the original supplier. Thus, the customer is spared the

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inconvenience of procrastination a n d / o r pump out charges by the original supplier that might be perceived as an intentional incentive no t to switch. There fo re , the added provisions will eliminate any perceived commercial advantage that the original supplier wou ldhave along with the percept ion of "tying" the customer to a particular supplier.

Why is it necessary to restrict the filling of containers to the owner or with the owner's authorization? Because the owner of the container is more likely to be responsive to the need for maintaining the conta iner in a safe and p roper manne r than is an individual whose pr imary objective i s jns t to sell gas at a lower price than his competi t ion. A supplier who would fill a competi tor 's container is, at the very least, i ndu lg ing in a form of misappropriat ion of property. Such a practice might be described as a questionable business practice. While the ethics of a business transaction is no t a normal subject to be addressed in a safety standard, it should be no ted that a supplier who drives down a street filling his competi tor 's tanks wil lhave little reason to anticipate the prospect of repeat business. Therefore, he will have every incentive to maximize that one-time cut-rate sale by overfilling the container, which is an extremely dangerous practice.

The modest requi rement of owner authorization for the transfer o f product into a container should provide an enforceable imped iment to the less than ethical supplier who is p rone to ignore basic safety considerations. It should also be no ted that the proposed requi rements do no t diminish the responsibilities of any supplier to that segment of the market comprising consumers who own containers.

The need. for restricting the filling of containers, is recognized by the Uni ted States Depar tment of Transportataon (DOT) rules (which were adopted by the Interstate Commerce Commission sometime pr ior to 1919), which state: ~A container charged with a compressed gas must not be shi]~ped unless it was charged by or with the consent of the owner o t t h e container." [49 CFR 173.30(b)]

Similarly, the U.S. Depar tment of Labor's OSHA regulations state: "Containers shall be filled or used only upon authorization of the owner." [29 CFR 191O.ll0(b)(14)(i i)]

The need for such restrictions on filling containers is also recognized by agencies such as the Uni ted States Consumer Product Safety Commission (CPSC), whose staff has gone on record in a letter stating the following: ~I'he requi rement that a tank be filled only by or with the consent of its owner provides significant safety benefits to consumers. Before the new NFPA rules became effective, owners of p ropane tanks (supplier-owned) were able to prevent them from becoming empty by keeping records. .°f refilling, dates, and amounts,., and coordinat ing refilling to c o m o d e with usage, thereby obvtatmg the need for relighting pilot lights on appliances. Injury informat ion available to CPSC indicates that a significant risk is associated with relighting pilot lights on appliances. The record-keeping also provided a basis for recognizing differences in fuel use which could indicate dangerous leaks."

The revised language of Section 4-2.2.1 eliminates the ment ion of "emergency response procedures." That requirement , which was included in the language adopted on the floor at the 1991 Fall Meeting in Montreal, is premature because nei ther the in tent nor scope of such procedures have been considered nor specified elsewhere in the standard. Lacking such specificity, the enforceability of the requ i rement is, at the best, questionable.

The word "stationary"is included in Section 4-2.2.1 to be consistent with usage elsewhere in the standard. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: ADAMS: It is evident that this action is contrary to the NFPA

Standards Council action taken on this mat ter in the past. Al though the substantiation given by the submitter leads on eto believe that additional safety information has been received to defend the submitters substantiation, there was no documenta t ion given to the committee at the meet ing or subsequent to that meet ing to support the statements. I also include in this reason the substantiation given by Mr. Renfrew in Comment 58-81 (Log #74).

MORTIMER: This proposal should be rejected. Being the owner of a container does no t necessarily mean that you can safely fill a container, or give permission to a person who can safely fill a container. Current wording is adequate for the safe filling of

containers, and the changes do noth ing to improve or enhance safety.

RENFREW: Acceptance of this Proposal is in direct conflict with action taken by the Standards Counc i l in 1991.

In 1991, the Council he ld a hear ing (91-43) regarding the phrase "shall be filled only by the owner or upon the owner's authorization" contained with NFPA 58. As a result of the hearing, the Council concluded that phrase is de le ted f rom the s tandard and that "other language in the proposed TIA concerning safety requirements for the filling of LP-Gas containers is already addressed by o ther existing provisions in NFPA 58".

Proposal 58-97 Accepted in Part by the Committee, reintroduces the phrase "the contmner 's owner or upon authorization of the container 's owner" into the standard.

The substantiation received by the Technical Committee references a "declaratory judgement" issued in 1992 by the Utah Federal District Court which reportedly states "the ownership phrasing of NFPA 58 Section 4-2.2.1 was an appropriate components of the s tandard that provided an impor tant enhancemen t of safety which transcends all o ther considerations". For the record, a copy of the declaratory j u d g e m e n t was no t furnished to the Committee.

AS the hearing in 1991, the Council was aware of legal issues in Utah regarding the filling of containers only by the owner or with their authorization. At that time the Council noted as part of the hear ing "the council wishes to stress that in reaching its decision to delete 4-2.2.1, it did no t a t tempt to reach any conclusion concerning the legal issues raised by the Attorney General. Rather the Council has confined itself to an examination of the question of whether safety considerations justify the re tent ion of 4-2.2.1 in NFPA 58".

The substantiation states that various governmental regulations and insurance companies require filling of containers only by the owner or upon heir authorization. I believe the Council was made aware of similar information at the 1991 hearing.

The substantiation also states that " t h e p r o p o s e d language will enhance safety while removing any imped iment to the normal change of supplier when desired by a consumer or customer".

To suppor t tlais position, the following phrases are included which in my opinion address business practices not safety:. "if a customer becomes dissatisfied with his (her) current supplier", the customer is spared the inconvenience of procrast inat ion", and "eliminate any perceived commercial advantage".

Fur thermore, the substantiation implies that container fillers, o ther than an owner, will not pe r form their duties with the same level o f safety: ~the owner of the container is more likely to be responsive to the need for maintaining the container in a safe and proper manne r than is an individual whose primary objective is just to sell gas at a lower price than his competit ion".

Finally, at the 1991 hear ing the Council stated "The council, however, does no t regard ownership of a container by the filler as a prerequisite to safety".

In conclusion, I believe the substantiation does no t provide any new safety related information and should be re jec ted by the Committee.

The above information was part of a complaint to the Standards Council regarding this issue. In the Standards Council response to the compliant, they said "the Council reviewed and considered all the information available to it and voted to deny the complaint, because the Council agrees that consideration of the issue now, while the issue is still being processed within the NFPA standards development system, would be premature". They also stated "Should Proposal 58-97 survive the full processing of the document , the appropriate t ime for the Council to consider any action concerning it will be when the fully processed documen t is presented to the Council for issuance". COMMENT ON AFFIRMATIVE:


(Log #74) 58- 81 - (4-2.2.1): Reject SUBMrrTER= Henry Renfrew, Dept of Public Safety COMMENT ON PROPOSAL NO: 58-97 RECOMMENDATION: The commit tee accepted in part Proposal 58-97. I r e commend the commit tee reject the proposal and delete t h e p r o p o s e d text. SUBSTANTIATION: Acceptance of this proposal is in direct conflict with action taken by the Standards Council in 1991.

In 1991, the council held a hearing (91-43) regarding the phrase "shall be filled only by the owner or upon the owner's authorization" contained with NFPA 58. As a result of the hearing,

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the council concluded that phrase is deleted from the standard and that "other language in the proposed TIA concerning safety requirements for the filling of LP-Gas containers is already addressed by other existing provisions in NFPA 58".

Proposal 58-97 accel~ted in part by the committee, reintroduces the phrase "the contmner's owner or upon authorization of the container's owner" into the standard.

The substantiation received by the technical committee references a "declaratory judgment" issued in 1992 by the Utah Federal District Court wHich-reportedly states "the ownership phrasing of NFPA 58 Section 4.2.2.1 was an appropriate component of the Standard that provided an important enhancement of safety which transcends all other considerations". For the record, a copy of the declaratory judgment was not furnished to the committee.

At the hearing in 1991, the council was aware of legal issues in Utah regarding the filling containers only by the owner or with their authorization. At that time the council noted as part of the hearing "the council wishes to stress that in reaching its decision to delete 4-2.2.1, it did not attempt to reach any conclusion concerning the legal issues raised by the Attorney General. Rather the Council has confined itself to an examination of the question of whether safety considerations justify the retention of 4-2.2.1 in NFPA 58".

The substantiation states that various governmental regulations and insurance companies require filling of containers only by the owner or upon their authorization. I believe the Council was made aware of similar information at the 1991 meeting.

The substantiation also states that " theproposed language will enhance safety while removing any impediment to the normal change of supplier when desired by a consumer or customer.

To support mis position, the following phrases are included which in my opimon address business practices not safety:. "if a customer becomes dissatisfied with his (her) current supplier", the customer is spared the inconvenience of procrastination", and "eliminate any perceived commercial advantage".

Furthermore, the substantiation implies that container fillers, other than an owner, will not perform their duties with the same level of safety "the owner of the container is more likely to be responsive to the need for maintaining the container in a safe and proper manner than is an individual whose primary objective is

st to sell gas at a lower price than his competition". Finally, a ( the 1991 hearing the Council stated "The council,

however, does not regard ownership of a container by the filler as a prerequisite to safety".

In conclusion, I believe the substantiation does not provide any new safety related information and should be rejected by the committee. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The technical committee restates its belief that this is a matter of safety. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 24 NEGATIVE: NOT RETURNED: 1 Van Hook

EXPLANATION OF NEGATIVE: ADAMS: The Committee should have accepted this Comment

based on the substantiation given by the submitter and my reason as stated in the Explanation of Negative on Comment 58-80 (Log #11).

MORTIMER: Comments should be accepted. I agree with the substantiation given by Henry Refrew.

RENFREW: See my Explanation of Negative on Comment 58-80 (Log #11).

(Log #15) 58- 82 - (4-2.2.9): Accept SUBMITTER: James H. Stannard, Jr., Stannard & Co. COMMENT ON PROPOSAL NO: 58-98 RECOMMENDATION: Delete:

SUBSTANTIATION: This comment is duplicated in Proposal 58- 99 with the added provision regarding the evacuation of containers. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #27) 58- 83 - (4-2.2.2): Reject SUBMITrER: Bruce Swiedcki, Nat'l Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-99 RECOMMENDATION: Revise as follows:

4.2.2.2 Injection of any material other than LP-Gas cc.~..Fre~e~ ^ . . t ' 1 : - : . . . . air, cx)gca, ~r :=:y . . . . . . . ~, ~,-- into containers :~ ~-.~:fer for the

vurnose of transferrin~ LP-Gas liquid shall not be permitted. (Remainder unchanged). SUBSTANTIATION: The proposed change addresses the use of foreign materials more completely, and is worded to avoid misinterpreting the requirement. COMMITTEE ACTION: Reject. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #66) 58- 84- (4.4.3.1): Accept SUBMITTER: Bruce Swiecicki, Nat'l Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-104 RECOMMENDATION: Agree with NFPA Technical Committee. SUBSTANTIATION: The proposal is made for editorial clarification. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:



(Log #62).

(Log #67) 58- 85 - (4.4.3.2(c)): Accept SUBMITTER: Bruce Swiecicki, Nat'i Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-105 RECOMMENDATION: Amend the NFPA Technical Committee action and reject the original NPGA proposal to insert a new section. SUBSTANTIATION: The OPD has not been proposed as a primary filling device. Without rejection, the proposed new Section 4.4.$.2(c) permits the OPD to become a primary filling device. Refer to details in the reason for comment on Log #39a. COMMITTEE ACTION: Accept.

] COMMITTF.~ STATEMENT: Accept the comment to revise action on Proposal 58-105 to reject. NUMBER OF-COMMII~I'EE MEMBERS ELIGIBI~ TO VOTE: 28 VOTE ON COMMITTEE ACTION:




PETRU: Refer to L. Pakrnda's Comments.

(Log #132) 58- 86 - (4-4.3.2(c)): Reject SUBMITTER: Steven T Gentry, Worthington Cylinder Corp COMMENT ON PROPOSAL NO: 58-105 RECOMMENDATION: Revise text to read as follows:

"4-4.3.2(c) Portable cylinders with 4 lb through 70 lb 40 lb, propane capacity..." SUBSTANTIATION: 1. In discussing and modifying this topic, the Technical Committee did not discuss the issue that some cylinders over 40 lb LP-Gas capacity may contain liquid vapor valves. In order to equip the cylinder with an OPD, an additional opening would have to be placed in all cylinders greater than 40 lb LP-Gas capacity. This would potentially require that all cylinders 41 Ib through70 Ib LP-Gas capacity be rebuilt or scrapped to accommodate the OPD. I have not been convinced by the Technical Committee that a problem exist with these cylinders and

230

N F P A 58 - - F 9 7 R O C

that safety would be enhanced by expanding the requirement from the original submitters request.

2. To accommodated thee 70 lb LP-Gas requirement, cylinders using liquid vapor valves would have to be completely redesigned so that the cylinder could not be filled through the oudet connection. To my knowledge, there h no such device for use in LP-Gas.

5. Although I agree that is would be nice to have NFPA 58 adopted by many countries throughout the world, we need to focus that it is an ANSI standard. The Technical Committee increased the cylinder size from 40 lb to 70 lb to accommodate metric size cylinders used outside the United States. I believe that the standard should reflect the requirements of the United States and the additional countries that adopt the standard should be handled as exceptions or additions once that specific country adopts the standard. COMMITTEE ALl'ION: Reject. COMMITTEE STATEMENT." The proposed text has been deleted in Comment 58-85 (Log #67). NUMBER OF COMMrITEE MEMBERS ELIGIBLE TO V O T ~ 28 VOTE ON COMMITTEE ACTION:




(Log #68) 58- 87- (4-4.3.3): Accept SUBMr['rER: Bruce Swiecicki, Nat'l Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-106 RECOMMENDATION: Revise the text as follows: '

4-4.3,3(a) If a fixed maximum liquid level gauge ,ev~l~ i i~ r.rc;'=---~c= ~=-c: , or a variable liquid level a~m~e without liquid volume temperature correction is used, the ]~qu~d level indicated by these gauges shall be computed based on the maximum permitted filFmg limit when the liquid is at 40°F for aboveground containers or at 50°F for underground containers. SUBSTANTIATION: Re.on." Including the OPD in this section would unintentionally declare it to be a primary filling device. Section 1-6 now references the criteria for the maximum permitted filling limit in the proposed OPD definition. COMMrlWRR ACTION: Accept. NUMBER OF ODMMITrF~ MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #42) 58- 88 - (4-~.~,~(C)): Accept SUBM/TrER: Bruce Swiecicki, Nat'l Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-107

I RECOMMENDATION: Editorial Comment: Insert "maximum" between "fixed" and "liquid" in 4-4.3.5(c).

SUBSTANTIATION: None. COMMrITEE ACTION: Accept. NUMBER OF COMMITYEE M E l t E R S ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #4) 58- 89 - (5-4.1): Reject SUBMITrER: Northeast Regional F'we Code Dev. Committee COMMENT ON PROPOSAL NO: 58-112 RECOMMENDATION: The committee should reconsider the committee action and accept the proposal and add the fol lowing:

5-4.1.1 All nermm emnldved at LMinder exchanae noints sh~dFhe trah3ed in the safe handlln~, stora~e and emer~en~ procedures. SUBSTANTIATION: The-0pera~on of retail ~ylind& exchange has become a significant national operation. The requirements for Safety are important as facilities often contain other hazardous materials and operations (service stations, hardware stores). The safety considerations need to addres~

I. Bu'ddings with potential single exits. 2. Flammable gas containers near fueling operations. 3. Untrained personnel. 4. Potential leaking cylinders located near exits. 5. Potential ignition sources such as car fires and smoking. 6. Fuel tanker truck off loading. 7. Serious potential for vehide impact. 8. Condition of containers dropped off for exchange. Proposal 58-112 along with the modifications for employee

training is critical to insure minimum fire safety standards for this hazard. We also feel that the definition of cylinder exchange point is important for sa l ty and code enforcement. COMMFFIT.E ACTION: Reiect. COMMITTEE STATEMEN'I~. • Refer to proposal 58-1 which revises 1-5, Qualification of Personnel, to make it applicable only to persons whose primary duties fall within the scope of the standard. This does n0t apply to persons at retail establishments who have many duties. The cylinder has a dosed valve and a plug, and is considered by the US. Department of Transportation to be a safe %con er

OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 NEGATIVE~ 2 NOT RETURNED: 1 Van Hook

EXPLANATION OF NEGATIVE: ADAMS: I believe this matter needs addressing since the

exchange cylinder locations falls within the scope of this standard. See the Action taken on Comment 58-3 (Log #CC8). Although there has been no known incidents at this time involving these installations, there is definitely a need for persons handling these tanks to be able to recognize problems that could occur with cylinders received and sold.

RENFREW: I agree with the Northeast Regional Fire Code Dev. Committee. The information in the original Proposal (58-112) should be accepted by the Committee. Persons employed at cylinder exchange points should be trained in the safe handling, storage and emergency procedures. The substantiation by the Committee states "Refer to Proposal 58-1 which revises 1-5, Qualification of Personnel, to make it applicable only to persons whose primary duties fall within the scope of the standard. This does not apply to persons at retail establishments who have many duties." I agree but believe that persons at cylinder exchange points should be required to be trained in addition to the revised 1-5. That ~ the intent of the original Proposal.

(Log #7) 58- 9o- (5-#.1): Reject SUBMITrER: Southeast Regional Fwe Code Dev. Committee COMMENT ON PROPOSAL NO: 58-112 RECOMMENDATION: Reconsider the committee action and accept the proposal. Also change the distance for the cylinder exchange point from an opening or doorw~ from I0 feet to 20 feet. SUBSTANTIATION: Many of these cylinder exchange points are located at small stores that have a single exit. The placement of these exchange points within 10 feet from an opening or an exit places the occupants at a greater risk. Ignition sources in these facilities are no / 'm~y located in the vicinity of the doorway inside the building. Dam provided by the Austin FD is provided as additional suppdrflng data. COMMITTEE ACTION: Reject. COMMITYgE S T A ~ The committee believes that the ~F~Rg proposed is adequate. No accident data has been

to refute this. OF CoMMrrI 'EE MEMBERS ELIGIBLE TO VOTE: 28

VOTE ON COMMITTEE ACTION: AFFIRMATIVF~ 26 NEGATIVE: 1 NOT RETURNED: 1 Van Hook

EXPLANATION OF NEGATIVE: ~ : I agree with the Southeast Regional Fire Code Dev.

Committee. The Committee should add specific information about cylinder exchange points and keep them at lest 20 ft from an opening or doorway into a building.

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N F P A 58 - - F97 R O C

(Log #116) 58- 91 - (5-4.1): Reject SUBMITTER: Paul Maldonado, Austin Fire Department COMMENT ON PROPOSAL NO: 58-113 RECOMMENDATION: Revise Section 5-4.1 to read:

5-4.1" Location of Storage Outside of Buildings. Storage outside of buildings for containers awaiting use, exchange, or resale shall located at least ~40 ft (~3~ 12.2m) from any doorway and source of

in a building frequented by the public and in accordance with Table 5-4.1 with respect to:

(a) through (e) unchanged SUBSTANTIATION: The current provisions for locating cylinder exchange cabinets are based on separation distances that have not been quantified by testing or other scientific methods. These provisions also do not consider the location of cylinder exchange cabinets in relation to sources of ignition. For example, vending and ice machines or equipment demonstrations are commonly placed in front of mercantile occupancies near cylinder exchange cabinets. Thisproposal seeks to increase the separation distance from building doorways from 5 ft to 40 ft and proposes to require separation between LP-Gas cylinder exchange cabinets and sources of ignition. The proposed value is based on vapor dispersion modeling using software that has been quantified against full-scale releases of a number of hazardous materials.

The separation distance proposed is based on computer modeling of a hypotheticalLP-Gas release from the pressure relief device installed on a 20 lb. vertical propane container. The Austin Fire Department uses the Radian Corporation software CHARM, or Chemical Hazard Airborne Release Model. The software is used by many of the Fortune 500 petrochemical and chemical companies for vapor dispersion modeling of chemical releases° The software allows the user to input variables about the chemical, its container and the environment. Using algorithms based on dense gas, positively-buoyant and negatively-buoyant gas dispersion theorems, the software calculates the dimensions and duration of a vapor release and other variables. The model's physical and thermodynamic values for propane originate from the American Institute of Chemical Engineers Design Institute of Physical Properties or "DIPPER" database. The meteorological data is based on National Weather Service 5-year data averages for normal daylight conditions in Austin, Texas. The container was assumed to be filled in accordance with the volumetric requirements of Section 4-4.4.2. Values for the cylinder and relief valve dimensions are based on manufacturer's data sheets from Manchester Tank Co., and Engineered Controls International Incorporated.

The attached output illustrates the plume for the subject container at 25 percent LFL (5,375 PPM), 50 percent LFL (10,750 PPM) and the LFL (21,500 PPM)for propane, the release scenario is the operation of the cylinder's pressure release device. At the first 3 minutes of the release, the model illustrates that the vapor plume will form a 37 ft deep vapor puff that is at the LFL concentration for propane. After 3 minutes, the puff begins to decay and divide into smaller puffs. As the puffs decay, the boundary of the LFL atmosphere becomes smaller. Based on these results, exchange cabinets for 20 lb. vertical LP-Gas cylinders should be located a minimum of 40 ft from building openings and sources of ignition.

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Note: Supporting material available for review at NFPA Headquarters.

Because many mercantile occupancies are now constructed as retail warehouses, these buildings offer enough area to safely locate cylinder exchange cabinets. The Austin Fire Department has applied this separation distance for LP-Gas cylinder exchange cabinets. Exchange cabinets can be located 40 ft from building openings and ignition sources with little difficulty. At smaller mercantile occupancies like convenience stores, an exchange cabinet may be placed at the front of the store if sources of ignition are relocated and vehicle impact protection is provided. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Committee Action on Comment 58-90 (Log #7).

The use of a container failure model with total release of the contents of a propane container has never been the basis for the distances in NFPA 58. NFPA 58 has based separation distances on a combination of experience and incidents. Exchange cabinets have been in use for 10 years, and the committee is not aware of any incidents to support an increase of separation distances. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: RENFREW: I think 20 ft from an opening or doorway into a

building is sufficient. I do not agree with the submitter on 40 ft. The computer modeling furnished by the submitter is interesting but not a valid basis for 40 ft based on the pressure relief ability and function of the container valves. One day I hope all this computer modeling will be integrated with safety controls and function of systems and stop gmng us worst case unrealistic scenarios.

(Log #45) 58- 92- (5-4.1): Reject SUBMITFER: Wayne Wagner, Tennessee Fire Code Development Committee COMMENT ON PROPOSAL NO: 58-112 RECOMMENDATION: Revise text as follows:

5-4.1 Location of Storage Outside of Buildings. Storage outside of buildings for containers awaiting use, resale, or part of a cylinder exchange point shall be located at least 10 ft from any doorway or opening in a building frequented by the public; 20 ft from any automotive service station fuel dispenser and in accordance with Table 5-4.1 with respect to.

(a) Nearest important building or group of buildings. (b) Line of adjoining property that may be built upon° (c) Busy thoroughfares or sidewalks. (d) Line of adjoining property occupied by schools, churches,

hospitals, athletic fields, or other points of public gathering. (e) Dispensing station. Exception: Cylinders in the filling process shall not be

considered to be in storage. SUBSTANTIATION: Cylinder exchange point added to this section. In summary all types of storage should be at least 10 ft away from entrances used by the public and 20 ft from fuel dispenser in the event of a building fire (and emergency egress involved) or if fire in area of a fueldispenser (radiant hea t )or the storage. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Committee Action on Comment 58-90 (Log #7). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: RENFREW: See my Explanation of Negative on Comments 58-89

(Log #4), 58-90 (Log #7), and 58-91 (Log #116). The Committee is rejecting several different requests from fire departments all over the United States. I hope this issue resurfaces again the cycle of the standard.

(Log #32) 58- 93 - (5-4.1 (New)): Reject SUBMYITER: Gregory G. Victor, Glendale Fire Department COMMENT ON PROPOSAL NO: 58-112 RECOMMENDATION: Add revised text to the submitter's language as follows:

5-4.1 Location of Storage Outside of Buildings. Storage outside of buildings for containers awaiting use resale or part of a cylinder exchange point shall be located at least -1-# 20 ft. From any

232

N F P A 58 - - F 9 7 R O C

doorway or opening in a building frequentea.a- b 7 the FubP.c; 20 ft. from any automotive service station fuel dispenser and in accordance with ...balance to remain the same. SUBSTANTIATION: Twenty ft is a more appropriate distance for separation of LPG corttainers from an exit. The people in the building deserve a sail; egresspathway. Section 5-2.3.1 states that containers shall not be locatect near exits. Near is not defined therefore the distance is left up to the AHJ. I am sure that most AHJs will find that 5 ft is too close inside a building so why should it be acceptable on the other side of 1/4 in piece of glass? Propane vendors want these cages in the front of thebuilding for marketing reasons but 1 see no reason why they can't be located on the side or rear of the building instead of next to exits, ignition sources such as ice machines and pop machines. I would be interested in finding out where the original distances came from. Is there any testing that has been done by the NFPA to justify such close distances?

Regarding deleting £he words "frequented by the public" the hazard is the same without regard to who is using the building. Workers in the building deserve the same protection as the public does. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Committee Action on Comment 58-90 (Log #7). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: RENFREW: See my Explanation of Negative on Comments 58-89

(Log #4), 58-90 (Log #7), and 58-91 (Log #116). Another request from a fire deparmaent for the separation distance to be 20 ft. I agree.

(Log #43) 58- 94- (6-3.4): Accept SUBMITTER: Bruce Swiecicki, Nat'l Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-117 RECOMMENDATION: The NPGA wishes to endorse Mr. McTier's comments on this proposal as they are printed in the ROP. SUBSTANTIATION: None. COMMITTEE ACTION: Accept. COMMITTEE STATEMENT: The Committee thanks the subitter for the comment. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMI'IqTEE ACTION:


EXPLANATION OF NEGATIVE: RENFREW: Mr. Mocfimer is right (no change, frivolous). This

does not even qualify ,.as a proposal. MORTIMER: Comments should he rejected. No

recommendation or changes being made. Comment is frivolous and Committee Action to Accept does nothing but promote similar comments in the future.

(Log #CC13) 58- 95 - (8-2.3): Accept SUBM1TTER: Technical Committee on Liquefied Petroleum Gases COMMENT ON PROPOSAL NO: 59-123

I RECOMMENDATION: Revise the proposed a new second paragraph to 8-2.3(a)3 to read as follows:

(3) Systems complying with the provisions of 3-11.3 shall have a water and weather resistant label placed near the bleeder valve with the following text: "Do not use fixed maximum liquid level gauge at ultra low emission transfer stations." SUBSTANTIATION: Editorial revision for clarity. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITFEE ACTION:


(Log #69) 58- 96 - (Chapter 9): Accept in Part SUBMITTER: Bruce Swiecicki, Nat'l Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-126 RECOMMENDATION: Revise Section 9-1.1.1 as follows:

9-1.1.1 Containers designed to overate at Creater than 15 nsi foF ' ~ . . . . . . . . . . . . shall be ~ i n accordance with the/~SME Boiler and Pressure Vessel Code, Section VllI.,,,(remainder unchanged)

Revise Section 9-5.2 and Table 9-5.2 to be consistent with API Standard 2510. For example, API permits reductions in distances if supplemental protection is provided.

Revise Section 9-6: 9-6 Reinstallation of Refrigerated Containers. Once installed,

containers that have been out of service for more than one year shall not be put back in service unless they successfully withstand, without distortion, h)~r~.~mSc pressure retests...(remainder unchanged) SUBSTANTIATION: The changes to Section 9-1.1.1 will make this section consistent with Section VIII of the Boiler and Pressure Vessel Code (see U-1 (c) (8)).

The change to Section 9-5.2 and Table 9-5.2 will make NFPA 58 consistent with nationally recognized standards which are already existing.

The change to Section 9-6 will remove a required hydrostatic pressure test and allow the use of propane vapor or other medium. Hydrostatic test are unnecessary for refrigerated vessels, and their use increases complications due to the introduction of moisture to the container, which can lead to contaminated product and corrosion. COMMITTEE ACTION: Accept in Part.

1. Revise Section 9-1.1.1 to read: 9-1.1.1 Containers designed to operate at greater than 15 psi shall

be designed and constructed in accordance with the ASME Boiler and Pressure Vessel Code, Section VllI....(remainder unchanged). COMMITTEE STATEMENT: The proposed revisions to 9-1.1.1 are accepted with an editorial revision. The proposed revision to 9-6 is rejected as the paragraph is deleted in Comment 58-100 (Log #CC1). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #71) 58- 97 - (Chapter 9): Accept in Principle SUBMITTER: P.E. Duus, Steel Plate Fabricators Association Inc. COMMENT ON PROPOSAL NO: 58-126 RECOMMENDATION: This chapter should include requirements for relief devices and reference to Appendix E. SUBSTANTIATION: Chapter 9 does not contain any requirements for relief devices. COMMITTEE ACTION: Accept in Principle. COMMITTEE STATEMENT: Refer to Commmittee Comment on 58-100 (Log #CC1). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


(Log #101) 58- 98 - (Chapter 9): Accept in Principle in Part SUBMITrEl~ Bruce Swiecicki, Natl Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-126 RECOMMENDATION: Revise Section 9-1.1.1 as follows:

9-1.1.1 Containers designed to overate ~t greater than 15 osi 1~ p~'~ or greater shall be O..¢,i~.II~'in accordance with the #~SME Boiler and Pressure Vessel Code, Section VIII,...(remainder unchanged)

Revise Section 9-5.2 and Table 9-5.2 to be consistent with API Standard 2510. For example API permits reductions in distances if supplemental protection is provided.

Revise Section 9-6: 9-6 Reinstatlation of Refrigerated Containers. Once installed,

containers that have been out of service for more than one year shall not be put back in service unless they successfully withstand, without distortion, h)'dr~:vaSc pressure retests...(remainder unchanged)

233

N F P A 5 8 - - F 9 7 R O C

S U B S T A N T I A T I O N : T h e changes to Sect ion 9-1.1.1 will make this sect ion consis tent with Section VIII of the Boiler a n d Pressure Vessel Code (see U-1 (c) (8)).

The change to Section 9-5.2 and Table 9-5.2 will make NFPA 58 consis tent with nat ional ly recognized s tandards which are already existing.

The change to Sect ion 9-6 will remove a requ i red hydrostat ic ressure test and allow the use of p ropane vapor or o the r m e d i u m . ydrostatic tests are unnecessa ry for refr igerated vessels, a n d their

use increases complicat ions due to the in t roduc t ion o f mois ture to the container , which can lead to con tamina ted p roduc t and corros ion. COMMITTEE ACTION: Accept in Principle in ParL COMMITTEE STATEMENT: Refer to Commi t tee Action on C o m m e n t 58-96 (Log # 69) for act ion on 9-1.1.1. N U M B E R OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 28 V O T E O N COMMITTEE ACTION:


(Log #117) 58- 99 - (Chapter 9): Accept in Principle SUBMITTER: J ame s H. Stannard , Jr . , S tanuard & Co. COMMENT O N PROPOSAL NO: 58-126 RECOMMENDATION: Add A p p e n d i x E of NFPA 59 to NFPA 58. S U B S T A N T I A T I O N : The new Chapte r 9 of NFPA 58 is i n t ended to cover refr igerated p ropane a n d also ma tch the language of NFPA 59.

Append ix E of NFPA 59 was inadvertent ly omitted. COMMITTEE ACTION: Accept in Principle. COMMITTEE STATEMENT: Refer to Commi t t ee C o m m e n t on 58-100 (Log #CC1). N U M B E R OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 28 V O T E O N COMMITTEE ACTION:


(Log #CC1) 58- 100 - (9-2.5 and 9-2.6): Accept SUBMITTER: Technica l Commi t t ee on Liquefied Pe t ro leum Gases COMMENT O N PROPOSAL NO: 58-126 RECOMMENDATION: 1. Delete 9-6.

2. Revise 9-2.5 to read: The internal pressure a n d vacuum of refr igerated LP-Gas

conta iners shall be ma i n t a i ned within the limits establ ished in the design specification. T he des ign of pressure control means shall inc lude the following fai lure modes:

a. For pressure: 1. Loss of refrigeration. 2. Opera t ional upset, inc lud ing failure of control devices. 3. Vapor d i sp lacement a n d flash vaporizat ion du r i ng filling, as a

resul t o f filling, and control led mix ing or p u m p recirculat ion of d i f ferent compos i t ions and tempera tures .

4. Drop in a tmospher ic pressure° 5. Fire exposure. 6. Flash vaporizat ion resul t ing f rom p u m p recirculation.

b. For vacuum: 1. Withdrawal of liquid or vapor at the m a x i m u m rate. 2. Rise in a tmospher i c pressure. 3. Reduct ion in vapor pressure as a result of in t roduct ion of

subcoo led LP-gas. 3. Add a new 9-2.6 to read:

9-2.6 The m i n i m u m start to discharge o f air f r om a pressure relief valve at 120 percen t o f the m a x i m u m permissible start-to- d ischarge pressure = requ:.re~ :'~ Table 2 ~.2.~ shall be c o m p u t e d us ing the following formula:

633'000FA° s2 ~---~ LC Qa =

Where:

O~ = m i n i m u m requi red flow capacity of air, in cu ft per min , at 60°F and 14.7 psia.

F = A composi te env i ronmenta l factor, as tabula ted in Table 9- 2.6.A. To receive credit for r educed hea t input , the insulat ion shou ld resist d i s lodgmen t by fire hose s t reams, shou ld be noncombus t ib le , and shall no t decompose at t empera tu res up to 1,500°F (816°C). If insula t ion does n o t comply with these criteria, the env i ronmenta l factor, F, for a hare conta iner shou ld he used.

A = Total exposed wetted surface, in sq ft. For a vertical conta iner the wetted area shall be equal to the total surface area of the shell up to a he igh t of 30 ft (9.1 m) above grade

L = La ten t hea t of p roduc t at the flow rat ing pressure, Btu/Ib. (The latent hea t of pu re p ropane at a tmospher ic pressure is 183.5 B t u / l b a n d of iso-butance is 157.8 Btu / lb )

C = Cons tan t for gas or vapor related to specific heats (k=Co/Cv) at 60°F (16°C) a n d 14.696 psia (an absolute presusre of 101o325 kPa). (The ratio of specific hea t (k) is 1.13 and C-330 for pure p ropane a n d k=l.10 and C=316 for bu tane) .

Table 9-2.6A Environmental Factors Insula t ion Factor F Bare conta iner 1.0 Insulated conta iners with the following typical conduc tance values, k, in Btu per h r per sq ft per degrees Fahrenhei t , based on 1,600 degrees Fahrenhe i t t empera tu re difference: k = 4.0, Btu per h r per sq ft per °F 0.3 k = 2.0, Btu per hr per sq ft per °F 0.15 k = 1.0, But per hr per sq ft per °F 0.075

Z = Compressibil i ty factor at flowing condit ions. = Absolute t empera tu re at flowing condit ions.

M = Molecular weight of gas.

Table 9-2.6B Chart for Gas Constant "C"

Constant Constant Constant k C k C k C

1.00 315 1.26 343 1.52 366 1.02 318 1.28 345 1.54 368 1.04 320 1.30 347 1.56 369 1.06 322 1.32 349 1.58 371 1.08 324 1.34 351 1.60 372 1.10 327 1.36 352 1.62 374 1.12 329 1.38 354 1.64 376 1.14 331 1.40 356 1.66 377 1.16 333 1.42 358 1.68 379 1.18 335 1.44 359 1.70 380 1.20 337 1.46 361 2.00 400 1.22 339 1.48 363 2.20 412 1.24 341 1.50 364

4. Revise 9-5.2 to read: Spacing of refr igerated p ropane conta iners f rom impor tan t

buildings, s torage conta iners for f l ammable or combust ib le liquids and lines of ad jo in ing property that can be buil t upon , shall be in accordance with Table 9-5.2.

5. Revise Table 9-5.2 to read:

Table 9-5.2 Minimum Distances

Water Capacity per Container , Gallons

(m s) Up to 70,000 (265) 70,001 to 90,000 (265 to 341 m s) 90,001 to 120,000 (341 to 454 m s) 120,001 to 200,000 (454 to 757 m s) 200,001 to 1,000,000 (757 to 3785 m s) Over 1,000,000/3785 m s)

Aboveground Conta iners

75 ft (23 m) 100 ft (30 m) 125 ft (38 m) 200 ft (61 m) 300 ft (91 m)

400 ft (122 m)

S U B S T A N T I A T I O N : Revisions are m a d e to the p roposed new Chapter 9 to correct errors a n d include n e e d e d material on relief valve sizing. COMMITTEE ACTION: Accept . N U M B E R OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 28 V O T E O N COMMITTEE ACTION:


2 3 4

N F P A 58 - - F 9 7 R O C

(Log #12) 58- 101 - (A-2-2.6.4): Reject SUBMITTER: R. E. Thatcher, R. E. (Dick) Thatcher & Assoc. COMMENT ON PROPOSAL NO: 58-131 RECOMMENDATION: Recommend the example (shown below) in A-2-2.6.4 be retained and revised to reflect the current document. SUBSTANTIATION: The confusion concerning the content of warning labels has been substantially reduced since the example was introduced in 58-92. This ANSI approved decal is required on any cylinder used as a part of a listed assembly without any change. This example may be used by other after market suppliers as a guide to producing their own decals.

While the decal char~ge may not be within the same cycle as NFPA 58, neither are :many other changes to referenced codes and standards. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The committee believes that to show an example label in the standard is inappropriate due to the factors involved in attempting to satisfy the multitude of requirements needed to properly convey all information regarding all aspects of propane safety. Many of these are mandated outside this standard.

The committee notes that some cylinders are permitted in buildings not open to the public, and the current label in the

~ x prohibits this use. R OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28

VOTE ON COMMITTEE ACTION: AFFIRMATIVE: 25 NEGATIVE: 2 NOT RETURNED: 1 Van Hook

EXPLANATION OF NEGATIVE: ADAMS: In my opinion the deletion of the example of a warning

label on cylinder will be a reduction of life and fire safety requirements of the standard. If a label design is unsatisfactory, then at least a list of mffety concerns to be placed on a label should be shown. This Comment should have been accepted and not rejected. I also embrace, as a reason for my negative vote on the committee action, the substantiation by RonaldJordan of the US Consumer Products Safety Commission in Comment 58-107 (Log #59) and his recommendation proposed on Comment 58-106 (Log #58).

LAMAI~ Appendix A-2-2.7.4, Proposal 58-131. This explains my negative Ballot on the Committee action which rejected Logs 12, 22, 24, 28, 51, 58 and 59. These are all comments seeking to retain the ~ of a suitable warning to be attached to refillable containers such as those used on barbeque grills, and as required in Section 2-2.6.4. The information provided in this example is very important for the safety of persons filling or owning or usin~

or storin~ containers with highly flammable LP-gas under high e.- As pointed out on page 73 of the LP-GASES OOK, the information does not have to be in the exact

words or format shown, but it comprises about 50 lines plus illustration. I believe it is imperative that such as illustration be in NFPA 58. Otherwise those seeking to comply with Section 2-2.7.4 and those checking for compliance will have no way of knowing what is intended. Attached is a copy of Log 59 as submitted by U.S. Consumer Product Safety Commission which urges rejection of the Proposal to delete this figure.

Also see the correspondingwarning label on page 55 of ANSI z21.58-1995 covering OUTDOOR COOKING GAS APPLIANCES. It is identical in most respects to the illustration in A-2-2.6.4. It is up-dated to cover all of the current configurations of valves on such containers. I recommend that it be adopted to replace the Pthresent example. (Exception: the word "(optional)" as related to

e fixed liquid level gauge should not be includ~;~t, as proposed changes in NFPA 58 require this means for checking the level of liquid during or after the filling of the container.)

(Log #22) 58- 102 - (A-2-2.6.4): Reject SUBMITTER: Charles C. Lamar, Lamar Consultants, Inc COMMENT ON PROPOSAL NO: 58-131 RECOMMENDATION: Reject proposed deletion of Figure A-2- 2.6.4; delete asterisk from Section 2-2.6.4 on page 13 of 1995 edition and add wording "See Appendix A-2-2.6.4f SUBSTANTIATION: Figure A-2-2.6.4 (on page 58-73 of 1995 edition, per copy attached) is needed to illustrate the WARNING information ~ in Section 2-2.6.4 for safety of persons filling or owning or using or storing containers with highly flammable LP+Gas under high pressure. (The asterisk next to the section number is too often ignored or misunderstood, so "See Appendix A-2-2.6.4" should be substituted). COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Committee Action on Comment 58-101 (Log #12). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: ADAMS: See my Explanation of Negative on Comment 58-101

(Log #12). LAMAR: See my Explanation of Negative on Comment 58-101

(Log #12).

D A i ~ E R • FLAMMABLE GAS UNOER PHE~URE o LEAKING L,P.GAS MAY CAUSE A FIRE OR EXPLOSK)N IF IGNI]£D m CONTACT LP.G~ SUPPER ~131~P~RS OR DiSPOSAl. OF THIS CYLINDER OR UNUSED LP~IS

• FQR OU~OOR USE ONLY* e DO NOT USE OR SIOP~ CYLINDER IN A BULDII~ GARAGE 08 ENCLOSED AREA cu~roM~ WARNING1 WHWIA ¢OIINECrIN6 FOR U~[, , I(+ow the ¢+ ol Lg~s. I you I~, su or sael l~mO Lt,G,~, Jn'6dde ~ * Usa ody in <:ompL,~ ~b~ ~ code

9| l~Oqnw~bmkcVFmd~' lnd~kFwDq~dton V. ~P, zilaildfdlwtmaa~c~ ~divctU~ ~ m ~ m ~ m a

. ~ ytu.P~t ~p~, Io~ . . . . . . . ~v~mdor m i.ovidm, wim.~ a~moe.

Be +cram ~er m+Jmm oa~o i~ d~Ockod. +Oc not ~ck ~ Om I.i~ wi~ z mtck o opm m + ~ ~ _ ~ . .

c ~ ~d~ces ~ be ~ I Io z cyi~ d 20 k c~ly +i~ ~ m '

M+l~"r'+mm+Y ~+m*m" ~ m ° e r'+dmm~m~°"c'm*' + ~ ~ ' m is m m~e, ~ m o+mer

DO HOT. MO , DEFACE OR OBLITERATE IIS I'EXCEPT AS AUTHORIZED BY/ 'I/+PA 58 or CAN,'CGA-B149,2

235

N F P A 5 8 - - F 9 7 R O C

COMMENT ON AFFIRMATIVE: RENFREW: I made the motion to reject this Proposal because I

think putting "the Label" in the standard is not good because different cylinder uses and applications require changes to a safety warning label. Plus, this is an issue between CPSC and the manufacturers of cylinders to provide adequate safety warning labels. This issue bring the standard into a position of being involved in liability case over issues like - is the warning label sufficient. The Committee has no expertise in that area. Adding "THE LABEL" sounds like a good idea, but it is not appropriate for the standard.

(Log #24) 58- 103 - (A-2-2.6.4): Reject SUBMITTER= J o h n Cedervall, Deerfield, IL COMMENT ON PROPOSAL NO: 58-131 RECOMMENDATION: Revise wording of A-2-2.6.4 as follows:

A-2-2.6.4 A -~o~.~!c ;'?~='=g l=Sc! ~ ! L g l l g d l l P ~ warning label, which is intended for use with gas grill cylinders, is shown in Figure A-2-2.6.4. SUBSTANTIATION: Rather than deleting the information given in Fig. A-2-2.6.4, the reference should clearly indicate that i t is shown only as an example, ffA-2-2.6.4 is deleted, the requirement of 2-2.6.4 needs to provide some guidance as to what is meant by "...the potential hazards of LP-GAS." COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Committee Action on Comment 58-101 (Log #12) where the deletion of the label is affirmed. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:



(Log #12). LAMAR: See my Explanation of Negative on Comment 58-101

(Log #12).

(Log #28) 58- 104- (A-2-2.6.4): Reject SUBMITTER: Charles C. Lamar, Lamar Consultants, Inc COMMENT ON PROPOSAL NO: 58-131 RECOMMENDATION: Reject proposed deletion of Figure A-2- 2.6.4; delete asterisk from Section 2-2.6.4 on page 13 of 1995 Edition and add wording "See Appendix A-2-2.6.4" SUBSTANTIATION: Fi~ure A-2-2.6.4 (1995 Edition) is need to illustrate the WARNING reformation Le,.q.!Lix~ in Section 2-2.6.4 for safety of persons filling or owning or using or storing containers with highly flammable LP-gas under high pressure• (The asterisk next to the section number is too often ignored or misunderstood, so "See Appendix A-2-2.6.4" should be substituted)

~ E P ~ F L A ~ A a L E ~ UNDER PRESSURE

COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Refer to Committee Statement on Comment 58-101 (Log #12). NUMBER OF COMMITTEE MEMBF.a~ ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:



(Log #12). ~ See my Explanation of Negative on Comment 58-101

(Log #12).

(Log #51 ) 58- 165 - (A-2-2.6.4): Reject SUBMITTER: Ronald Jordan, U.S. Consumer Product Safety Commission COMMENT ON PROPOSAL NO: 58-131 RECOMMENDATION: Revise the statement of hazard section in Figure A-2-2.6.4 as follows:

"DANGER-EXTREMELY FLAMMABLE COMPRESSED GAS. LEAKING LP-GAS MAY CAUSE A FIRE OR EXPLOSION IF IGNITED. CONTACT WITH THE LIQUID CONTENTS OF THIS CYLINDER WILL CAUSE FREEZE BURNS TO THE SKIN"

Separate the remainder of the labeling which presently appears in capital letters associated with the word "DANGER" from the specific labelingquoted above by at least two spaces or incorporate as bullets under "CUSTOMER WARNING." SUBSTANTIATION: This is the labeling agreed to by the NLPGA during negotiations with CPSC in 1984 and 1985. This labeling satisfies the requirements of the FHSA. The position stated herein is that of the Commission staff. It has not been reviewed or

roved by the Commissioners. ITI'EE ACTION: Reject.

COMMITTEE STATEMENT: The committee has affirmed its decision to delete the label in Comment 58-101 (Log #12). NUMBER OF COMMITTEE MEMBERS ELIGIBLETO VOTE: 28 VOTE ON COMMITTEE ACTION:



• See my Explanation of Negative on Comment 58-101 (Log #12).

L t A K I N ~ I L r - O A ~ M A y O A U ~ , I ~ ^ FIRI O f l E X P L O ~ I O I t iF I ( I I~ I ITI~D C O N ' I r A C l r 1.8).~GIAI~ I U P I ~ L l l i l I : I I ~OR I I l l l ~ A l a l . OSl I l l . I r o n i C A L O1~ ~ 1 4 i I ~VILJItMDaMI o l a U tM IU I I aO L I L ~ I A S l

l l d l~T U K ~ a l r O I r t E OVUlU41~; ;R I~NI i~ BUILOIH4~I. O A I ~ O E * O R E N O L O E a O ~J~l~..*q,

O t , - t ~ T O ~ E P I WAI~h4 I I ~ l :

L r - ~ J a a , I~ln~KJ~ROly ~O~ o v e ~ l a w a y ffot~l 8ho ¢ y ~ R d a r .m¢l ¢~H th~ Fb~ Dml=,~l~xlot, l. O o n o t e U ~ l r ~ h m .

O e c ~ a m ~ 10 ~ e ~ t h e c y l k l d e r .

©1~1~, II,I~ZO I ~ a ~ t h e ~ 1 ~ .

~ e ~ ~o a o / W n d ~ o~ ~ 0 ~ ~ p n c ~ y or Jess.

~ - - o d to ~ ~i~lllrll~Irll|l.IT4~I. P I i a o l VdlllV'll~ ~n~1~ly IOII~IIN.

l~q-4G~ ( :~ [ : ) l k IN I ; ; ;OY l~ ICOR U a E : " U~ ~ In r . o r r l l ) l l l m ~ i w l I h I Oo(14mL • R e a d m ~ f ~ w m a n ~ ; ~ ~ s • o m ~ m w ~ h ~ a 8 m ~ n Q row. ~ m w m ~ - ~ q ~ d ~

• Turn off aI ~ e B on ~,e app~en~e. • ~ n ~ ~ ~ 9 1 a ~ k e ~ I m l ~ ~ ~ k _ A ~ 9 ~ a p y

wet • i f " eel 4 l ~ l ~ l r n l r l 4 I d " X . " ~ G Y ~ W4II~II. N ll~dl4a4~lw i i i~El Ie t r lL e k m e v i l ~ , e ~ d kttq~D L P ~ ~ ~ ~ n ~ ~ . A l i a . o I l m I = l a l I I I l I r I C e V I ~ r I I I I a ~ l I I I I / e i I i d o n o t I N k h i m t a i n t i n g a g s p l l ~

236

NFPA 58 - - F97 ROC

(Log #58) 58- 106 - (A-2-2.6.4): Accept in Principle SUBMITTER: Ronald Jordan, U.S. Consumer Product Safety Commission COMMENT ON PROPOSAL NO: 58-131 RECOMMENDATION: Add the following paragraph to the "Federal Regulations" section under the "Foreward"on page 58-5 Of NFTA 58:

"The Federal Hazardous Substances Act (15 U.S.C. 1261) requires cautionary labeling of refillable portable tanks of flammable and extremely flammable liquefied petroleum gases distributed for consumer use. They are typically 40 pounds and less, used with gas barbeque grills, portable lanaps, camp stoves, and heaters. The Federal Hazardous Substances Act is administrated by the U.S. Consumer Product Safety Commission under regulations codified at 16 CFR 1500. An example of the specific cautionary labeling is referenced elsewhere in this standard." SUBSTANTIATION: This "Foreward" does not acknowledge the Federal Hazardous Substance Act (15 U.S.C. 1261). Inclusion of this paragraph inforrm the reader that the warning label provision for portable cylinders in Section 2-2.6.4 and content illustrated in Figure A-2.2.6.4 are required by federal law. The position stated herein is that of the Commission staff. It has not been reviewed or approved by the Commissioners. COMMITTEE ACTION: Accept in Principle.

Add the following to the th i rdparagraph of the foreword: The Federal Hazardous Substances Act (15 U.S.C. 1261) requires

cautionary labeling of refillable cylinders of liquefied petroleum gases distributed for consumer use. They are typically 40 pounds and less, used with outdoor cooking appliances, portable lamps, camp stoves, and heaters. The Federal Hazardous Substances Act is administrated by the U.S. Consumer Product Safety Commission under regulations codified at 16 CFR 1500. COMI~'VrEE STATKMENT: The comment is accepted with editorial changes. The last sentence is deleted as the label has been deleted. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:



• See my Explanation of Negative on ~:omment 58-101 (Log #12).

LP-gas cylinders required by the FHSA. This label was developed by CPSC staff and the National LP Gas Association (NLPGA) for the purpose of adequately warning consumers and marketers of the hazards associated with the use of LP-gas. The position stated herein is that of the Commission staff. It has not been reviewed o r

roved by the Commissioners. ITTEE ACTION: Reject.

COMMITTEE STATEMENT: Refer to Committee Action on Comments 58-101 (Log #12) and 58-106 (Log #58). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:



(Log #12). LAMARz See my Explanation of Negative on Comment 58-101

(Log #12).

(Log #73) 58- 108 - (Appendix E): Accept in Principle SUBMITTER: P.E. Duns, Steel Plate Fabricators Association Inc. COMMENT ON PROPOSAL NO: 58-152 RECOMMENDATION: Adopt notes 1, 2 and 3 from Table 3 in API 2000 which limit the exposed area to a height of 30 ft above

~IJ'BS'TANTIATION: NFPA 58 (and 59) require relief valves to be sized based on the entire wetted surface of the vessel. For large vessels .and tanks this results, in very large relieving capacities, bordenng on the impracucal. Such large releases of vapor may well present a hazard greater than the hazard it is intended to mitigate• COMMITTEE ACTION: Accept in Principle. COMMITTEE STATEMENT: Refer to Committee Action on Comment 58-100 (Log #CC1). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: PAKRUDA= See my Explanation of Negative on Comment 58-9

(Log #62).

(Log #59) 58- 107 - (A-2-2.6.4): Reject SUBMITTER: Ronald Jordan, U.S. Consumer Product Safety Commission COMMENT ON PROPOSAL NO: 58-131 RECOMMENDATION: Reject the proposal to delete Figure A-2- 2.6.4, "A sample cylinder warning label. Update the pictorial on the sample label to include Type 1 and Type 2 fittings and any other new requirements of NFPA 58 that affect the label. SUBSTANTIATION: CPSC staff opposes the deletion of Figure A-2-2.6.4 from NFPA 58. A warning label is required on portable LP-gas cylinders by the Federal Hazardous Substances Act (FSHA), 15 U.S.C. 1261(p)(1). Figure A-2-2.6.4provides the only guidance in NFPA 58 on the content of warning labels for portable

(Log #70) 58- 109 - (Appendix F): Accept in Principle SUBMITTER: Bruce Swiecicki, Nat'l Propane Gas Assn. COMMENT ON PROPOSAL NO: 58-133 RECOMMENDATION: Comment # h Revise the action as follows:

F-4.2.1 Containers equipped with fixed maximum liquid level gauges, c'.-c~l!'=g Frc:'czt2cn dc-'ccz, or with variableliquid level gauges, when temperature determinations are not practical, can be filled ud!'z~ng a'=)- c.= of ".l'hc=c de ' . 'c~ with either gauge provided that the fixed maximum liquid level is installed, cr ~ c ~.;-c===:!!'ng v . . . . . . . . . . . . . . . . . . . . . . . ~ . . . . . or the variable gauge is set, to indicate the volume equal to the maximum permitted filling limit as provided in 4-4.3.3(a). The level is computed on the basis that the liquid temperature will be 40°F, for aboveground containers or 50F for underground containers.

Ggmmen~ #2: Create an new Section F-4.3.4: F-4.3.4 When installing an overfilling prevention device on a

portable cylinder for vapor service having a capacity of 4 lb. through 40 lb., the following table shown o n p a g e 238 shall apply. SUBSTANTIATION: Comment 1: The OPD has not been proposed as a primary filling device. Without acceptance of this comment, the proposed new F-4.2.1 would regard the OPD as a primary filling device.

237

N F P A 58 - - F 9 7 R O C

Table F-4.3.4 This Table was developed to indicate the proper fixed liquid level gauge to be used in each

cylinder. The Table is not intended to cover each cylinder design for configuration. It is imperative that the user of the Table know the cylinder design specifications.

CYLINDER SIZE 4.25#

5# 6# 10# 11# 11.5 2O# 25# 30# 4O# 6# 10#

30# 4O#

MATERIAL Steel Steel Steel Steel Steel Steel Steel Steel Steel Steel

Aluminum Aluminum Aluminum Aluminum Aluminum

CYLINDER I.D. (Inches)

8.9 8.0 6.0 8.9 8.9 12.0 12.0 12.0 12.0 12.0 6.0 10.0 12.0 12.0 12.0

CYLINDER WATER

CAPACITY (Lbs) 10.2 11.9 15.5 26.1 26.2 27.3 47.6 59.7 71.5 95.3 15.0 23.6 47.7 71.5 95.3

RECOMMENDED DIP TUBE

LENGTH {Inches) 2.2 2.6 3.2 3.6 3.5 2.9 3.8 4.5 4.7 6.5 4.5 3.8 4.6 5.8 7.0

Note: The user of this table is urged to contact the actual manufacturer of the cylinder to assure the proper length tube for each cylinder.

Comment 2: The new table in Appendix F is to reduce the opportunity for errors in dip tube length during the retrofit installation process. In addition to providing a uniform dip tube length for cylinders undergoing requalification, the proposal will also permit the safe installation of a used valve on another cylinder. Note: The major cylinder manufacturers are currently verifying the dimensions in Table F-4.3.4. It may be necessary to revise the table at the June meeting of the Technical Committee. COMMITTEE ACTION: Accept in Principle.

1. Accept the proposed revision to F-4.2.1. [ 2. Add a new F-4-3.4 to read: I F-4-3.4 The following table can be used to determine minimum [ dip tube length when installing an overfilling prevention device on [ cylinders for vapor service. I 3. Revise the proposed Table F-4-3.4 to read:

COMMITTEE STATEMENT: The proposal is accepted with editorial changes. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: VOTE ON COMMITTEE ACTION:


COMMENT ON AFFIRMATIVE: PETRU: Refer to L. Pakruda's Comments.

28

Table F-4.3.4 This Table indicates the approximate fixed maximum liquid level gauge dip tube lengths to be used for retrofitting

cylinders with valves incorporating an overfilling prevention device. The table does not cover every cylinder design or configuration.

CYLINDER SIZE 4.25#

5# 6# 11# 11.5 20# 25# 36# 40# 6# 10# 20# 30# 40#

MATERIAL Steel Steel Steel Steel Steel Steel Steel Steel Steel

Aluminum Aluminum Aluminum Aluminum Aluminum

CYLINDER I.D. (Inches)

8.9 8.0 7.5 8.9 12.0 12.0 12.0 12.0 12.0 6.0 10.0 12.0 12.0 12.0

CYLINDER WATER

CAPACITY (Lbs) 10.2 11.9 15.5 26.2 27.3 47.6 59.7 71.5 95.3 15.0 23.6 47.6 71.5 95.2

Note: The user of this table is urged to contact the actual manufacturer of the cylinder tube for each cylinder.

RECOMMENDED DIP TUBE

LENGTH (Inches) 2.2 2.6 3.2 3.8 3.2 ~.8 4.7 4.7 6.4 4.7 3.8 4.7 5.8 7.0

to assure the proper length

238

N F P A 58 - - F 9 7 R O C

(Log #76) 58- 110 - (F-4-2.1): Reject SUBMITTER: A.F . Dyer, A.F. Dyer Consul t ing Service COMMENT ON PROPOSAL NO: 58-133 RECOMMENDATION: Revise the seventh line o f the p roposed wording to read, "- -prevent ion device (if it operates on a volumetr ic basis) is des igned, or the variable gauge is set, to--" SUBSTANTIATION: T h e text p roposed for F-4.2.1 in 58-153 obviously assumes tha t all OPDs w i t operate on a volumetr ic basis. This is correct for those on the marke t today. However, I unde r s t and tha t a s imple OPD that will opera te on a weight (filling density) basis is abou t ready for field test ing & demons t ra t ion . My p roposed change would allow for such a device, wi thout det ract ing f rom the criteria for the volumetr ic OPDs. It would be a shame for the "97 edi t ion of 58 to effectively prohibi t an OPD that may become available at abou t the same time. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: T he cur ren t r e q u i r e m e n t does no t l imit fil l ing to a volumetr ic basis. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION:


Errata Corrections to the F97 R OP

The Technica l Commi t t ee on Liquefied Pe t ro leum Gases notes the following errata changes to Proposal 58-103 (Log #CP38):

L = filling limit f r om Table 4-4.2.1 F = correct ion factor to correct vo lume at t empera tu re "t" to

60°F (16°C), f rom Table 4-4.2.2(al.

d. Delete 9-6.

Editorial Corrections to the F97 ROC

The Technica l Commi t t ee on Liquefied Pe t ro leum Gases notes the following editorial changes to C o m m e n t 58-48 (Log #18). The section is be ing repr in ted he re as an aid to the reviewer.

Proposal 58-61 (Log #57) and C o m m e n t s in the ROC resul t in a new Section 3-2.5 as follows:

3-2.5 Installation of Conta iners on Roofs o f Buildings. With the pr ior approval of the author i ty hav ing jur isdict ion, bui ldings complying with Type I, 443 or 332, or Type II, 222 construct ion as specified i n NFPA 220, S tandard on Types of Building Construct ion, shall be permi t ted to have ASME containers installed, filled, and used on roofs in accordance with the following.

3-2.5.1 LP-Gas conta iners installed on roofs or terraces shall be 2000 gal (7.6 m s) water capacity or less. The aggregate water capacity of LP-Gas tanks installed on the roof or terrace of one bui lding shall no t exceed 4000 gal (15.1 m~).

Exception: Addit ional installations shall be pe rmi t t ed where located 50 ft (15.2 m) apart.

3-2.5.2 An ASME conta iner installed on the roof o f a bui ld ing shall always be filled by two operators, one at the controls of the vehicle supplying LPG, and ano the r at the controls of the tank.

3-2.5.3 T h e fire d e p a r t m e n t shall be advised of each installation of p ropane tanks on a roof.

i 3-2.5.4 Conta iners shall be instal led in external locations only. W h e r e a fill line to the conta iner is required, it shall be located entirely outside the building. The fill connec t ion shall be located at least 8 ft (2.4 m) above g r o u n d level.

3-2.5.5 Containers shall be installed on a level location.

3-2.5.6 The conta iner shall be secured to the bui ld ing structure. The suppor t of the conta iner shall be des igned to the same seismic criteria as the building.

3-2.5.7 The roof on which the conta iner is located shall be able to suppor t the weight of the conta iner filled with water, with the safety marg ins establ ished by the applicable cons t ruc t ion codes.

3-2.5.8 Conta iners shall be located in areas where the re is free air circulation, at least 10 ft (3.0 m) f rom bui ld ing open ings (such as windows a n d doors) , and at least 20 ft (6.1 m) f rom air intakes of air condi t ioning and venti lat ing systems.

3-2.5.9 Locat ion shall permi t the easy access to all valves an d controls a n d m u s t have e n o u g h a rea to pe rmi t the requi red main tenance .

3-2.5.10 The location of the conta iner shall have fixed stairs or ano the r safe m e t h o d to be reached.

3-2.5.11 ff the installation requires the use of more than one container , the distances between containers of Table 3-2.2.2 shall apply.

3-2.5.12 If the conta iner location is h igher t h a n 23 ft (7 m) f ro m the g round , or the filling hose can n o t be observed by the operators in it 's entire length, the conta iner shall have a filling line cons t ruc ted to withstand liquid transfer, a n d it shall have the following appur tenances :

(a) Filling valve, cap, two control, valves, hydrostat ic relief, ven t ing line with control valve.

(b) The liquid filling line shall be pa in ted in red for at least 0.5 ft (0.15 m) at the t ransfer poin t and at the container.

(c) If a vapor re turn l ine is installed, it shall be pa in ted yellow.

2 3 9

report of the committee gerry e. misel, jr., georgia gas ... · allows enclosure by parapets, which...

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