statement of problem and substantiation for public input ... · pdf fileflammable gas piping...

Public Input No. 1-NFPA 56-2014 [ Global Input ]

NOTE: The following Public Input appeared as Rejected but held (Hold) in PublicComment No. 56PS-12 of the A2013 Second Draft Report (ROC) for NFPA 56 and perthe Regs. at 4.4.8.3.1.

Additional Proposed Changes

File Name Description Approved

56PS-12.pdf 56PS-12

Statement of Problem and Substantiation for Public Input

Recommendation: Revise text to read as follows: A.3.3.6 Inert Gas. Users should note that radioactive gases such as radon are not inert in the context of NFPA 56.Inert gases do not react readily with other materials under normal temperatures and pressures. For example, nitrogen combines with some of the more active metals such as lithium and magnesium to form nitrides, and at high temperatures it will also combine with hydrogen, oxygen, and other elements. The gases neon, krypton, and xenon are considered rare due to their scarcity. Although these gases are commonly referred to as inert gases, the formation of compounds is possible. For example, xenon combines with fluorine to form various fluorides and with oxygen to form oxides; the compounds formed are crystalline solids. [55, 2010] Substantiation: Radon is inert under the definition provided. However, it is radioactive and is therefore not considered inert for the purposes of NFPA 56.

Submitter Information Verification

Submitter Full Name: TC on GPS-AAA

Organization: TC on Gas Process Safety

Street Address:

City:

State:

Zip:

Submittal Date: Thu Feb 20 13:32:02 EST 2014

Committee Statement

Resolution: FR-11-NFPA 56-2015

Statement: Updated the reference to most current edition. This included language that radon is an inert butshould not be use.

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

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Type your content here ...

As a member of the Gas Processors Association and an Operator/Designer of natural gasgathering/processing facilities, I would like to offer my support to the NFPA 56 Committee TaskForce Report “Assessment of Oil & Gas Industry issues including gathering lines” as published byJohn Puskar. Specifically the exemption of gathering lines operated in compliance with PHMSA 49cfr 191/192 (DOT 191/192) to NFPA 56 requirements.

Additionally, I would like to recommend NFPA evaluate and accept the equivalency of PSMrequirements found in 29 cfr 1910.119 as being compliant with NFPA 56 requirements.

Scott A. Neil, PE

Vice President Engineering and Tech Services

Corporate Engineering/Chief Corporate Office

[email protected]

Office: 303-605-1977

Mobile: 303-809-2370


See recommendation


Submitter Full Name: Scott Neil

Organization: DCP Midsteam LLC

Street Address:

City:

State:

Zip:

Submittal Date: Fri Oct 24 19:18:43 EDT 2014

Committee Statement

Resolution: These are non-actionable items.


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As a member of the Gas Processors Associa on and an Operator/Designer of natural gasgathering/processing facili es, I would like to offer my support to the NFPA 56 Commi ee Task ForceReport, Assessment of Oil & Gas Industry Issues Including Gathering Lines, published by John Puskar. Specifically the exemp on of gathering lines operated in compliance with PHMSA 49 CFR 191/192 (DOT191/192) to NFPA 56 requirements.

Addi onally, I would like to recommend NFPA evaluate and accept the equivalency of PSM requirementsfound in 29 CFR 1910.119.


Equivalency of PSM requirements found in 29 CFR 1910.119.


Submitter Full Name: Justin Brady

Organization: Chesapeake Energy

Affilliation: GPA

Street Address:

City:

State:

Zip:

Submittal Date: Tue Dec 09 11:12:12 EST 2014

Committee Statement



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NOTE: The following Public Input appeared as Rejected but held (Hold) in PublicComment No. 56PS-14 of the A2013 Second Draft Report (ROC) for NFPA 56 and perthe Regs. at 4.4.8.3.1.

Additional Proposed Changes

File Name Description Approved

56PS-14.pdf 56PS-14


Recommendation: Revise text to read as follows: A.6.1 Pipe cleaning methods and requirements change with the intent of the piping system. The most common cleaning methods for industrial natural gas piping systems, where it is required, is discharging or blowing the piping system down with compressed air. This blowing process is carefully managed and controlled. In other cases, possibly pharmaceutical and or food processing, liquid solvents may be used where the process requirements make this necessary. Substantiation: The committee added clarification on the possible use of solvents in applications particularly sensitive to the presence of impurities.


Submitter Full Name: TC on GPS-AAA

Organization: TC on Gas Process Safety

Street Address:

City:

State:

Zip:

Submittal Date: Thu Feb 20 13:34:33 EST 2014

Committee Statement

Resolution: This content reflected paragraph 6.2.2.


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As a member of the Gas Processors Association and an Operator/Designer of natural gasgathering/processing facilities, I would like to offer my support to the NFPA 56 Committee TaskForce Report, Assessment of Oil & Gas Industry Issues Including Gathering Lines, published byJohn Puskar. Specifically the exemption of gathering lines operated in compliance with PHMSA 49CFR 191/192 (DOT 191/192) to NFPA 56 requirements.”

“Additionally, I would like to recommend NFPA evaluate and accept the equivalency of PSMrequirements found in 29 CFR 1910.119.”


As a member of the Gas Processors Association and an Operator/Designer of natural gas gathering/processing facilities, I would like to offer my support to the NFPA 56 Committee Task Force Report, Assessment of Oil & Gas Industry Issues Including Gathering Lines, published by John Puskar. Specifically the exemption of gathering lines operated in compliance with PHMSA 49 CFR 191/192 (DOT 191/192) to NFPA 56 requirements.”

“Additionally, I would like to recommend NFPA evaluate and accept the equivalency of PSM requirements found in 29 CFR 1910.119.”


Submitter Full Name: Bruce Proctor

Organization: Superior Pipeline Company

Affilliation: supporting Gas Processors Association

Street Address:

City:

State:

Zip:

Submittal Date: Mon Jan 05 17:27:51 EST 2015

Committee Statement



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Public Input No. 12-NFPA 56-2015 [ Section No. 1.1.2 ]

1.1.2 Nonapplication of Standard.

This standard shall not apply to the following items:

(10 * ) Systems regulated by U.S. Department of Transportation (DOT) 49 CFR 191/192 and technicallyequivalent gathering lines.

(1)

(2)

(3)

(4) Fuel-dispensing facilities covered by NFPA 52, Vehicular Gaseous Fuel Systems Code.

(5)

(6)

(7)

(8)

(9)

(10)

(11) Commissioning and maintenance of equipment

(12) Vent lines from pressure relief valves or devices unless such vent lines are also used for purging offlammable gas piping systems

(13)


This is the result of a task force lead by John Puskar and Scott Neil. A complete report from the task force has been submitted to the committee chair regarding this submission.


Submitter Full Name: John Puskar

Organization: Prescient Technical Services LLC

Street Address:

City:

State:

Zip:

Submittal Date: Thu Jan 01 18:40:35 EST 2015

Committee Statement


Statement: Clarify that gathering lines and upstream piping are not in the scope of this document.

* Piping systems covered by NFPA 2, Hydrogen Technologies Code

* Piping systems covered by NFPA 51, Standard for the Design and Installation of Oxygen–Fuel GasSystems for Welding, Cutting, and Allied Processes

* Piping systems covered by NFPA 51A, Standard for Acetylene Cylinder Charging Plants

* Piping systems covered by NFPA 54, National Fuel Gas Code

* Piping systems covered by NFPA 55, Compressed Gases and Cryogenic Fluids Code

* Piping systems covered by NFPA 58, Liquefied Petroleum Gas Code

* LP-Gas (including refrigerated storage) at utility gas plants (seeNFPA 59, Utility LP-Gas Plant Code)

* LNG facilities covered by NFPA 59A, Standard for the Production, Storage, and Handling ofLiquefied Natural Gas (LNG)

* Vehicle fuel dispensers

* Systems regulated by U.S. Department of Transportation (DOT) 49 CFR 100–199


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1.1.2 Nonapplication of Standard.

This standard shall not apply to the following items:

(1)

(2)

(3)

(4) Fuel-dispensing facilities covered by NFPA 52, Vehicular Gaseous Fuel Systems Code .

(5)

(6)

(7)

(8)

(9)

(10)

(11) Commissioning and maintenance of equipment

(12) Vent lines from pressure relief valves or devices unless such vent lines are also used for purging offlammable gas piping systems

(13) (10

*) Systems regulated by U.S. Department of Transportation (DOT) 49 CFR

100–199

(1) 191/192 and technically equivalent gathering lines, distribution, and or transmission lines.


This modification would include deleting sections 7.1.2 and 8.2.1.Sections 7.1.2 and 8.2.1 discuss the possibility of a “plant” being owned by a serving gas utility. It’s not clear what a “plant” is. I believe it was meant to indicate electrical generating plant. However, there is no definition for plant. In my opinion, this is an exemption. First of all, exemptions should not be addressed in the body of the document. Section 1.1.2 Non-application of standard is the place for this. This entire matter is very parallel to the entire discussion regarding the midstream gas processing industry and the task for work related to it. In fact it’s the same issue. In effect the midstream task force work says many gathering lines are technically equivalent to DOT regulated lines and therefore the DOT practices related to purging and safe piping processes should apply. This is the same issue with segments of distribution piping and transmission piping that consist of largely underground sections that might be somewhat long and have few isolation valves. In these cases DOT practices address creating a plan for doing this kind of work. If NFPA 56 does not fit well for these kinds of systems and DOT does then why not require it instead of abdicating to some unknown set of practices that some gas utilities have or do not have? It makes no sense.Hence, this submission slightly changes the original task force for midstream piping systems and by doing so eliminates the need to exempt gas utilities, (7.1.2 and 8.2.1) later in the document.


* Piping systems covered by NFPA 2, Hydrogen Technologies Code

* Piping systems covered by NFPA 51, Standard for the Design and Installation of Oxygen–FuelGas Systems for Welding, Cutting, and Allied Processes

* Piping systems covered by NFPA 51A, Standard for Acetylene Cylinder Charging Plants

* Piping systems covered by NFPA 54, National Fuel Gas Code

* Piping systems covered by NFPA 55, Compressed Gases and Cryogenic Fluids Code

* Piping systems covered by NFPA 58, Liquefied Petroleum Gas Code

* LP-Gas (including refrigerated storage) at utility gas plants (see NFPA 59, Utility LP-Gas PlantCode )

* LNG facilities covered by NFPA 59A, Standard for the Production, Storage, and Handling ofLiquefied Natural Gas (LNG)

* Vehicle fuel dispensers


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Organization: PuskarCo

Street Address:

City:

State:

Zip:


Committee Statement




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Public Input No. 17-NFPA 56-2015 [ Section No. 2.2 ]

2.2 NFPA Publications.

National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471.

NFPA 2, Hydrogen Technologies Code , 2011 edition.

NFPA 30, Flammable and Combustible Liquids Code, 2012 edition.

NFPA 31, Standard for the Installation of Oil-Burning Equipment, 2011 edition.

NFPA 51, Standard for the Design and Installation of Oxygen–Fuel Gas Systems for Welding, Cutting, andAllied Processes, 2013 edition.

NFPA 51A, Standard for Acetylene Cylinder Charging Plants, 2012 edition.

NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, 2014 edition.

NFPA 52, Vehicular Gaseous Fuel Systems Code, 2013 edition.

NFPA 54, National Fuel Gas Code, 2012 edition.

NFPA 55, Compressed Gases and Cryogenic Fluids Code, 2013 edition.

NFPA 58, Liquefied Petroleum Gas Code, 2014 edition.

NFPA 59, Utility LP-Gas Plant Code, 2012 edition.

NFPA 59A, Standard for the Production, Storage, and Handling of Liquefied Natural Gas (LNG), 2013edition.

NFPA 69, Standard on Explosion Prevention Systems, 2008 edition.

NFPA 70® , National Electrical Code®, 2014 edition.

NFPA 2112

NFPA 2113


NFPA 2112 and 2113 were added as part of previous public comments for chapter 4, these are related to flame resistant clothing.




Street Address:

City:

State:

Zip:


Committee Statement

Resolution: FR-5-NFPA 56-2015 FR-4-NFPA 56-2015

Statement: NFPA 2113 was added due to its inclusion in FR-4.


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2.3.1 ASME Publications.

American Society of Mechanical Engineers ASME International , Three Park Avenue, New York, NY10016-5990.

ASME B31.1, Power Piping, 2010 2014 .

ASME B31.3, Process Piping, 2010 2012 .

ASME B31.12, Hydrogen Piping and Pipelines, 2008 2011 .


Referenced current editions.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 5-NFPA 56-2014 [Chapter D]


Submitter Full Name: Aaron Adamczyk

Organization: [ Not Specified ]

Street Address:

City:

State:

Zip:

Submittal Date: Mon Jun 16 17:19:55 EDT 2014

Committee Statement


Statement: Referenced current editions.


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Public Input No. 18-NFPA 56-2015 [ Section No. 2.4 ]

2.4 References for Extracts in Mandatory Sections.

NFPA 54, National Fuel Gas Code, 2012 edition.

NFPA 55, Compressed Gases and Cryogenic Fluids Code, 2013 edition.

API RP 99 (2014), Flash Fire Risk Assessment for the Upstream Oil and Gas Industry


The definition for flash fire was extracted from API RP 99. If it's easier this may also be in NFPA 2113, I did not have a chance to look.




Street Address:

City:

State:

Zip:


Committee Statement

Resolution: As a result of resolving PI-19, this references is not needed.


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Public Input No. 15-NFPA 56-2015 [ New Section after 3.2 ]

3.3.7 isolation

Isolations of piping systems shall be such that a complete and positive zero energy state is achieved. Thiszero energy state shall be verified and document making sure that closed valves are leak free. Acceptablemethods of verifying complete and positive isolation include double block and bleed with a monitored bleedvent, disconnection and capping, or the installation of blinds between flanges.


Isolation is used in the document but it is not clear what is meant. In some cases practioners can be lead to believe this simply means closing a valve. This can be very dangerous. We should be more clear and explicit regarding the extent of isolation intended and validation of the isolation.




Street Address:

City:

State:

Zip:


Committee Statement

Resolution: CI-7-NFPA 56-2015

Statement: The committee has formed a task group to look at the inclusion of isolation in the document.


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Public Input No. 19-NFPA 56-2015 [ New Section after 3.3 ]

3.3.8 Flash Fire

Flash Fire : A fire that spreads rapidly by means of a brief flame front through a diffuse fuel such as gas orthe vapors of an ignitable liquid, without the production of a damaging pressure. {API RP 99, section 2.1.6,2014}


The concept of flash fire is an important one for this topic. I have also used the term in one of the public comments added related to nfpa 2112 and 2113




Street Address:

City:

State:

Zip:


Committee Statement

Resolution: USed definition from 921, see FR-#.


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Public Input No. 6-NFPA 56-2014 [ New Section after 4.4.1 ]

(7) Protection and Rescue of Personnel

(a) Training requirements for personnel involved in the work efforts

(b) Personal protective equipment including possible need for flame resistant clothing (FRC) and flash fireprotection as per NFPA 2112 and NFPA 2113.

(c) Rescue equipment including self contained breathing apparatus and breathing air escape packs

(d) Standby rescue personnel

(e) Primary and secondary muster areas

(f) Assignment of personnel for alerting and accounting of personnel duties


The document previously did not address matters related to protection personnel or their possible rescue. The document also did not address the term flash fire, or flame resistant clothing. This section raises the awareness level of users to all of these issues.



Organization: Prescient Technical Services LLC.

Street Address:

City:

State:

Zip:

Submittal Date: Mon Oct 20 22:43:33 EDT 2014

Committee Statement


Statement: Made editorial revisions for clarity.

While the current text highlights control of static electricity at the discharge point, the inclusion ofnon-conductive components within a temporary piping system used for venting and purging caninduce static charges that may not be accounted for if the focus is limited to the discharge point.Although primarily directed at non-conductive liquids, NFPA 77 provides the essential basis for controlof this hazard and, while it is generically referenced in the annex for Section 4.4.1(4)(a), drawing theuser to the specifics of Section 10.3 in NFPA 77 will promote a proper review of this detail. API RP2003 provides a full discussion of protections for static electricity and can be of assistance inevaluating the risks from static electricity.

Reorganized and updated to raise the awareness level of users to these issues.


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4.4.1 *


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The written procedure for each cleaning and purging activity shall address, as a minimum, the followingitems:

replace item (m) below with the following:

Evaluate engineering controls that allow excess gas from depressuriation to be consumed in a controlledmanner instead of vented, (i.e. flaring or controlled combustion in process equipment to as low a pressureas safely possible).

(1) Scope of work and site-specific purge procedure development

(2) Cleaning and purging method

(3) Piping and instrument diagrams (PIDs)

(4) Chemical and physical properties of flammable gas, cleaning media, purge media, anddischarge gas

(5) Determination of purge end point introducing flammable gas, inert gas, or air

(6) Assessment and control of purge inlet and discharge locations

(7)

(8) Temporary piping system design

(9) Personal protective equipment (PPE)

(10) Training and qualifications

(11) Management review and approval

(12) Restoration of service

(13) Target design, launcher/receiver venting review for pigging operations

(14) Regulatory permits

(15) Evaluation of engineering controls

to limit potential unintended ignition of gases (controlled oxidation, “flaring”)

(a) that allow excess gases to be consumed in some safe manner that limits the amount of gas tobe vented from depressurization processes, (i.e. flaring or controlled oxidation in equipment).

(b) Written stand-down instructions to stop activity in a controlled manner

(c)

(16)

(17)

(18)

(19)

(20)

(21)

(22)

(23)

(24)

(25)

(26) Communication plans

(27) Pre-job briefings

* Mitigation or capture strategies

* Precautions for gases that have toxic, highly toxic, unstable reactive, corrosive, or otherdeleterious properties beyond flammability

* Environmental conditions and work locations

Establishment and clear identification of exclusion zones where flammable gas–air mixturesare likely to exist

Limited access for personnel not directly involved with purge operations

Assessment of potential for gas migration (building openings, adjacent structures)

Prohibition of hot work within exclusion zones

Lockout/tagout

Impact of environmental conditions (wind speed and direction, temperature, barometricpressure) on purge operations

Vehicular and air traffic, if applicable

Topography

Noise control/monitoring


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(28) Work permits

(29) Roles and responsibilities

(30) Emergency response plan

(31) Facility alarm, alert and warning systems

(32) General facility notification prior to start of purge operations

(33) General facility notification at the conclusion of purge operations

(34) Notification of regulatory authorities as required (local emergency responders, utility operators,community officials, environmental authorities, etc.)

(35) Control of ignition sources

(36)

(37) No smoking or spark-producing work within exclusion zones

(38) Elimination of hot work within exclusion zone

(39) Static electricity ignition sources at discharge point

(40) Pre-purge piping system assessment

(41) Assessment of piping system for trapped liquids, pyrophoric solids, and other flammable orcombustible deposits within the piping system

(42) Ensuring that the piping system is properly isolated

(43) Limiting site conditions that impact the safety of the activity

(44)

(45)

(46)

(47)

(48)

(49)

(50)


The way item (m) is currently stated is confusing, the intent is not clear.




Street Address:

City:

State:

Zip:


Committee Statement

* Bonding and grounding considerations

* Purge monitoring and instrumentation

Ensuring that monitoring instruments are appropriate for gas being purged

Training

Calibration

Monitoring frequency and reporting

Appropriate selection of sample point(s)

General atmosphere checks in vicinity of purge gas release


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4.4.1 *


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(7)




(11) Management review and approval

(12) Restoration of service

(13) Target design, launcher/receiver venting review for pigging operations

(14) Regulatory permits

(15) Evaluation of engineering controls to limit potential unintended ignition of gases (controlledoxidation, “flaring”)

(16) Written stand-down instructions to stop activity in a controlled manner

(17)

(18)

(19)

(20)

(21)

(22)

(23)

(24)

(25)

(26)

(27)



(30) Work permits












Lockout/tagout



Topography



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(38)




(42) Non-conductive piping, hose or fittings in temporary piping assemblies





(47)

(48)

(49)

(50)

(51)

(52)

(53)


While the current text highlights control of static electricity at the discharge point, the inclusion of non-conductive components within a temporary piping system used for venting and purging can induce static charges that may not be accounted for if the focus is limited to the discharge point. Proper bonding of the conductive portions of the assembly on both sides of the non-conductive portions is essential to proper control of static electricity and treatment of only the discharge point may not be sufficient for complete control of the hazard. Although primarily directed at non-conductive liquids, NFPA 77 provides the essential basis for control of this hazard and, while it is generically referenced in the annex for Section 4.4.1(4)(a), drawing the user to the specifics of Section 10.3 in NFPA 77 will promote a proper review of this detail. API RP 2003 provides a full discussion of protections for static electricity and can be of assistance in evaluating the risks from static electricity.

For the purposes of NFPA 56, substitution of the term “fluid” for “liquid” in the extracted text assists the user in making the connection to the subject of gas purging as discussed in NFPA 56. Additionally, the term “hose” is appended to state “hose[s]” in recognition that multiple flexible sections may be used to route temporary vent piping.



Public Input No. 24-NFPA 56-2015 [New Section afterA.4.4.1(4)(a)]

Annex material associated with thisproposal





Training

Calibration





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Submitter Full Name: Lawrence Danner

Organization: GE Power & Water

Street Address:

City:

State:

Zip:


Committee Statement






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4.4.1*


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(7)




(a) Management review and approval

(b) Restoration of service

(c) Target design, launcher/receiver venting review for pigging operations

(d) Regulatory permits

(e) Evaluation of engineering controls to limit potential unintended ignition of gases (controlledoxidation, “flaring”)

(f) Written stand-down instructions to stop activity in a controlled manner

(g)

(h) Locations of nearby residences, schools, churches, roads, medical facilities, and parks

(i) Evacuation routes and road block locations

(j) On-site and or classroom table top drills of emergency drills

(k) Qualifications of personnel

(l) Hazards

(11)

(12)

(13)

(14)

(15)

(16)

(17)

(18)

(19)

(20)










Lockout/tagout



Topography



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(23) Work permits







(30) Emergency phone list including: emergency services, ambulances, hospitals, air rescue(helicopter services), local emergency planning committee, state response center, nationalresponse center, state and local law enforcement, fire departments, operators and contractors,gas supplier including distribution emergency personnel, emergency leak repair and valveservice contractors.


(32)








(40)

(41)

(42)

(43)

(44)

(45)

(46)


Enhancement of considerations for preparing a more complete and effective work plan.Removed personnel protective equipment and training from section 1), added them to section 7, protection and rescue of personnel.Added mitigation or capture strategiesAdded sections n) through r)Added section 3 i)






Training

Calibration





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Organization: prescient Technical Services LLC.

Street Address:

City:

State:

Zip:


Committee Statement






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Public Input No. 8-NFPA 56-2014 [ Section No. 5.1 [Excluding any Sub-Sections] ]

Persons whose duties fall within the scope of this standard shall be provided with training that is consistentwith the scope of their job activities and assigned tasks for the cleaning or purging work to be performed .Evidence of knowledge transfer shall be included as part of the training program.


Explicitly stating what the training is to be about.Nothing currently speaks to the need to validate knowledge transfer.




Street Address:

City:

State:

Zip:


Committee Statement


Statement: Language added to help insure knowledge transfer is effective.


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5.1.3

Training records including dates of training, name of instructor (s), content or curriculum covered, andevidence of knowledge transfer shall be maintained for a period not less than 5 years from the date ofcompletion of the activity.


We ask for training records to be maintained but we never explain what we mean by this. It is hoped this clears that up.




Street Address:

City:

State:

Zip:


Committee Statement


Statement: Clarification to what records must be maintained.


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It is proposed that these be deleted, in favor of submission #13's concept and language

7.1.2 *

If the plant is owned or operated by the serving natural gas supplier, natural gas piping between the pointof delivery or source valve and the plant shall be permitted to be purged into service in accordance with theserving natural gas supplier’s written procedures.

7.1.2.1

The natural gas supplier’s written procedures shall include a safety validation in accordance with Section4.5.

7.1.2.2

The natural gas supplier’s written procedures and process shall be coordinated with the plant operationalpersonnel.


Sections 7.1.2 and 8.2.1 discuss the possibility of a “plant” being owned by a serving gas utility. It’s not clear what a “plant” is. I believe it was meant to indicate electrical generating plant. However, there is no definition for plant. In my opinion, this is an exemption. First of all, exemptions should not be addressed in the body of the document. Section 1.1.2 Non-application of standard is the place for this. This entire matter is very parallel to the entire discussion regarding the midstream gas processing industry and the task for work related to it. In fact it’s the same issue. In effect the midstream task force work says many gathering lines are technically equivalent to DOT regulated lines and therefore the DOT practices related to purging and safe piping processes should apply. This is the same issue with segments of distribution piping and transmission piping that consist of largely underground sections that might be somewhat long and have few isolation valves. In these cases DOT practices address creating a plan for doing this kind of work. If NFPA 56 does not fit well for these kinds of systems and DOT does then why not require it instead of abdicating to some unknown set of practices that some gas utilities have or do not have? It makes no sense.Hence, this submission slightly changes the original task force for midstream piping systems and by doing so eliminates the need to exempt gas utilities, (7.1.2 and 8.2.1) later in the document.RELATED TO SUBMISSION #13




Street Address:

City:

State:

Zip:


Committee Statement


Statement: Clarify that this is applicable explicitly to electrical generating plant.


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IT IS PROPOSED THAT THIS SECTION BE DELETED IN ACCORDANCE WITH PUBLIC COMMENT#13

8.2.1 *

If owned or operated by the serving natural gas supplier, natural gas piping between the point of delivery orsource valve and the plant shall be permitted to be purged out of service in accordance with the servingnatural gas supplier’s written procedures.

8.2.1.1

The natural gas supplier’s written procedures shall include a safety validation in accordance with Section4.5.

8.2.1.2

The natural gas supplier’s written procedures and process shall be coordinated with the plant operationalpersonnel.


Sections 7.1.2 and 8.2.1 discuss the possibility of a “plant” being owned by a serving gas utility. It’s not clear what a “plant” is. I believe it was meant to indicate electrical generating plant. However, there is no definition for plant. In my opinion, this is an exemption. First of all, exemptions should not be addressed in the body of the document. Section 1.1.2 Non-application of standard is the place for this. This entire matter is very parallel to the entire discussion regarding the midstream gas processing industry and the task for work related to it. In fact it’s the same issue. In effect the midstream task force work says many gathering lines are technically equivalent to DOT regulated lines and therefore the DOT practices related to purging and safe piping processes should apply. This is the same issue with segments of distribution piping and transmission piping that consist of largely underground sections that might be somewhat long and have few isolation valves. In these cases DOT practices address creating a plan for doing this kind of work. If NFPA 56 does not fit well for these kinds of systems and DOT does then why not require it instead of abdicating to some unknown set of practices that some gas utilities have or do not have? It makes no sense.Hence, this submission slightly changes the original task force for midstream piping systems and by doing so eliminates the need to exempt gas utilities, (7.1.2 and 8.2.1) later in the document.RELATED TO COMMENT 13




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Committee Statement


Statement: Clarify this is explicitly applicable to electric generating plants.


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Public Input No. 14-NFPA 56-2015 [ New Section after A.1.1.2(6) ]

For Public Comment #12

“Section 1.1.2 exemption (10): US DOT 49 cfr 191/192 contains guidance on carefully planningflammable gas piping activities including purging gathering line systems into and out of service.Much of this guidance addresses techniques for relatively long underground runs where there maynot be isolation valves. This standard, NFPA 56, also provides guidance for purging piping systemsinto and out of service. Many of the techniques and processes within this standard, including therequirements for detailed planning and the use of nitrogen or other inert gases for purging canenhance the safety of gathering line installation and servicing activities.”

For Public comment #13

“Section 1.1.2 exemption (10): US DOT 49 cfr 191/192 contains guidance on carefully planningflammable gas piping activities including purging gathering line systems into and out of service.Much of this guidance addresses techniques for relatively long underground runs where there maynot be isolation valves. These kinds of runs are technically equivalent to some distribution andtransmission line segments. This standard, NFPA 56, also provides guidance for purging pipingsystems into and out of service. Many of the techniques and processes within this standard,including the requirements for detailed planning and the use of nitrogen or other inert gases forpurging can enhance the safety of gathering, distribution and transmission line segment installationand servicing activities.”


These annex sections help to explain the non application of standard submissions made. I provided two annex sections here, one for public comment #12 and one for #13. They are very similar and I thought these might be discussed at the same time.




Street Address:

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Committee Statement




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Public Input No. 24-NFPA 56-2015 [ New Section after A.4.4.1(4)(a) ]

TITLE OF NEW CONTENT


A.4.4.1(4)(e) Temporary piping may be comprised of an assembly of solid piping, flexible hose and flexibletubing. It is preferable to use only conductive components in the temporary piping system; however, theuse of non-conductive components may be necessitated by the constraints of the installation or process. Specific guidance on grounding and bonding of non-conductive components is provided in NFPA 77 Section10.3, included here for the convenience of the user:

10.3* Flexible Hose and Tubing. Flexible hose and flexible tubing are available in metal, lined metal,nonconductive plastic, reinforced rubber and plastic, and composite-ply types.

10.3.1 Where nonconductive hose or tubing must be used because of process conditions, the hazards ofstatic electric charge generation should be thoroughly investigated.

10.3.2 As a minimum, all conductive couplings (e.g., end fittings) and components should be bonded andgrounded.

10.3.3 If hose[s] are used immediately downstream of filters in nonconductive liquid [fluid] service, theyshould be of metal or other conductive material. Semiconductive liners might be necessary to preventcharge accumulation and pinhole damage to the hose.

10.3.4 Conductive hose[s] should be electrically continuous, and the continuity should be periodicallychecked.

10.3.4.1 Hose[s] with more than one internal spiral should not be used because it is not possible todetermine if one of the spirals has lost its continuity.

A.10.3 For all-metal conductive hose, the resistance to ground from any point normally should be 10ohms or less. For conductive hose that contain a continuous bonding element, such as wire or braid, theresistance to ground from any metal connector normally should be 1000 ohms per meter or less, with thesame exception being applicable. Resistance to ground through semiconductive hose with a current-limiting design that eliminates a low-resistance bonding element and resistance to ground through insulatingflanges should be between 103 ohms/m and 105 ohms/m. In either case, the total resistance to groundfrom a metal hose connector should not exceed 106 ohms.

While a resistance to ground of less than 106 ohms will prevent accumulation of static electric charge inmost cases, if periodic testing reveals a significant increase in the as-installed resistance, that increasecould be the result of corrosion or other damage, which could lead to sudden loss of continuity. The hose,insulating flange, or both should be inspected to determine the need for replacement.

Where conductive hose has double spirals, one for bonding and the other for mechanical strength,continuity between the end connectors confirms the continuity of only one spiral. A fire was reported duringdraining of toluene from a tank vehicle through such a hose. It was found that the inner spiral not only wasbroken but was not designed to be bonded to the end connectors. For handling nonconductive liquids, oneoption is to use a hose with a semiconductive or conductive liner, so that a broken inner spiral cannotbecome isolated from ground and form a spark gap. Ideally, the inner spiral should be separately bonded tothe end connectors.

It is especially important to ensure continuity with end connectors (or nozzles) where a hose is used in anignitable atmosphere. In general, it is safer to use a properly designed fixed fill system, such as a dip pipearrangement, for filling tank vehicles, rather than to use a hose.

Where used in flammable atmospheres, such as inside tanks, utility hose should be conductive orsemiconductive. In particular, all metal connectors and nozzles should be grounded. Ungrounded hoseconnectors on nonconductive hose can become charged by a variety of means, such as by the insertion ofa nitrogen hose into a tank containing charged liquid or mist, by rubbing, or by streaming currents generatedby the flow of steam condensate. While clean and dry gases do not generate charge, a nonconductivehose will become highly charged by the flow of steam.

Additional background information on control of static electricity for fluid systems can be found in APIRecommended Practice 2003.


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See Justification for Public Input No. 23-NFPA 56-2015



Public Input No. 23-NFPA 56-2015 [Section No. 4.4.1]


Submitter Full Name: Lawrence Danner

Organization: GE Power & Water

Street Address:

City:

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Zip:


Committee Statement






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Public Input No. 5-NFPA 56-2014 [ Chapter D ]

Annex D Informational References

D.1 Referenced Publications.

The documents or portions thereof listed in this annex are referenced within the informational sections ofthis standard and are not part of the requirements of this document unless also listed in Chapter 2 for otherreasons.

D.1.1 NFPA Publications.

National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471.

NFPA 1, Fire Code, 2012 edition 2015 .

NFPA 2, Hydrogen Technologies Code, 2011 edition 2016 .

NFPA 30, Flammable and Combustible Liquids Code, 2012 edition 2015 .

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages, 2012 edition 2015 .

NFPA 37, Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines, 2010edition 2015 .

NFPA 45, Standard on Fire Protection for Laboratories Using Chemicals, 2011 edition 2015 .

NFPA 51, Standard for the Design and Installation of Oxygen–Fuel Gas Systems for Welding, Cutting, andAllied Processes, 2013 edition .

NFPA 51A, Standard for Acetylene Cylinder Charging Plants, 2012 edition 2017 .

NFPA 52, Vehicular Gaseous Fuel Systems Code, 2013 edition 2016 .

NFPA 54, National Fuel Gas Code, 2012 edition 2015 .

NFPA 55, Compressed Gases and Cryogenic Fluids Code, 2010 edition 2016 .

NFPA 55, Compressed Gases and Cryogenic Fluids Code , 2013 edition.NFPA 58, Liquefied PetroleumGas Code, 2014 edition 2017 .

NFPA 59, Utility LP-Gas Plant Code, 2012 edition 2015 .

NFPA 59A, Standard for the Production, Storage, and Handling of Liquefied Natural Gas (LNG), 2013edition 2016 .

NFPA 69, Standard on Explosion Prevention Systems, 2008 edition 2014 .

NFPA 70 ®, National Electrical Code ®, 2014 edition 2017 .

NFPA 77, Recommended Practice on Static Electricity, 2014 edition .

NFPA 85, Boiler and Combustion Systems Hazards Code, 2011 edition 2015 .

NFPA 86, Standard for Ovens and Furnaces, 2011 edition 2015 .

NFPA 87, Recommended Practice for Fluid Heaters, 2011 edition 2015 .

NFPA 99, Health Care Facilities Code, 2012 edition 2015 .

NFPA 400, Hazardous Materials Code, 2013 edition 2016 .

NFPA 801, Standard for Fire Protection for Facilities Handling Radioactive Materials, 2014 edition .

D.1.2 Other Publications.

D.1.2.1 AGA Publications.

American Gas Association, 400 N. Capitol Street, N W, Washington, DC 20001.

AGA XK0101, Purging Principles and Practices, 2001.


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D.1.2.2 AIChE Publications.

American Institute of Chemical Engineers, Center for Chemical Process Safety, Three Park Avenue, NewYork, NY 10016-5991.

Crowl, D. A., Understanding Explosions, 2003.

Guidelines for Hazard Evaluation Procedures, 2nd 3rd edition, 1992 2008 .

D.1.2.3 ASME Publications.

American Society of Mechanical Engineers, Three ASME International , Two Park Avenue, New York,NY 10016 1001 5 -5990.

ASME B31.1, Power Piping, 2010 2014 .

ASME B31.3, Process Piping, 2010 2014 .

D.1.2.4 ASTM Publications.

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

ASTM E 2079, Standard Test Method for Limiting Oxygen (Oxidant) Concentration for Gases and Vapors,2007, reapproved 2013 .

D.1.2.5 U.S. Government Publications.

U.S. Government Printing Office, Washington, DC 20402.

Kuchta, J. M., Investigation of Fire and Explosion Accidents in the Chemical, Mining, and Fuel-RelatedIndustries — A Manual, in U.S. Bureau of Mines Bulletin 680, U.S. Department of the Interior, 1985.

Title 49, Code of Federal Regulations, Parts 100–185, Hazardous Material Regulations.

Title 49, Code of Federal Regulations, Parts 190–199, Pipeline Safety Regulations.

U.S. Department of Labor, Occupational Safety and Health Administration (OSHA), Safety and HealthTopics, “Competent Persons,” http://www.osha.gov/SLTC/competentperson/index.html.

D.1.2.6 Other Publications.

Britton, L. G., “Using Heats of Oxidation to Evaluate Flammability Hazards,” Process Safety Progress,20(1), (March 2002):31–54.

Coward, J. F., and G. W. Jones, “Limits of Flammability of Gases and Vapors,” Bulletin 503, U.S. Bureau ofMines, Pittsburgh, PA, 1952.

Jones, G. W., et al., “Research on the Flammability Characteristics of Aircraft Fuels,” Wright AirDevelopment Center, Wright-Patterson AFB, OH, Technical Report 52-35, Supplement I, 1954.

Kuchta, J. M., et al., “Effect of Pressure and Temperature on Flammability Limits of ChlorinatedCombustibles in Oxygen-Nitrogen and Nitrogen Tetroxide-Nitrogen Atmospheres,” Journal of Chemical andEngineering Data, Vol. 13, No. 3, July 1968 (American Chemical Society, Washington, DC), p. 421.

Zabetakis, M. G., “Flammability Characteristics of Combustible Gases and Vapors,” Bulletin 627, U.S.Bureau of Mines, Pittsburgh, PA, 1965.

Zabetakis, M. G., and B. H. Rosen, “Considerations Involved in Handling Kerosine,” Proceedings, API, Vol.37, Sec. III, 1957, p. 296.

D.2 Informational References.

D.2.1 ASSE Publications.

American Society of Safety Engineers, 1800 E. Oakton Street, Des Plaines, IL 60018.

ASSE/ISO Risk Management, Risk Management Package, 2011. (Includes the following 3standards)

ANSI/ASSE Z690.1, Vocabulary for Risk Management, 2011.

ANSI/ASSE Z690.2, Risk Management — Principles and Guidelines, 2011.

ANSI/ASSE Z690.3, Risk Assessment Techniques, 2011.

D.2.2 Other Publications. (Reserved)


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D.3 References for Extracts in Informational Sections.

NFPA 2, Hydrogen Technologies Code, 2011 edition 2016 .

NFPA 51, Standard for the Design and Installation of Oxygen–Fuel Gas Systems for Welding, Cutting, andAllied Processes, 2013 edition .

NFPA 51A, Standard for Acetylene Cylinder Charging Plants, 2012 edition 2017 .

NFPA 54, National Fuel Gas Code, 2012 edition 2015 .

NFPA 55, Compressed Gases and Cryogenic Fluids Code, 2013 edition 2016 .

NFPA 58, Liquefied Petroleum Gas Code, 2014 edition 2017 .

NFPA 59, Utility LP-Gas Plant Code, 2012 edition 2015 .

NFPA 59A, Standard for the Production, Storage, and Handling of Liquefied Natural Gas (LNG), 2013edition 2016 .

NFPA 69, Standard on Explosion Prevention Systems, 2008 edition 2014 .


Referenced current organization names, and editions.



Public Input No. 4-NFPA 56-2014 [Section No. 2.3.1] Referenced current editions.


Submitter Full Name: Aaron Adamczyk

Organization: [ Not Specified ]

Street Address:

City:

State:

Zip:

Submittal Date: Tue Jul 08 02:12:08 EDT 2014

Committee Statement


Statement: Update to new edition of AGA document which is currently being revised.

See Committee Input to revise Annex B based on new edition of AGA document.


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