Report Of Committee on Fl~ammable Liquids

Correlating Conmlittee

Paul C. Lamb, Chairman Englewood, NJ

• Martin F. Henry; Secretary National Fire Protecti©n Association

(Nonvoting)

W. H. Axtman, American Boi ler Mfrs. Assn. Rep. Liquid Fuel Burning Equipment Comm.

G. E. Cain, G. E. Cain & Co. J. A. Cedervall, Underwriters Laboratories Inc. Donald M. Johnson, San Bruno, CA

Rep. Western 0 i l & Gas Assn. F. (}wen Kubias, SCM/Glidden Steven Landon, Roanoke, TX

Rep. Tex t i le Care A l l i ed Trades Assn. Wi111am R. Rucinski, Fire Marshal Oiv., Lansing, HI

Technical Committee on

Classification & Properties of Flammable Liquids

F. Owen Kubias, Chairman SCM/G1idden

Martin F. Henry, Secretary National Fire Protect~ion Assn.

(Nonvoting)

A. Richard Albrecht, Oow Chemical Co. Rep. American Petroleum Inst.

Harlan R. Bratvold, Underwriters Laboratories Inc. Richard G. Gann, Ctr for Fire Research Arthur A. Krawetz, Phoenix ChemicaL1 Laboratory Inc. Roland J. Land, Emett & Chandler New York Inc. Joe 3. Mayhew, Chemical Mfrs. Assn. Harry H. Mclntyre, Harry McIntyre Assoc. Paul G. Sikoris, Frank B Hall & Cop. of NJ Jack S. Snyder, Merck & Co., Inc~

Rep. Chemical Manufacturers Assn. R. I. Spencer, Industrial Risk Insurers Pat R. Wrigley, Nat'1 Petroleum Refiners Assn.

Alternates

Jose P. Abrenica, M&M Protection Consultants (Alternate to M&M Prot. Consul. Rep.)

John A. Davenport, Industrial Risk Insurers (Alternate to R. I. Spencer)

Milton Freifeld, Chemical Mfrs. Assn. (Alternate to J. S. Snyder)

Michael S. Hildebrand, American Petroleum Inst. (Alternate to A. R. Albrecht)

Clayton Huggett, Ctr for Fire Research (Alternate to R. Gann)

Technical Committee on

Liquid Fuei Burning Equipment

W. J. Smith, Chairman Underwriters Laboratories Inc.

Martin F. Henry, Secretary National Fire Protect ion Assn.

(Nonvoting)

W. H. Axtman, American Boi ler Mfrs. Assn. Frank 3. Connors, Peabody Fire Dept, Peabody, MA

Rep. Mass Fire Prevention Assn. Richard A. Daniels, Ralph Gerdes & Assoc., Inc. Robert B. Greenes, Public Fuel Service Inc.

Rep. Petroleum Marketers Assn. of America Richard A. Gross, Industr ia l Risk Insurers Alfred J. Hogan, Cypress Gardens, FL William G. Hullhorst, AMCA In t ' l

(Vote Limited to Chapter 5)

Alternates

Russell N. Mosher, American Boiler Mfrs. Assn. (Alternate to W. H. Axtman)

Gregory G. No11, American Petroleum Institute (Alternate to API Rep.)

Frank E. Rademacher, Industrial Risk Insurers (Alternate to R. A. Gross)

Technical Committee on

Manufacture of Organic Coatings

G. E. Cain, Chairman G. E. Cain & Co.

Martin F. Henry, Secretary National Fire Protection Assn.

(Nonvotingi

Andrew W. Beilfuss Jr. , M&M Protection Consultants Floyd T. Edwards, Industrial Risk Insurers Nelson W. Lamb, Hercules Inc.

Rep. Chemnlcal Manufacturers Assn. J. Benjamin Roy Jr., Office of the State Fire Marshal, Delaware

Rep. Fire Marshals Assn. of N. America Damon W. Snow, Monsanto Co.

Rep. American Petroleum Inst.

Alternates

John 3aresko, Industrial Risk Insurers (Alternate to F. T. Edwards)

J

117

Technical Committee on

Tank Leakage and Repair Safeguards

3. A. Cederval l , Chairman Underwriters Laboratories Inc.

Martin F. Henry, Secretary Natlonal Fire Protection Assn.

(Nonvoting)

Donald W. Fleischer, Veeder-Root Co. Carl V. Hasselback, White Arrow Service Stations, Inc.

Rep. Petroleum Marketers Assn. of America Will iam C. 3ackson, Ph i l l i ps Petroleum Co.

Rep. American Petroleum Inst . Donald M. Johnson, San Bruno, CA

Rep. Western Oil & Gas Assn. Richard 3. Kelner, Nassau County Fire Marshals Off ice Frederick B. Ki l lmar, Ki l lmar Assoc., I n c . Edwin Liu, NJ Dept. of Envlromental Protection George S. Lomax, Heath Consultants, Inc. Robert N. Renkes, Petroleum Equipment Ins t i t u te Robert L. Ruyle, Ruyle & Assoc. Bruce R. Sharp, Armor Shield, Inc. Robert P. Siegel, 3M Co. Pat R. Wrigley, Nat'1 Petroleum Refiners Assn.

Alternates

John A. Ainlay, Steel Tank Insitute (Alternate to Steel Tank Institute)

Rudolph C. White, American Petroleum Institute (Alternate to W. C. Jackson)

This l i s t 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.

The Report of the Committee on Flammable Liquids is presented for adoption in 6 parts.

Part I of th is Report, was prepared by the Technical Committee on C lass i f i ca t ion and Properties of Flammable Liquids and proposes for adoption amendments to NFPA 321-1982, Standard on Basic C lass i f i ca t ion of Flammable and Combustible Liquids. NFPA 321-1982 is pOblished in Volume 1 of the 1985 National Fire Codes and in separate pamphlet form.

Part I of th is Report has been submitted to l e t t e r ba l lo t of the Technical Committee on Class i f ica t ion and Properties of Flammable Liquids which consists of 12 vot ing members; of whom 11 voted a f f i rma t i ve l y , and 1 ba l lo t was not returned (Mr. Wrigley).

Part I of th is Report has also been submitted to l e t t e r ba l lo t of the Correlat ing Committee on Flammable Liquids which consists of 8 vot ing members; a l l of whom voted af f i rmat !ve ly .

Part I I of this Report, was prepared by the Technical Committee on Liquid Fuel Burning Equipment and proposes for adoption amendments to NFPA 31-1983, Standard for the Installation of Oil Burning Equipment. NFPA 31-1983 is published in Volume I of the 1985 National Fire Codes and in separate pamphlet forth.;

Part I I of th is Report has been submitted to le t ter bal lot of the Technical Committee on Liquid Fuel Burning Equipment which consists of 9 voting members. The ba l l o t was in two segments. The f i r s t segment concerned i t s e l f with Proposal 31-22 of the Report. Seven members voted a f f i rma t i ve l y , and 2 voted negat ively (Messrs. Hogan and Connors).

Hr. Hogan's reason for the negative vote indicated that he would submit substant iat ion on the matter in the form of a publ ic comment at the appropriate time.

Mr. Connors negative vote indicated that, in his opinion, a l l portable kerosene heaters and stoves should be vented by means of an approved chimney or vent.

The second segment of Part I I dealt with the remainder of the Report, and al l 9 members voted affirmatively.

Part I I of this Report has also been submitted to le t ter ballot of the Correlating Committee on Flammable Liquids which consists of 8 voting members; al l of whom voted affirmatively.

Part I I I of this Report, was prepared by the Technical Committee on Manufacture of Organic Coatings and proposes for adoption amendments to NFPA 35-1982, Standard for the Manufacture of Organic Coatings. NFPA 35-1982 is published in Volume I of the 1985 National Fire Codes and in separate pamphlet form.

part I I I of this Report has been submitted to le t te r ballot of the Technical Committee on Manufacture of Organic Coatingswhich consists of 6 voting members; of whom 5 voted affirmatively, and I ballot was not returned (Mr. Roy).

Part I I I of this Report has also been submitted to le t te r bal lot of the Correlating Committee on Flammable Liquids which consists of 8 voting members; al l of whom voted affirmatively.

Part IV of this Report, was prepared by the Technical Committee on Tank Leakage and Repair Safeguards and proposes for adoption amendments to NFPA 327-!982, Standard Procedures for Cleaning or Safeguarding Small Tanks and Containers. NFPA 327-1982 is published in Volume 1 of the 1985 National Fire Codes and in separate pamphlet form.

Part IV of this Report has been submitted to le t ter ballot of the Technical Committee on Tank Leakage and Repair Safeguards which consists of 15 voting members; of whom 11 voted aff irmatively, and 4 ballots were not returned (Messrs. Hasselback, Killmar, Sharp and Wrigley).

Part IV of th is Report has also been submitted to le t ter bal lot of the Correlating Committee on Flammable Liquids which consists of 8 voting members; al l of whom voted aff irmatively.

118

Part V of this Report, was prepared by the Technical Committee on Tank Leakage and Repair Safeguards and proposes for adoption amendments to NFPA 328-1982, Recommended Practice for the Control of Flammable and Combustible Liquids and Gases in Manholes, Sewers, and Similar Underground Structures. NFPA 328-1982 is published in Volume 7 of the 1985 National Fire Codes and in separate pamphlet form.

Part V of this Report has been submitted to le t ter bal lot of the Technical Committee on Tank Leakage and Repair Safeguards which consists of 15 voting members; of whom 11 voted affirmatively, and 4 ballots were not returned (Messrs. Hasselback, Killmar, Sharp and Wrigley).

Part V of this Report has also been submitted to le t ter bal lot of the Correlating Committee on Flammable Liquids which consists of 8 voting members; al l of whom voted affirmatively.

Part Vi of th is Report, was prepared by the Technical Committee on Tank Leakage and Repair Safeguards and proposes fo r adoption amendments to NFPA 329-1983, Recommended Pract ice fo r Handling Underground Leakage of Flammable and Combustible Liquids. NFPA 329-1983 is published in Volume 7 of the 1985 National Fire Codes and in separate pamphlet f o r m .

Part VI of this Report has been submitted to le t ter ballot of the Technical Committee on Tank Leakage and Repair Safeguards which consists of 15 voting members; of whom 11 voted affirmatively, and 4 ballots were not returned (Messrs. Hasselback, Killmar, Sharp and Wrigley).

part vI of this Report has also been submitted to let ter ballot of the Correlating Committee on Flammable Liquids which consists of 8 voting members; al l of whom voted affirmatively.

119

PART I

321- 1 - (I-2 Footnote): Accept SUBMITTER: Technical Committee on Classif ication and Properties of Flammable and Combustible Liquids RECOMMENDATION: Revise footnote to "Flash Point" as follows:

"Certain solutions of l iquids in water may exhibit a flash point under the standard closed-cup test procedures but wi l l not burn and wi l l even extinguish a f i r e . To assist in the ident i f icat ion of such solutions the following ASTM standards, developed through the consensus standards procedures of that society may be used: ASTM D4207, Standard Test Method for Sustained Burning of Low Viscosity Liquid Mixtures by the Wick Test, and ASTM-4206 Standard Test Method for Sustained Burning of Liquid Mixtures by the Setaflash Tester (Open Cup).. Liquid mixtures that do not sustain combustion for a specified time at a specified temperature are considered not to sustain burning. These tests provide additional data for determining proper storage and handling of such mixtures. In a confined space such mixtures s t i l l could create a flammable vapor-alr mixture depending to a large extent upon the amount of flammable material in the mixture and the quantity of the s p i l l . " SUBSTANTIATION: This wi l l help to c la r i f y which tests might be used in providing exemptions of certain liquids exhibit ing flash points from regulations. COMMITTEE ACTION: Accept.

321- 2 - (I-2 Footnote (New)): Accept SUBMITTER: Technical Committee on Classif icat ion and Properties of Flammable and Combustible Liquids RECOMMENDATION: Insert a new additional footnote under "Flash Point'! as follows:

(3) ASTM E502, Standard Test Method for Selection and Use of ASTM Standards for the Determination of Flash Point of Chemicals by Closed Cup Methods, covers the determination of the flash point of l iquid and solid chemical compounds flashing from below 16 ° to 700°F (-I0 ° to 370°C). The results obtained are discussed along with pos@ible sources of error and factors that might cause interference. SUBSTANTIATION: This is a summary of good practice in using c losed-cup f l a s h po in t equipment w i th cons iderab le i n fo rma t i on on the s i g n i f i c a n c e o f the f l a s h po in t t e s t and poss ib le i n t e r f e r e n c e s . COMMITTEE ACTION: Accept.

321- 4 - ( I -2) : Accept SUBMITTER: Technical Committee on Classif ication and Properties of Flammable and Combustible Liquids RECOMMENDATION: Under def in i t ion of Flash Point, subsection (e) delete the words "specific Setaflash Methods exist (Cf ASTM D 324-77 . . . . components)" and insert "ASTM D 3278 is speci f ical ly required" in place of the deleted words. SUBSTANTIATION: ASTM D 3243 has been withdrawn. COMMITTEE ACTION: Accept.

321- S - ( I -2) : Accept SUBMITTER: Technical Committee on Classif ication and Properties of Flammable and Combustible Liquids RECOMMENDATION: Update the ASTM Methods as follows:

ASTM D-56-79 to ASTM D-S6 ASTM D-3828-78 to ASTM D-3828 ASTH D-3278-78 to ASTH D-3278 ASTM D-323-79 to ASTM D-323 ASTM D-86-78 to ASTM D-86

SUBSTANTIATION: These are e d i t o r i a l changes. COMMITTEE ACTION: Accept.

321- 6 - (I-3.4 (New)): Accept SUBMITTER: Technical Committee on Classif ication and Properties of Flammable and Combustible Liquids RECOMMENDATION: Establish a new Section I-3.4 as follows:

I-3.4 Comparative Classif ication of Liquids. Agency NFPA

Aoencv Classif icat ion Classif ication DOT Flammable Class I

Combustible Class II and IlIA

Flash Point Below lO0°F (37.8°C)

IO0°F to 200°F (37.8 ° to 93.3°C)

Below 140°F (60°C)

UN Flammable Class I and I I

SUBSTANTIATION: In the Committee's op in ion , t h i s t ab le w i l l be he lp fu l and usefu l to the Code-user. COMMITTEE ACTIQN: Accept.

321- 3 - ( 1 -2 ) : Accept SUBMITTER: Technical Committee on C l a s s i f i c a t i o n and Proper t ies o f Flammable and Combustible L iqu ids RECOMMENDATION: Under the l i s t e d Flash Point methods, amend (a) to read as f o l l o w s :

(a) The f l a s h po in t o f a l i q u i d having a v i s c o s i t y below 5.S cSt a t 104°F (40°C) o r below 9.S cSt a t 77°F (25°C) sha l l be determined in accordance wi th ASTM D-S6, Standard Method o f Test f o r Flash Point by the Tag Closed Tes ter . Cut-back aspha l t s , those l i q u i d s which tend to form a su r face f i l m and ma te r i a l s which conta in suspended s o l i d s are excluded from study by ASTM O-56-82 even i f they o therw ise meet the v i s c o s i t y requi rements.

Amend (b) to read: (b) The f l a s h po in t o f a l i q u l d having a v i s c o s i t y

o f S.S cSt o r more at 104°F (40°C) or 9.5 cSt or more at 77°F (25°C) o r a f l a s h po in t o f 200°F (93.4°C) or h igher sha l l be determined in accordance wi th ASTM D-93, Standard Test Method f o r Flash Point by the Pensky-Martens Closed Tes ter .

Delete ( c ) , ASTM 0-3243, and r e l e t t e r subsequent t e s t methods as a p p r o p r i a t e . SUBSTANTIATION: These changes b r ing NFPA 321 i n t o conformi ty w i th cu r ren t ASTM te~ t methods. COMMITTEE ACTION: Accept.

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PART I I

31- 1 - (1-1.1 and 1-1.2) : Accept SUBMITTER: Technical Committee on L iqu id Fuel Burning Equipment RECOMMENDATION: In 1-1.1 de le te the phrase "except in te rna l . . . . weed burners".

Establ lsh a new I -1 .2 to read: 1-1.2 This standard does not apply to internal

combustion engines, o i l lamps, and por tab le devices such as blow torches, mel t ing pots, and weed burners. SUBSTANTIATION: This cons t i tu tes an e d i t o r i a l c l a r i f i c a t i o n . COMMITTEE ACTION: Accept.

31- 2 - (Figure IB): Accept SUBMITT[R: Technical Committee on Liquid Fuel Burning Equipment RECOMMENDATION: Delete the asterisk in the note adjacent to the figure. SUBSTANTIATION: This is edi tor ia l . The asterisk has no significance. COMMITTEE ACTION: Accept.

31- 3 - (I-6.1(a), (b), (c)): Accept SUBMITTER: Technical Committee on Liquid Fuel Burning Equipment RECOMMENDATION: Change the (a), (I}), (c) format to a direct statement, as follows:

I-6.1 All o i l - f i red appliances other than direct-f ired heaters, l isted kerosene stoves, and l isted portable kerosene heaters, :~hall be chimney connected except as provided in Se,ction I-8. SUBSTANTIATION: This is an editorial c lar i f icat ion: COMMITTEE ACTION: Accept.

31- 6 - (I-10.3): Accept SUBMITTER: Technical Committee on Liquid Fuel Burning Equipment RECOMMENDATION: In the second sentence, insert the word "to" between "pressure" and "15 psi"; and change the "15 psi" to read "15 psig". SUBSTANTIATION: These are editorial corrections. COMMITTEE ACTION: Accept.

(Log #1). 31- 7 - (Not Spec i f ied) : Accept in P r i nc ip l e SUBMITTER: Freder ic M. Blum, Wynnewood, PA RECOMMENDATION: Add a paragraph to requi re a l l o i l - f i red appliances to be f i t ted with an in-l ine, replaceable-element f i l t e r on the oi l supply l ine. SUBSTANTIATION: The oil pump strainer (or equivalent rotary chopper-filter) and the f i l t e r bui l t into the oi l nozzle are not fine enough to remove the finest sediment and sludge, nor can they remove water. Over time, the nozzle can become clogged, leading to soot production and consequent puffbacks; flue pipe and chimney clogging; diminished heating system efficiency; and f i re hazards. COMMITTEE ACTION: Accept in Principle.

Establish a new section 1-10.7 to read: 1-10.7 A suitable oi l f i l t e r shall be provided in

the fuel supply to an oi l burner or o i l - f i red unit burning ASTM Numbers I and 2 fuel o i l . A suitable fuel oi l strainer shall be provided in the fuel supply to an oi l burner or o i l - f i red unit burning ASTM Number 4 or heavier fuel o i i . COMMITTEE COMMENT: The Submitter did not specify a section, nor did he propose specific wording. Nonetheless, the Committee agrees with the concept. In the Submitter's description, i t appears he was concerned only with d i s t i l l a te fuels. Filters are not suitable for residual fuels, so strainers are specified for Number 4 fuel oi l and heavier (the residual fuels).

(Log #2) 31- 4 - (Not Specified): Accept in Principle SUBMITTER: Frederic M. B1um, Wynnewood, PA RECOMMENDATION: Add a paragraph requiring that chimneys be inspected and cleaned i f necessary before install ing oi l burning appliances. SUBSTANTIATION: This is necessary, so much so that I consider i ts omission from NFPA 31 to be an oversight. The chimney can become blocked by f a l l l n g soot deposi ts or mortar. Proper inspect ion must invo lve the use of a strong a r t i f i c i a l l l g h t source, not j u s t day l i g h t f i l t e r i n g down from the top. COMMITTEE ACTION: Accept in P r i nc i p l e .

Establ ish a new 1-7.1.4 to read: 1-7.1.4 Pr io r to i n s t a l l a t i o n of an o i l burner or

o i l - f i r e d un i t , the chimney or vent ing system to which i t is to be connected shal l be ex~nlned by the i n s t a l l e r and shown to be in good,condi t ion and repa i r . COMMITTEE COMMENT: The Committee agrees wi th the substant ia t ion of fered by the Submitter. No spec i f i c wording or sect ion was c i ted , but t h i s add i t i on should s a t i s f y his request and should meet the i n ten t of his proposal.

31- 5 - (I-8.2): Accept SUBMITTER: Technical Committee on Liquid Fuel Burning Equipment RECOMMENDATION: Change I-8.2 to read as follows:

1-8.2 Direct Vent Appliances. Direct vent appliances shall be listed and installed in accordance with their l is t ing and the manufacturer's instruction. SUBSTANTIATION: This change is appropriate, and in fact is editorial in nature, since the definit ion had been changed in a previous edition to direct-vent appliance from sealed combustion appliance. COMMITTEE AqTION: Accept.

31- B - (2-1.2.3(a)): Accept SUBMITTER: Technical Committee on Liquid Fuel Burning Equipment ~ : In 2-I.2.3(a), add a final reference as follows:

"or Standard for Glass-Fiber Reinforced Plastic Underground Storage Tanks for Petroleum Products, UL 1316-83." SUBSTANTIATION: Making reference to this standard is appropriate in that i t recognizes glass-fiber tanks in underground usage, and maintains consistency with NFPA 30, Flammable and Combustible Liquids Code. COMMITTEE ACTION: Accept.

31- 9 - (2-1.2.3(c) (New)): Accept SUBMITTER: Technical Committee on Liquid Fuel Burning Equipment RECOMMENDATION: Establish a new 2-I.2.3(c) to read:

(c) American Society for Testing and Materials, Standard Specification for Glass-Fiber Reinforced Polyester Underground Petroleum Storage Tanks, ASTM D-4021-81. SUBSTANTIATION: Reference to t h i s standard provides coverage to tanks that are suitable for the service and maintains consistency with NFPA 30, Flammable and Combustible Liquids Code. COMMITTEE ACTION: Accept.

(Log ~4) 31- 10 - (2-1 .2 .3 , 2 -3 .1 .3 , 2-4.4, 2 -6 .1 ) : Re jec t SUBMITTER: A. G. Meyers, Clemmer Industries Ltd. RECOMMENDATION: The following paragraphs are suggested for changes to include the ULC standards:

2-I.2.3 Tanks shall be used under substantially atmospheric pressure shall be bui l t in accordance with approved standards of design. Atmospheric tanks may be bui l t in accordance with:

\

121

(a) Underwriters Laboratories Inc., Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids, UL 142, or ULC S6OIM or ULC $630M. Standard for Steel Underground Tanks for Flammable and Combustible Liquids, UL 58 or ULC S603M or ULC S603.1M; or Standard for Steel Inside Tanks for Oil-burner Fuel, UL 80 or ULC $602M.

2-3.1.3 A supply tank larger than 10 gal.(38 L) but not larger than 660 gal (2500 L) shall meet the construction provisions of Standard UL 80 or ULC S602M (see 2-1.2.3(a)), or as provided in 2-1.2.5.

2-4.4 Only a tank meeting the construction provisions of Standards UL 58 and UL 80 or ULC $602 or ULC S603 or ULC S603.IM (see 2-I .2.3(a)) , or as provided in 2-1.2.6, shall be installed enclosed inside of a building.

2-6.1 A tank having a capacity of more than 660 gal (2500 L) shall meet the construction provisions of Standard UL 142 or ULC S6OIM or ULC S630M (see 2-1.2.3(a)), or as provided in 2-1.2.6 or shall comply with API Standard 650 (see 2-1.2.3(b)). SUBSTANTIATION: The Committee should consider applicable Canadian standards both for underground and aboveground tanks. The standards have undergone a great deal of research and study by task groups and are the latest state of the art for tanks. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee has no doubt that the Canadian standards are well researched and that they constitute state of the art technology. However, there is a Canadian standard on oi l burning equipment that is a counterpart to NFPA 31. CSAB 139 is certainly a good standard and is used in Canada, and i t makes references to the relevant Canadian standards and specifications. The NFPA 31 Committee sees no compelling reason to cite the Canadian standards, since references can never be al l - inc lusive, and l i s t ing of too many references might render NFPA 31 unwieldy for use. There are many worthwhile standards developed in other countries as well, and i t would be impractical to l i s t a l l of them.

31- 11 - (2-1.2.4): Accept SUBMITTER: Technical Committee on Liquid Fuel Burning Equipment RECOMMENDATION: Correct the reference from 2-I.23(a) to 2-I.2.3(a). SUBSTANTIATION: This is an edi tor ia l correction. COMMITTEE ACTION: Accept.

31- 12 - (2-2.1): Accept SUBMITTER: Technical Committee on Liquid Fuel Burning Equipment RECOMMENDATION: After the reference to UL 58, add additional references to UL 1316 and to ASTM 0-4021. SUBSTANTIATION: This is an edl tor ia l change (see changes to 2-1.2.3). COMMITTEE ACTION: Accept.

31- 13 - (2-2.4): Accept SUBMITTER: Technical Committee on Liquid Fuel Burning Equipment RECOMMENDATION: Revise section 2-2.4 to read as follows:

2-2.4 Tanks and their piping shall be protected by either:

(a) A properly engineered, installed and maintained cathodic protection system in accordance with recognized standards of design, such as:

(I) American Petroleum Inst i tute Publication 1632-1983, Cathodic Protection of Underground Petroleum Storage Tanks and Piping Systems.

(2) Underwriters Laboratories of Canada ULC-S603.I-M 1982, 'Standard for Galvanic Corrosion Protection Systems for Steel Underground Tanks for Flammable and Combustible Liquids.

(3) Steel Tank Ins t i t u te Standard No. sti-P32, Specif icat ions for st i-P3 System for External Corrosion Protection of Underground Steel Storage Tanks -1983.

(4) National Association of Corrosion Engineers Standard RP-OI-69 (1983 Rev.) Recommended Practice, Control of External Corrosion of Underground or Submerged Metallic Piping Systems.

(b) Corrosion resistant materials of construction such as special al loys, f iber glass reinforced plast ic, or f iber glass reinforced plastic coatings, or equivalent approved system. Selection of the type of protect ion to be employed shall be based upon the corrosion h is tory of the area and the judgment of a qua l i f ied engineer.

The author i ty having j u r i s d i c t i o n may waive the requirements for corrosion protect ion where evidence is provided that such protect ion is not necessary.

(See API Publication 1615-1979, I ns ta l l a t i on of Underground Petroleum Storage Systems, for further information.) SUBSTANTIATION: This revis ion is made in order to achieve consistency with NFPA 30, Flammable and Combustible Liquids Code. COMMITTEE ACTION: Accept.

31- 14 - (2-3.1.3): Accept SUBMITTER: Technical Committee on Liquid Fuel Burning Equipment RECOMMENDATION: Change the reference from 2-1.2.5 to 2-I .2.6. SUBSTANTIATION: This is an edl tor ia l correction. COMMITTEE ACTION: Accept.

31- 15 - (2-4.4): Accept SUBMITTER: Technical Committee on Liquid Fuel Burning Equipment RECOMMENDATION: Delete the reference to UL 58. Keep the reference to UL 80, and add a reference to UL 142. SUBSTANTIATION: The reference to UL 58 is not appropriate, since UL 58 deals with underground tanks. Section 2-4.4 does not deal with underground tanks, but rather with those that are enclosed inside buildings. COMMITTEE ACTION: Accept.

31- 16 - (Table 2-2): Accept SUBMITTER: Technical Committee on Liquid Fuel Burning Equipment RECOMMENDATION: Place an asterisk af ter "Approved foam or inerting system"; at the bottom of the table, adjacent to the asterisk, insert "See NFPA 69, Explosion Prevention Systems". SUBSTANTIATION: This change makes Table 2-2 consistent with i ts counterpart in NFPA 30, Flammable and Combustible Liquids Code. COMMITTEE ACTION: Accept.

31- 17 - (Table 2-5): Accept SUBMITTER: Technical Committee on Liquid Fuel Burning Equipment RECOMMENDATION: Change the "Fixed Roof Tanks" at the top of the table to read:

"Fixed Roof or Horizontal Tanks". SUBSTANTIATION: This wi l l achieve consistency with NFPA 30, Flammable and Combustible Liquids Code, and wi l l o f fer spacing guidance where horizontal tanks are used. COMMITTEE ACTION: Accept.

(Log #5) 31- 18 - (2-6.7.2): Reject SUBMITTER: A. G. Meyers, Clemmer Industries Ltd. RECOMMENDATION: Delete the words "a weak roof- to-shel l seam" from 2-6.7.2. SUBSTANTIAT]ION: A weak roof j o i n t is not achievable on shop fabricated tanks.

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COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The wording in this sentence of 2-6.7.2 is identical with, and is an extraction from, NFPA 30, Flammable and Combustible Liquids Code. In the Committee's opinion, i t should remain as is to be consistent with NFPA 30. In addition, the Submitter o f f e r s no s u b s t a n t i a t i o n to suppor t h is con ten t ion on weak r o o f - t o - s h e l l seams.

31- 19 - (2-6.7.2): Accept SUBMITTER: Technical Committee on Liquid Fuel Burning Equipment RECOMMENDATION: In 2-6.7.2, add a new sentence at the end to read:

"Design methods which wi l l provide a weak roof- to-shel l seam construction are contained in API '650, Welded Steel Tanks for Oil Storage, and UL 142, Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids." SUBSTANTIATION: This addition wi l l bring NFPA 31 into consistency with NFPA 30, Flammable and Combustible Liquids Code. COMMITTEE ACTION: Accept.

31- 20 - (3-3.3): Accept SUBMITTER: Technical Committee or, Liquid Fuel Burning Equlpment RECOMMENDATION: Change the reference from "3-3.6 and Section 3-8" to read "3-3.6 or Section 3-8". ~UB~TANTIATION: This is an edi tor ia l change. COMMITTEE ACTION: Accept.

31- 21 - (Table 4- I ) : Accept SUBMITTER: Technical Committee on Liquid Fuel Burning Equipment RECOMMENDATION: In Table 4-I under "Form I I I , last l lne, change " I f , IV, and IV" to read " I f , IV, and V". SUBSTANTIATION: This is an edi tor ia l change. COMMITTEE ACTION: Accept.

(Log #3) 31- 22 - (Not Specified): Reject SUBMITTER: Alfred J. Hogan, IAFC, Inc. RECOMMENDATION: Add a paragraph as follows:

"Liquid fuel burning heaters may be used when they are:

1. Listed by a nationally recognized testlng agency. 2. Permanently connected to an approved chimney or

vent." SUBSTANTIATION: A serious f i r e problem exists with l iquid fuel burning heaters being located too close to combustibles and in means of egress. As the use of this means of heating has increased, so have the stat is t ics of deaths, in jur ies and extensive property losses as compiled by the U.S. Consumer Product Safety Commission, ISFSI, and the Citizens Committee for Fire Prevention. This proposal is made in the interest of l i f e safety from f i r e and is supported by the Auxil iary Heating Committee of the Fire Marshals Association of North American, ISFSI, and IAFC. CQMMITTEE ACTION: Reject. COMMITTEE COMMENT: No section of the Code is cited by the Submitter. The phrase " l iquid fuel burning heaters" is not defined as a concept or enti ty, and this makes i t somewhat unclear as to the intent of the submission. Based on the Submitter's substantiation, i t appears that the intent is to prohibit a l l devices that are p o r t a b l e . . I f the proposal were to be accepted as stated, a major conf l ic t would be created within the code, and especially with Chapter 5 which deals with portable heaters. Use of the phr.ase "nationally recognized testing laboratory" is also, in the Committee's opinion, inappropriate, since there is no broadly recognized def in i t ion of the term. I t should be noted that Section I-3 of NFPA 31 already indicates.

that al l oil-burning equipment shall be approved, so the authority having jur isdict ion is empowered by the Code to accept or reject heating devices, and Section I-3 indicates that devices that are l is ted may be considered as meeting the requirements of the standard.

A further d i f f i cu l t y is that commercial and industrial type units come under the. scope of this standard, and are often approved without benefit of a l i s t ing ; and many other types of appliances such as portable construction heaters and industrial d i rect - f i red heaters, are not designed for chimney or vent connection and acceptance of the proposal would preclude the use of these appliances. In addition, guidance for proper and safe use of portable heaters would be lost to the Code user, since they are covered

• in Chapter S. Even with instal led heaters, combustible material can be placed too close to heating devices.

I t is the Committee's opinion that oi l burning equipment should be approved, and the Code now provides for that approval. The Code addresses equipment that is not required to be chimney-connected, and i t is not our intent to cease addressing that important subject.

31- 23 - ( 5 - 1 . 2 . 1 ) : Accept SUBMITTER: Technical Committee on L iqu id Fuel Burning Equipment RECOMMENDATION: Change the f i r s t sentence to read:

"Kerosene and o i l stoves and p o r t a b l e kerosene heaters sha l l be equipped wi th a pr imary sa fe t y c o n t r o l , or be i n h e r e n t l y const ruc ted to prevent abnormal d ischarge o f fue l a t the burner in case o f i g n i t i o n f a i l u r e or f lame ex t i ngu ishmen t . " SUBSTANTIATION: The wick type kerosene heater , which is the most p reva len t , does not r e q u i r e a pr imary sa fe t y con t ro l to stop the f low o f o i l in case o f f lame f a i l u r e , nor would t h i s be t e c h n i c a l l y f e a s i b l e .

The oi l flow in a wick fed device wi l l automatically and inherently cease when the flame is extinguished due to the nature of capi l lary action. I t should be remembered too that the wick is the only means of fuel transfer from the reservoir at the bottom of the heater to the combustion chamber above.

There are some wick less type po r tab le kerosene heate rs , however, t ha t employ a vapor ized fue l process where a pr imary sa fe t y con t ro l should be, and . i s , requ i red . COMMITTEE ACTION: Accept.

31- 24 - ( 5 - 1 . 6 . 1 ) : Accept SUBMITTER: Technical Committee on L iqu id Fuel Burning Equipment RECOMMENDATION: Es tab l i sh a new 5-1.6 .1 as f o l l o w s , and renumber present 5-1.6.1 and f o l l o w i n g sec t ions acco rd ing l y :

5-1 .6 .1 P o r t a b l e kerosene heaters sha l l be l i s t e d . SUBSTANTIATION: There are heaters in the marketplace t ha t have not had the b e n e f i t o f t e s t i n g and l i s t i n g , and t h i s i s not approp r ia te in the Committee's op in ion , In a d d i t i o n , there are at l e a s t nine States tha t now requ i re l i s t i n g f o r sa le or use o f po r t ab le kerosene heaters . COMMITTEE ACTION: Accept.

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PART III

35- 1 - (I-6): Accept SUBMITTER: Technical Committee on Manufacture of Organic Coatings RECOMMENDATION: Change the definit ion of "nitrocellulose" from the existing definit ion to:

Nitrocellulose. A nitrated cellulose (cotton l inters or wood pulp) with a nitrogen content ranging from 10.5 percent to 12.6 percent.

(a) Solvent-wet nitrocellulose. A fibrous, granular, cubed or f lake-l ike nitrocellulose wetted with not less than 25 percent by weight alcohol, toluene or othe~ organic l iquid having a flash point not lower than 2S°F (-40°C).

(b) Water-wet nitrocellulose. A fibrous, granular, cubed or flake-like nitrocellulose wetted with not less than 25 percent by weight water.

(c) Plasticized nltrocellulose. A colloided, chip or similar-particle-type nitrocellulose plasticized with not less than 18 percent by weight plasticizing substance such as dibutyl phthalate and dioctyl phthalate.

(d) Dry nitrocellulose. Nitrocellulose containing less than the minimum wetting agents described above. SUBSTANTIATION: The definit ion of nitrocellulose as written does not completely identify the product. As an example, plasticized nitrocellulose, which was not included in the present definit ion, has a different physical form and flammability hazard from solvent - or water-wet nitrocellulose. COMMITTEE ACTION: Accept.

35- 2 - (6- I .1. I ) : Accept SUBMITTER: Technical Committee on Manufacture of Organic Coatings RECOMMENDATION: Replace present section with new 6-1.1.1:

6-1.1.1 Nitrocellulose is a flammable material. I ts burning rate varies depending on i ts wetting agent and degree of dryness.

(a) Solvent-wet nitrocellulose, wet with flammable liquids such as alcohol and toluene, has the same degree of hazard as the flammable wetting agent. The burning rate is similar to the wetting agent alone.

(b) Water-wet nitrocellulose is d i f f i cu l t to ignite and, once ignited, is slower burning than solvent-wet ni trocel I ul ose.

(c) P las t i c i zed n l t r o c e l l u l o s e burns very in tense ly and is a more ser ious f i r e hazard than so lvent wet ni t roce l 1 ul ose.

(d) Dry n i t r o c e l l u l o s e burns r a p i d l y and with intense heat and shal l be avoided in a l l operat ions. SUBSTANTIATION: This proposed s u b s t i t u t i o n includes p l a s t i c l z e d n i t r o c e l l u l o s e and be t t e r descr ibes the f lammab i l i t y of the d i f f e r e n t types of n i t r o c e l l u l o s e . COMMITTEE ACTION: Accept.

3S- 3 - (6-1.2.3): Accept SUBMITTER: Technlcal Committee on Manufacture of Organic Coatings RECOMMENDATION: Revise 6-1.2.3 to read as follows:

6-1.2.3 Drums shal l not be dropped. I f there is a d i f fe rence in e leva t ion , the handl ing equipment shal l not drop, puncture or damage the drums. Always keep drums under con t ro l . SUBSTANTIATION: The add i t i on of "Always keep drums under con t ro l " is j u s t an added caut ion fo r proper handl ing. COMMITTEE ACTION: Accept.

35- 4 - (6-1.3.1(a)): Accept SUBMITTER: Technical Committee on Manufacture of Organic Coatings RECOMMENDATION: Revise 6-I.3.1(a) to read as follows:

6-1.3.1 Nitrocellulose shall bestored as follows: (a) In a room or building attached to the production

area, separation shall be by a f i re wall with a f i re resistance rating of not less than 2 hours with openings equipped with approved f i re doors. The f i re doors shall be controlled by fusible links mounted on both sides of the wall. The room shall be equipped with an automatic sprinkler system providing a density of 0.35 gpm per sq f t over the entire storage area. A deluge type system is preferred. SUBSTANTIATION: These changes define the f i re resistance rating of the " f i re wall" (2 hours), and describe the "preferred" type of sprinkler protection (deluge). This addition should help users in the design of storage fac i l i t ies . COMMITTEE ACTXQN: Accept.

35- 5 - (6-1.3.1(b) and (c)): Accept SUBMITTER: Technical Committee on Manufacture of Organic Coatings RECOMMENDATXON: Revise 6-I.3.1(b) as follows:

(b) On a detached pad or in a detached noncombustible structure such as a roofed shed, located as shown in Table 6-1.3.1. A sprinkler system providing a density of 0.35 gpm per sq f t (1.3 L/min) is recommended but not mandatory. I f , however, the recommended sprinkler system is provided, the distances in Table 6-1.3.1 can be reduced by one-half.

Table 6-1.3.1 Wet N i t r o c e l l u l o s e Distance * of Prdperty Line or

(Dry Weight) Nearest Important Bu i ld ing

Pounds Feet (Meters)

Up to 1,000 SO (15) 1,000-5,000 75 (23) 5,000-10,000 100 (30) 10,000-2S,000 125 (38) 25,000-50,000 150 (45)

Over SO,O00 As Approved by Au thor i t y Having Jurisdiction

*Note: I f s p r i n k l e r p ro tec t ion is provided as recommended in 6-1 .3 .1(b) as wel l as the other recommendations in Section 6-1.3, the distances shown can be reduced by one-ha l f .

0e le te 6 -1 .3 .1 (c ) . SUBSTANTIATION: TEe proposed tab le is based on a standard developed by the New Jersey Bureau of Engineering and Safety. Many years of experience ind i ca te tha t the distances are both reasonable and safe. The tab le w i l l provide code users wi th a be t te r guide fo r s to r i ng var ious quan t i t i e s of n i t r o c e l l u l o s e . With these rev is ions to paragraphs (a) and (b) , paragraph (c) is no longer needed, nor is i t app l i cab le . COMMITTEE ACTION: Accept.

35- 6 - (6 -1 .3 .6 , 6-1.3.7 and 6-1.3 .8 (New)): Accept SUBMITTER: Technical Committee on Manufacture of Organic Coatings RECOMMENOATION: Add new sect ions 6-1 .3 .6 , 6-1.3.7 and 6-1.3 .8 as fo l l ows :

6-1 .3 .6 N i t r o c e l l u l o s e shal l be stored only in approved DOT closed conta iners. Before s to r ing drums, make sure t h e i r c losures are t i g h t in order to prevent loss of wet t ing agent by evaporat ion.

6-1.3.7 Heat should be avoided in the storage area. Where heat is necessary, the bu i l d i ng should be equipped wi th low-pressure steam or hot -water rad ia to rs . These shal l be so located as to avoid contact wi th the drums of n i t r o c e l l u l o s e under any circumstance~. Overheating of drums by d i r e c t contact wi th hot surfaces or by storage in an overheated environment may cause pressure bui ldup in the drums and eventual release o f the l i d .

124

6-1.3.8 The storage area shall be marked with a readily visible sign identifyding the material and i ts hazard - i .e . , "NITROCELLULOSE - FLAMMABLE - KEEP HEAT, SPARKS, AND FLAME AWAY." SUBSTANTIATION: Section 6-1.3.6 offers an additional caution towarn against the potent ia l for n i t roce l lu lose drying out i f the l i ds are not in place and tightened on the drums. Sections 6-1.3.7 and 6-1.3.8 are sel f -explanatory, and, in the opinion of the Committee, should add to safe handl ing. COMMITTEE ACTION: Accept.

35- 7 - (6-~.4.1): Accept SUBMITTER: Technical Committee on Manufacture of Organic Coatings RECOMMENDATION: Revise 6-1.4.1 to read as follows:

6-I.4.1 The amount of nitrtocellulose brought into the operating area shall be kept to a min!mum and'not exceed that required for a shift.~ Drums should remain closed until ready for use. When only part of a drum is used; the l i d and r ing should E,e replaced immediatelyand the ring tightened. SUBSTANTIATION: The emphasis on keeping the l ids on the drums is in order tO reduce the potential for the drying of nitrocellulose. COMMITTEE ACTION: Accept.

35- 8 - (6-1.4.3): Accept SUBMITTER: Technical Committee on Manufacture of Organic Coatings RECOMMENDATION: Revise 6-1.4.3 to read as follows:

6-1.4.3 Any nitrocellulose which may be spil led on the floor or elsewhere shall be promptly wet down with water, swept up, and put into a pail or covered metal container which contains water. The material should be removed at the end of the day or shift and disposed of properly (see 6-1.5.1). SUBSTANTIATION: Since solvent can evaporate from spilled nitrocellulose, i t should be wetted with water prior to being swept up. COMMITTEE ACTION: Accept.

35- g - (6-1,4.5 and 6-1.4.6): Accept SUBMITTER: Technical Committee on Manufacture of Organic Coatings RECOMMENDATION: Add a new 6-1.4.5 and 6-1.4.6 a s

fol lows: 6-1.4.5 Since there is always danger of i gn i t i on of

n i t roce l lu lose or i t s solvents, d i luents or solut ions from struck sparks, f r i c t i ona l heat, flame, or s ta t i c e l e c t r l c i t y , care shall be taken to el iminate these sources of ign i t ion .

6-1.4.6 Solvent wet and p last ic ized n i t roce l lu lose are free-flowing materials which c.ln generate static e lectr lc i ty while being poured from the drum. To prevent hazardous accumulations of static charge, drums, containers, rings of fiber ,Jrums and vessels shall be bonded and grounded during transfer operations. SUBSTANTIATION: In the Committee's opinion, these add!tions are self-explanatory but necessary precautionary provis!ons that should be included in the Code. COMMITTEE ACTION: Accept.

35- 10 - (6-1.5.1): Accept SUBMITTER: Technical Committee on Manufacture of Organic Coatings RECOMMENDATIONI Revise 6-1.5.1 to read as follows:

6~I.5.1 Sweepings and other small quantities of waste nitrocellulose shall be wet down with water and placed in a covered metal container. Dispose of the waste material by burning in a safe, isolated location or denitrating in an agitated, 5 percent sodium hydroxide aqueous solution in a well ventilated area. Disposal shall nqt be by burning in a boiler f i re box, incinerator, or other confined equipment. Burning shall only be conducted in accordance with federal, state, or local regulations regarding pollution.

SUBSTANTIATIQN: The addition Of the disposal metho d recommending 5 percent sodium hydroxide gives the user an alternatiye for disposing of small quantities, and ~s based on extensive experience and testing. COMMITTEE ACTION: Accept.

35- 11 - (6-3.1): Accept in Part (Log #I): SUBMITTER: Kenneth L. Zacharias, National Paint and Coating s Assn. RECOMMENDATION: Change last sentence to read:

"Only general details can be offered here, and the suppliers shall be consulted whenever these materials are to be used." SUBSTANTIATION: The supplier is a more appropr!ate source of information on organic peroxides than the authority having jur isdict ion. COMMITTEE ACTION: Accept in Part.

Insert "suppliers" but keep the reference to the authority having jur isdict ion, also. The final sentence wi l l read:

"Only general details can be offered here, and suppliers and the authority having jur isdict ion shall be consulted whenever these materials are to be used." COMMITTEE COMMENT: The Committee agrees that' the sdpplier is an appropriate source of information on organic peroxides, but the authority having jurisdict ion should not be excluded from th e consulting procedure.

(Log #2) 35- 12 - (7-2.1): Accept in Part SUBMITTER: Kenneth L. Zacharias, National Paint and Coatings Assn. RECOMMENDATION: Amend 7-2.1 to read:

7-2.1 Al l equipment sHch as tanks, machinery and piping where a flammable mixture may be present shall be bonded and connected to a ground.

The bond or ground or both sha11, be phys ica l ly applied or shall be inherent ly present, by the'nature of the. i n s ta l l a t l on . For s ta t i c d lss ipat lon purposes, th is e l e c t r l c a l l y conductive path shall not have a resistance of more than 25 ohms toground. SUBSTANTIATION: NPCA Sc ien t i f i c Circular No. 803, Generation and Control of Stat ic E l e c t r i c i t y , and NFPA 77, Recommended Practice on Stat ic E l e c t r i c i t y , provide information on t h i s subject.

Comment: Change to flammable would be a bet ter descr ipt ion of

hazard. Reference to NPCA Sc ien t i f i c Circular would re late paragraph to current industry pract ice.

(The task force questions the v a l i d i t y of "one mi l l i on ohms to ground" for s ta t i c d iss ipat ion purposes, as given in th is section.. The general p rac t ice- for industry is not morethan 25 ohms resistance for s ta t i c l !nes. ) COMMITTEE ACTION: Accept in Part.

The f i r s t sentence, which subst i tu tes the wor d "flammable" for the word " i g n l t l b ] e " is acceptable as an ed i to r ia l change. The remainder of the proposal is rejected by the Committee, and shall remain as presently writteq in the Code. COMMITTEE COMMENT: NFPA 77, Recommended Practice on Static Electr ic i ty, is referred to in 7-2.1, ~nd i t advises an electr ical ly conductive path of not more than one mil l ion ohms t o ground. I t would be inappropriate to include a reference that differs with this recommendation, and the Committee is convinced that the one miil lon ohm value should remain.

125

PART IV

327- I - ( I - I ) : Accept SUBMITTER: Technical Committee on Tank Leakage and Repair Safeguards RECOMMENDATION: In l ine I, change "are recommended for" to read "concern themselves with". SUBSTANTIATION: This is an editorial change. Use of the word "recommended" may appear to be misleading, since NFPA 327 is a standard procedure. COMMITTEE ACTION: Accept.

PART V

328- 1 - (Appendix B (New)): Accep t . SUBMITTER: Technical Committee on Tank Leakage and Repair Safeguards RECOMMENDATION: Estab l ish an Appendix sect idn to include referenced pub l i ca t i ons , and update such references as needed. SUBSTANTIATION: This is in keeping wi th es tab l ished NFPA procedure and s t y l e . COMMITTEE ACTION: Accept .

327- 2 - (I-2): Accept SUBMITTER: Technical Committee on Tank Leakage and Repair Safeguards RECOMMENDATION: Update referenced standards and develop a new chapter to include appropriate referenced standards. SUBSTANTIATION: This is in keeping with estab l ished NFPA style and procedures. COMMITTEE ACTION: Accept.

327- 3 - (I-3): Accept SUBMITTER: Technical Committee on Tank Leakage and Repair Safeguards RECOMMENDATION: Under definit ion of "Liquids (b) Flammable Liquid" insert "2068 mm Hg" following "40 Ib per sq in." SUBSTANTIATION: This is edi tor ial , and is consistent with NFPA 30, Flammable and Combustible Liquids Code. COMMITTEE ACTION: Accept.

(Log #) 328- 2 ; (Appendix B): Accept SUBMITTER: Technical Committee on Tank Leakage and Repair Safeguards RECOMMENDATION: Delete Appendix B, Analysls of Causes of Explosions: SUBSTANTIATION: Many of the inc idents l i s t e d are decades o ld . In add i t i on , the Committee fee ls that the Appendix does not serve a useful purpose r e l a t i v e to the recommended p rac t i ce . In format ion on such inc idents can be obtained from NFPA upon request. COMMITTEE ACTION: Accept.

327- 4 - (I-3): Accept SUBMITTER: Technical Committee on Tank Leakage and Repair Safeguards RECOMMENDATION: Insert definit ion of "Unstable Liquid" as follows:

Unstable (Reactive) Liquid. A l iquid which in the pure state or as commercially produced or transported wi l l vigorously polymerlze, decompose, condense, or wi l l become self-reactive under conditions of shock, pressure or temperature. SUBSTANTIATION: Subsection 2-1.3 of NFPA 327 mentions unstable or reactive materials, and so a definit ion should be included. This d e f i n i t i o n is the same as that used in NFPA 30, Flammable and Combustible L iquids Code. COMMITTEE ACTION: Accept.

126

PART VI

(Log'#24) 329- 1 - (Ti t le) : Reject SUBMITTER: Rudy White, Americar Petroleum Institute RECOMMENDATION: A proposal is ~ade to change document t i t l e from: - . ' .

"NFPA 329, Underground Leakage of Flammable and Combustible L iqu ids 1983" to : " ". ' ' .

"NFPA 329, Recommended P r a c t i c e . - Underground Leakage of Flammable and Combustible Liquids 1983." ' SUBSTANTIATION: NFPA 329 is a r_e,_~ommended oractlce (vs. a code) and should be identif ied as such on the front cover. This is consisten~ with other NFPA documents e.g. NFPA 30 i COMMITTEE ACTION: Re jec t . I " COMMITTEECOMMENT: This proposal d e a l s wi th a request tha t i s beyond the Committee's ~ b i l i t y to handle or c o n t r o l . NFPA " ~ • determines the 'word ing and format on the pamphlet cover , and not the Committee.

1 (Log #25) 329- 2 - (Front' Cover): Accept~in Part SUBMITTER: Rudy White, American Petroleum Institute RECOMMENDATION: A proposal is ~ade to emphasize paragraph 4 content through cha~ges in paragraph spacing and/or the use of bold ~r i ta l ic ized type. SUBSTANTIATION: Many new regulations are being developed at the federal, state land local levels which may or may not contain al l or a Iportion of NFPA 329. In l ight of that fact, the infor~nation contained in this paragraph, i f easily found, I wi l l l imi t confusion and costly mistakes in the future. COMMITTEE ACTION: Accept in Parlt.

Establish a foreword for NFPA ,329 to read: "NFPA does not, by the publicaltion of this document,

. . . . I , • • ~ntend to urge action which ~s not ~n compliance w~th applicable laws and this documenlt may not be construed as doing so. Users of this document should consult applicable Federal, State and lo'cal laws and regulations~" I COMMITTEE COMMENT: In the Committee's opinion, this foreword wi l l satisfy the Submitter's intent.

(Log #26) 329- 3 - (Chapter 2): Accept in Part SUBMITTER: Rudy White, American, Petroleum Institute RECOMMENDATION: A proposal is made to include an additional chapter in NFPA 329. I The chapter, to precede existing Chapter 2, is entit led "Chapter 2 Leak Detection Through Inventory Cont~o1." The purpose of the chapter is to inform the rea~er of the importance of proper inventory control records in assessing leakage of combustible and flammable liquids from underground storage fac i l i t i es . }

Chapter 2 Leak Detection Through Inventory Control

• . . I • 2-I General. I t is c r l t l ca l l y important that underground tank and piping leaks ~e detected as early as possible to avoid potential h~zards and environmental damage. The opera,or of a tank system should make every effort to identify losses as they

I ,

occur; he cannot afford to rely on detectlng the . . . . r . ' £1ammable or combustlble l lquld once i t has leaked from

his underground storage fac i l i t y l i n to the surrounding s o i l . I

Dai l y i nven to ry con t ro l procedures are the key to e a r l y leak d e t e c t i o n . A consc~ent,ous program cons i s t i ng o f d a i l y stock accoun~i,~g and pe r i od i c review of inventory data are an operator's " f i r s t l ine of defense" against underground leaks.

I 2-2 Inventory Control Procedure:~. • I , 2-2.1 Tanks with Metered D1spenslng. For this

method to be effective, al l meters which measure l i q u i d t

dispensed from the underground system should be properly calibrated. A meter which reads signif icantly higher than actual volume pumpedlmay be hiding a leak. Conversely, a meter which indicates less than the true

I volume may suggest a leak where one does not exist.

127

2-2.1 .1 Da i l y Procedures. At the beginning o f each business day (o r s h i f t ) , tank volume should be manual ly measured using a gage s t i c k or o the r means and a calibration chart to convert the tank level into gallons. This gaging operation should be ca'rried out with great care to insure maximum accuracy. ~ Opening meter total izer readings should also be recorded for each dispenser.

When liquid is added to the underground tank, the tank volume should be gaged both before and after the delivery. The operator should also check his tank for the presence of water using a water finding paste on the end of the gage stick. This should be done on a daily basis as part of the opening ~outine as well as immediately after any delivery into the tank. Water which is detected should be accounted for in. the inventory procedures and any significant accumulation ( i .e. greater than I/2 in.) should be promptly removed.

At the close of the business day (or the end of the shif t) , tank volume should again be gaged and meter totalizer'readings recorded. The differences,between the opening and closing total izer readings is the sales for the inventory period. All readings which are recorded as part of this procedure should be kept in a safe location and retained for a minimum of one year. Detailed instructions covering tank gaging, water gaging, meter calibration checks and recordkeeping are contained in the American Petroleum Institute Publication 1621.

2-2.1.2 Daily Reconciliation. Inventory reconciliation consists of comparing the measured closing inventory to the "book inventory" which is obtained by adding deliveries and subtracting sales and on site usage from the measured opening inventory• Due to variables inherent in the process, this . " reconciliation wil l rarely balance exactly to the gallon and small daily "over" or "short" figures are to be expected. The calculated variance should be carried forward each day with the new over or short f igure added (algebraically) to that of the previous day. Using this technique, the operator is able to identify trends over.time; daily fluctuations tend to'cancel out over the long term.

2-2.1.3 Inventory Reviews. The operator of an underground tank system storing flan~able or combustible liquids should review his daily inventory records once a week. He should be concerned with small but growing daily losses or sudden unexplained change~ from the established pattern. Either of these symptons could indicate a potential l e a k .

For a fac i l i t y which stores more than one variety of similar l iquid (such as a retai le servlce station), the operator should compare inventory records for the various tank systems. This wi l l mitigate the effect of temperature - induced erros on the inventory accounting. Since the impact of temperature should be roughly the same, a significant difference in the inventory variance from one product to the next may indicate a leak. The f i rs t step in investigating this would be to check the meter calibrations on the support system.

At the end of each month, the operator shoGld again review his daily inventory accounting. A cumulative shortage which is greater than 0.5 percent of the system throughput for the month may suggest a leak. The operator should look closely to see i f the negative variance is a one-time fluctuation or if-the~e is a consistent negative trend throughout the inventory period. As a further means of detecting leaks using inventory control, "action numbers" have been developed which equate the cumulative number of daily inventory shortages with the probability of leakage (US EPA, 1984). The "action numbers" indicate what number of shortages (or averages) constitute a significant trend and thus a potential problem.

2-2.2 Tanks Without Metered Dispensing. For these " systems, the inventory review is complicated by the fact that a11 withdrawals can only be measured by gaging the tank. Tank levels should be accurately gaged and recorded before and af ter any input or withdrawal. To determine i f the storage system is losing l iquid, the operator should compare the volume before an input or withdrawal with the measured volume after the previous input or withdrawal. This loss or gain figure for each period of tank inact iv i ty should

be carried forward and a cumulative variance maintained by adding the gain or subtracting the loss from the previous number. Since tank gaging errors are completely random, they should tend to cancel out from one measurement to the next. A consistent and increasing negative or positive trend indicates a potential leak which should be investigated.

References 1. American Petroleum Inst i tute Publication 1621:

Recommended Practice for Bulk Liouid Stock Control at Retail Outlets. Third Edition. 1977.

2. Environmental Protection Agency: More About Leakino Underaround Storaoe Tanks: A Backoround Bookle~ for the Chemical Advisory, October-1984.

3. Radian Corporation: Analysis of Factors Affectlna Service Station Inventory Control, prepared for API, July 1984. SUBSTANTIATION: Accurate inventory control records are the " f i r s t l ine of defense" in preventing and detecting leaks. Leakage of combustible and flammable l iquids especially in underground tank f a c i l i t i e s is very d i f f i c u l t to detect. Without the benefits of properly maintained inventory control records, leak investigation leads direct ly to more extensive and expensive procedures such as precision testing, monitoring well instal lat ion and testing etc. In many cases, these procedures may not be necessary when a primary search, including examination of inventory control records, is conducted. In fact, inventory control records may help expidite search procedures.

NFPA 329, in Section 4-3 does recommend a careful check of inventory control records when testing for underground leaks. However, no information is conveyed as to how to prepare and ef fect ive ly u t i l i ze such records. The proposed new Chapter 2 wi l l f i l l the informational void and outline the necessary steps to be taken in using inventory control records to detect leaks. COMMITTEE ACTION: Accept in Part.

Following subsection 4-3.1 a reference wi l l be made "(See Appendix C for a description of inventory control procedures)"; and following subsection 3-2.2.2(e), a reference wil l be made "(See Appendix C)". The material submitted wi l l be established as a new Appendix C, but with some changes to the submitted text, as follows: The t i t l e wi l l read "Inventory control Procedures"; Section 2-I of the text ent i t led "General" wi l l be deleted; the last subsection 2-2.1.3 wil l be changed by deleting the last two sentences that deal with action numbers; following th e last paragraph, change the word "References" to read "For additional information on the subject, see the following". COMMITTEE COMMENT: The Committee agrees that i t would be appropriate to have wording on inventory control, but feels i t belongs in an Appendix section rather than in a Chapter. The revisions to the submission are edi tor ia l in nature.

(Log #I) 329- 5 - (4-1.4): Reject SUBMITTER: Joseph R. Hooney, New Orleans, LA RECOMMENDATION: Revise 4- I .4 as follows:

4-1.4 Regardless of the testing procedure involved, keep in mind that l iquid-handling equipment should be tes ted in a cond i t i on as c lose as poss ib le to normal ope ra t i ng cond i t i on . "Normal , " as r e l a t e d to f i l l i n g and s torage o f products in underground tanks, i s f i l l i n g up to, or near, to, the top o f the f i l l - p i p e . In actual operation, the system cannot be f i l l e d any higher than that. Therefore, the addition of a " r iser" or a stand-plpe and f i l l i n g into such " r iser" or stand-pipe imposes an abnormal l iquid head pressure on the system and wi l l d is tor t (magnify) the true leakage rate, i f a leak or leaks exist . The addition of a short r iser (e.g., extending to a maximum of 1 f t above driveway grade) is permitted in order to accommodate the instruments used in some testing systems; even such a short r iser wi l l exaggerate the leakage rate, but to a re la t ive ly minor degree.

Testing at "normal" operating conditions is par t icu lar ly important when testing equipment which is underground or otherwise concealed. There are several important reasons for this. SUBSTANTIATION: Proposal is submitted in order to eliminate problem of distort ion of leakage rates ( in underground tank testing) caused by excessive test pressures, i .e . , pressures greater than the normal pressure encountered in day-to-day f ie ld operations. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The purpose of testing, in the Committee's opinion, is to determine whether or not there is a leak, and not whether or not a part icular test distorts the leak.

(Log #2) 329- 6 - ( 4 - 1 . 4 . 4 ) : Reject SUBMITTER: Joseph R. Mooney, New Orleans, LA RECOMMENDATION: Revise 4-1.4.4 as follows:

4-1.4.4 Excessive pressures or tests by nonrepresentative l iquids may indicate leaks where none existed or conceal leaks where one, in fact, exists. Excessive pressure, i .e . , pressure greater than that exper ienced under normal operating conditions, can also be imposed by the use of "r isers" or stand-pipes; such devices should nut be used (see the exception to this general rule in 4-1.4). SUBSTANTIATION: Proposal is submitted in order to eliminate problem of distort ion of leakage rates ( in underground tank testing) caused by excessive test pressures, i .e . , pressures greater than the noi-mal pressures encountered in day-to-day f ie ld operations. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See action on proposal 329-5, (4 -1 .4 ) .

(Log #8) 329- 4 - ( 4 -1 .3 ) : Accept SUBMITTER: 3oyce A. Rizzo, Hunter Environmental Serv ices, Inc. RECOMMENDATION: Revise 4-1.3 as f o l l o w s :

4-1 .3 One or more o f these p r e l i m i n a r y t es t s would be p a r t i c u l a r l y des i r ab l e i f p rec ise Prec is ion t e s t equipment is not immediately a v a i l a b l e . I f such equipment i s a v a i l a b l e , t ime and l abo r costs may be reduced by immediately making a Prec is ion Test. SUBSTANTIATION: Language should agree wi th 1983 Prec is ion Test Sect ion 4-3.10. COMMITTEE ACTION: Accept.

Delete the word "p rec i se " and c a p i t a l i z e "P rec i s i on Test " . Also, in 4 -3 .2 , on the l a s t l i n e , de le te the word "p rec i se " before "P rec i s ion Tes t " . COMMITTEE CQMHEN~: The Committee agrees wi th the Subs tan t i a t i on , but has made e d i t o r i a l changes f o r better reading.

329- 7 - ( 4 - 1 . 4 ) : Accept SUBMITTER: Technical Committee on Tank Leakage and Repai r Safeguards RECOMMENDATION: Revise to read as f o l l o w s :

4 -1 .4 Regardless o f the t e s t i n g procedure i nvo l ved , keep in mind t ha t l i q u i d - h a n d l i n g equipment should be tes ted in a cond i t i on as c lose as poss ib le to ope ra t i ng c o n d i t i o n s . Excessive pressures or t es t s by non rep resen ta t i ve l i q u i d s may i n d i c a t e leaks where none ex i s ted or conceal leaks where one, in f a c t , e x i s t s .

A lso, the Committee decided to de le te 4-1 .4 .1 through 4 -1 .4 .4 . COMMITTEE ACTION: Accept. COMMITTEE COMMENT: Subsect ions 4 - 1 . 4 . 1 , 4 -1 .4 .2 and 4 -1 .4 .3 are not r e l evan t to the sub jec t a t hand and are not needed. The rev ised 4 -1 .4 combines the e x i s t i n g 4 -1 .4 and 4 -1 .4 .4 , and improves understanding o f t h i s sec t i on .

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I (Log #9) 329- 8 - (4-2.4): Accept | SUBMITTER: Joyce A. Ri~zo, Hunter Environmental Services, Inc. I RECOMMENDATION: Revise 4-2.4 as follows:

4-2.4 Temperature change may falsely indicate a loss. The volume of petroleum products is highly sensitive to temperature change. A drop of one degree Fahrenheit wi l l shrink 1,000 gal (~;785L) of gasoline by "O.7".gal (2.2L). This may at f i r s t seem small but consider a typical example. In the spring, the ground wi l l s t i l l be relatively cool from the preceding cold weather, while liquids stored and transported aboveground may be relat ively warm.. SUBSTANTIATION: Update to agree w~th new data presented in Figure 2 of Chapter IV. COMMITTEE ACTION: Accept.

(Log #10) 329- 9 - (4-2.5): Accept SUBMITTER: Joyce A. Rizzo, Hunter Environmental Services, Inc. RECOMMENDATION: Revise 4-2.5 as follows:

4-2.5 A typical underground storage tank may handle 20,000 gal (75,700 L) in one month. I f , on the average, this liquid cooled 5°F (2.8°C) after delivery, stock records wi l l show a loss of 5 X .7 X 20 = 70 gal (265L). Ten degrees cooling would appear as a 140 gal (530L) loss for 20,000 gal (75,700L) handled, and 280 gal (l,060L) loss for 40,000 gal (151,400L) handled. Obviously a temperature increase would have the opposite effect and could actually conceal a physical loss. SUBSTANTIATION: Update to agree with data presented with Figure 2 of Chapter IV. COMMITTEE ACTION: Accept.

Insert the word "gasoline" on the f i rs t l ine between "underground" and "storage". COMMITTEE COMMENT: The Committee agrees with the Submitter, and adds one word for editorial c lar i f icat ion.

(Log #3) 329- 10 - (4-3.1.5 (New)): Accept in Part SUBMITTER: Richard P. Wilkinson, Veeder-Root RECOMMENDATION: Establish a new Section 4-3.1.5 as follows:

4-3.1.5 When acceptable to the authority having jurisdiction, in-tank monitoring systems that incorporate automatic gauging equipment may be used to accomplish inventory control and leak detection. SUBSTANTIATION: Testing leaks and lines for leakage can be more easily accomplished i f an underground storage system is equipped with automatic tank gauging equipment. Automatic gauges are designed to measure f luid levels more precisely than tlraditional "dip stick" methods and can therefore provide more accurate inventory records. These systems ,zlso often provide leak detection features which can help in determining the source of a leak. This type of equipment is relatively new and has not been previously included as part of NFPA 329. COMMITTEE ACTION: Accept in Part.

Delete subsections 4-3.1.3 and 4-3.1.4, and establish a new 4-3.1.3 to read:

4-3.1.3 In-tank monitoring systems that incorporate automatic gauging equipment may be used to accomplish inventory control and to indicate possible leakage. COMMITTEE COMMENT: This action accepts in-tank monitoring as feasible for inventory control, but not as an alternate to the Precision Test.

(Log #11) 329- 11 - (4-3.6, 4-3.6.1): Accept in Part (4-3.5, 4-3.5.1) SUBMITTER: 3oyce A. Rizzo, Hunter Environmental Services, Inc. RECOMMENDATION: Revise as follows:

4-3.6 HydrostaticTest of Piping. 4-3.6.1 Isolate the piping and conduct a hydrostatic

pressure test at 150 percent of the anticipated pressure of the system, but not less than 5 Ibs per square inch (34.48 kPa) gauge at the highest point of the system. The test shall be maintained for at least 10 minutes. I f the pressure drops more than 5 psi (260 mm Hg) per minute, i t indicates the probabil i ty of entrained air. Any pressure drop less than 5 psi (260 mm Hg) per minute is inclusive as i t may be caused by cooling. I f the test continues to indicate a leak, appropriate action must be taken. SUBSTANTIATION: 50 psi was or ig inal ly set for the test based on i ts being 150 percent times the typical discharge pressure of a remote/submersible pumping system at a service station which is usually 30-35 psi. Since every l ine has different operating pressures, the 50 psi is not appropriate in al l circumstances, the intent is 150 percent as proposed and as is the case in NFPA 30, Section 3-7.

Time factor is necessary to provide guidance for how long the test needs to be conducted. COMMITTEE ACTION: Accept in Part. • Rewrite 4-3.6 and place i t in the text as 4-3.5. Have present 4-3.5 renumbered as 4-3.6.

4-3.5 Hydrostatic Test of Piping. 4-3.5.1 Isolate the piping and conduct a hydrostatic

pressure test at 150 percent of the maximum anticipated pressure of the system, but not less than 5 Ib per sq in. (34.48 kPa) gauge at the highest point of the system. The test should be maintained for at least 10 minutes. I f the pressure drops, i t indicates the possibi l i ty of a leak in the piping and i t is recommended that a volumetric test be performed. I t should be noted that a loss of l iquid pressure can be attributed to the following: a l ine leak; a decrease in l iquid temperature in the l lne; piping distortion due to the l iquid pressure; or entrapped vapor in the piping. Accumulated l iquid loss during a volumetric test of more than 0.05 gallons per hour during timed restoration may indicate a leak in the piping. COMMITTEE COMMENT: The Committee agrees with the submitted substantiation. Changing the subsection to 4-3.5 in the text order enhances the reader's understanding of the pamphlet.

(Log #28) 329- 12 - (4-3.6.1): Accept in Part SUBMITTER: Rudy White, American Petroleum Institute RECOMMENDATION: A proposal is made to indicate the ava i lab i l i ty of methods to assess the effects of cooling on hydrostatic testing of piping. I t is recommended that the following sentence be incorporated. in the paragraph after the fourth existing sentence:

"The effects of cooling can be estimated through temperature monitoring or other means during the hydrostatic test." SUBSTANTIATION: Since most common combustible and flammable liquids have volumetric coefficients of expansion large enough to affect a hydrostatic test of piping, the temperature of the l iquid should be carefully monitored. Note that a recommendation is made for tanks in NFPA 329 Section 4-3.11.3. Also, API Recommended Practice 1110 (page 3) suggests temperature monitoring during a hydrostatic test of piping. ~OMMITTEE ACTION: Accept in Part.

See Committee Action on 329-11. COMMITTEE COMMENT: The change to present 4-3.6.1 (new 4-3.5.1) alludes to the effect of temperature on testing, but the Committee does not think that monitoring product temperature in piping is practical or feasible.

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(Log #12) 329- 13 - (4-3.7.1): Accept SUBMITTER: Joyce A. Rizzo, Hunter Environmental Services, Inc. RECOMMENDATION: Revise as follows:

4-3.7 Discharge Pipe Line Testing (pipe under pressure from remote pump).

4-3.7.1 Quite often pumps are located in the tank, or, on some rare occasions, just above the tank but remote from the dispensing devices. In such cases, the pipe to the dispensing equipment operates under pressure. A leak in this l ine wi l l cause rapid loss of pressure a f ter the pump is turned o f f . This can be checked using the procedure described in Section 4-3.6 or i f not practical, in the following manner. SUBSTANTIATION: The preferable procedure is to test the system at 150 percent of i ts maximum operating pressure as described in 4-3.6 to assure that i f weaknesses exist they are discovered. COMMITTEE ACTION: Accept.

Change the reference from subsection 4-3.6 to read 4-3.5 in the last sentence, in l ight of Committee Action on 329-11.

329- 14 - (4-3.6.5 (New)): Accept SUBMITTER: Technical Committee on Tank Leakage and Repair Safeguards RECOMMENDATION: Renumber subsection 4-3.5 as subsection 4-3.6. (See action on 329-11.) Establish a new 4-3.6.5 to read:

4-3.6.5 A l iquid volumetric pressure test can be performed on a suction l ine by connecting to the exi t port of the air .el iminator, or other appropriate f i t t i ng . This connection wi l l permit pressure to be applied to the suction piping from the pump to the check valve. In this test, the hydrostatic pressure should not exceed 15 psi in order to prevent damage to the pump. COMMITTEE ACTION: Accept. COMMITTEE COMMENT: This new section explains how a l iquid volumetric test can be performed. The subject was not covered in previous editions, and the Committee feels that i t should be described.

(Log #13) 329- 15 - (4-3.7.2): Accept in Part SUBMITTER: Joyce A. Rizzo, Hunte~ Environmental Services, Inc. RECOMMENDATION: Revise 4-3.7.2 as follows:

"4-3.7.2 . . . Start the pump, note the maximum pressure, seat the check valve, turn o f f the pump and observe any pressure drop. The test shall be maintained for at least lO minutes . . ." SUBSTANTIATION: The 25 to 35 psi is specific to service station applications and can be misleading.

The time factor is necessary to provide guidance for how long the test needs to be conducted. COMMITTEE ACTIQN: Accept in Part.

In the present 4-3.7.2, a l l wording after "and observe any pressure drop" is to be deleted.

After the Submitter's last sentence, include the following wording:

" I f the pressure drops, i t indicates the possib i l i ty of a leak in the piping and i t is recommended that a volumetric test be performed. I t should be noted that a loss of l iquid pressure can be attributed to the following: a l ine leak; a decrease in l iquid temperature in the l ine; piping distort ion due to the l iquid pressure; or entrapped vapor in the piping. Accumulated l iquid losses during a volumetric test of more than 0.05 gallons per hour during timed restoration may indicate a leak in the piping." COMMITTEE COMMENT: The Committee agrees with the Submitter's substantiation. Addition of the Committee's wording achieves consistency with the wording on hydrostatic test of piping.

329- 16 - (4-3.7.3): Accept SUBMITTER: Technical Committee on Tank Leakage and Repair Safeguards RECOMMENDATION: Renumber 4-3.7.3 as 4-3.8, and number al l subsequent sections accordingly. SUBSTANTIATION: This is an edi tor ia l correction. COMMITTEE ACTION: Accept.

(Log #4) 329- 17 - (4-3.10.I): Reject SUBMITT{R: George Lomax, Heath Consultants RECOMMENDATION: I propose that we f i x the 0.050 gallon per hour loss rate for tanks that are lO,O00 gallons in size and smaller; and then use this as a basis for the loss rate c r i te r ia on larger tanks. For example:

Loss rate per gallon for a 10,000 gallon tank = 0.050 = 0.000005 gallons per hour per gallon.

10,000 Apply the above equation to a 39,000 gal lon tank, and

we have an acceptable loss rate as follows: Acceptable loss rate for a 39,000 gallon tank = 0.000005 X 39,000 = 0.195 gallons per hour.

SUBSTANTIATION: Since we have seen the insta l la t ion of larger fuel storage tanks and an increased demand in the industrial sector for testing of large chemical and fuel oi l storage tanks, the loss rate c r i t e r i a of 0.050 gallons per hour is extremely small when we consider the co-eff ic ients of expansion with which we are sometimes dealing. For example, i f we consider a 50,000 gallon tank of ethyl acetate with a co-ef f ic ient of expansion of 0.00079 per degree, a thermal change in this tank of one one-thousandths of a degree represent an increase or decrease in product volume of 0.0395 gallons. Therefore, to cer t i fy a tank under these conditions as being t ight under the 329 c r i te r ia , an uncompensated temperature sh i f t of less than two one-thousandths of a degree wi l l cause us to fa i l the tank.

A histor lcal review of the technology we are presently using for testing underground storage tanks shows that the original design c r i t e r i a was for tanks that average 6,000 gallons in size. We know that we can test tanks larger than 6,000 gallons. However, as the tank gets larger, the margin of error based on thermal accuracy becomes smaller. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Sections 4-3.10.2 and 4-3.10.3 of fer lat i tude to the tester. The cr i ter ion has been widely accepted by most authori t ies, and was established for the technology employed.

(Log #27) 329- 18 - (4-3.10.1): Reject SUBMITTER: Rudy White, American Petroleum Inst i tute RECOMMENDATION: In paragraph I, a proposal is made to quali fy the precision test cr i ter ion of 0.05 gal/hr to the size of tank being tested. SUBSTANTIATION: A problem exists when one t r ies to apply the 0.05 gal/hr cr i ter ion to larger tanks. Current state-of- the-art precision testing equipment is not able to meet the NFPA cr i ter ion for these tanks. As a result, large tank owners and the precision testing industry are unable to determine and apply an appropriate technological standard for leak testing. COMMITTEE ACTION: ReJect. COMMITTEE COMMENT: See action on 329-17.

(Log #30) 329- 19 - (4-3.10.2): Accept SUBMITTER: Rudy White, American Petroleum Inst i tute RECOMMENDATION: A proposal is made to add the following sentence to the end of the paragraph:

"Precision tests should be performed by quali f ied technical personnel."

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SUBSTANTIATION: Competent technical personnel are often required to operate new and increasingly sophisticated precision testing devices now on the market. I t is in the best interest of the tank owner and the precision testing industry to assure that human error in conducting such tests is minimized. NFPA, in recommending a defined precision test, has a responsibi l i ty to inform the consumer-of the prerequisites of conducting such a test. COMMITTEE ACTION: Accept.

Also, add the words "experienced.in the use of the test method and in the interpretat ion of data produced". COMMITTEE COMMENT: The Committee agrees with the Submitter's substantiation, and feels that the addition of the Committee's wording wi l l serve even bette r to achieve the Submitter's purpose.

(Log #7) 329- 20 - (4-3.10.4 and 4-3.10.5 (New)): Reject SUBMITTER: Edward C. Nieshoff, Owens-Coming Fiberglas RECOMMENDATION: Change the exist ing 4-3.10.4 to 4-3.10.5 and insert the following .as a new 4-3.10.4:

"Double wall tanks, which are being required in some areas, introduce the need for alternate approaches to the precision test. The annular s~ace in these tanks can be tested by using a pressure type monitor. There are three types of continuous pressure monitors: vacuum, a i r pressure, and hydrostatic pressure. The pressure is applied to the cavity between the inner and outer walls of the double-wall tank." SUBSTANTIATION: (a) The existing code was written pr ior to the recent rapid development of the double-wall tank market.

(b) The requirement for double-wall tanks already exists in some areas and new environmental regulations are expected to broaden their use in the near future.

(c) This code change offers double wall tank manufacturers the opportunity to develop systems t h a t wi l l o f fer a continuous precision test to both inner and outer tank wall.

(d) I t also informs Code o f f i c i a l s of the alternate methods available to perform precision test on double wall tanks. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: In the Committee's opinion, the proposed change does not meet the c r i te r ia of Section 4-3.10.3 which specifies that i t deals with complete underground storage and handling equipment, rather than just the tank.

(Log #14) 329- 21 - (4-3.11.3): Accept in Part SUBMITTER: Joyce A. Rizzo, Hunter Environmental Services, Inc. RECOMMENDATION: Revise 4-3.11.3 as follows:

4-3.11.3 . . . In addition, the rate of temperature change wi l l vary depending on the temperature and volume of the product in the tank as well as the product added. Obviously, the test must be capable of detecting temperature changes to the accuracy necessary to assure compliance with the detectable l imi t of 0.05 gal (190 ml) in one hour stated in 4-3.10. SUBSTANTIATION: The ranges are unsubstantiated on recent data. The key to accurate temperature compensation should be quantitative, the term "very small" is nebulous. COMMITTEE ACTION: Accept in Part.

Delete the words "the detectable l imi t of 0.05 gallons (190 ml) in one hour stated in". COMMITTEE COMMENT: The Committee agrees with the Substantiation but sees no need to elaborate beyond the simple referr ing to the appropriate section, 4-3.10.

(Log #15) 329- 22 - (4-3.11.5): Accept in Part SUBMITTER: Joyce A. Rizzo, Hunter Environmental Services, Inc. RECOMMENDATION: Revise 4-3.11.5 as follows:

4-3.11.5 Temperature measurement must include a method for averaging any differences in temperature because the rate of change wil l not be the same. I f the product in the ground pr ior to f i l l i n g is at or close to ground temperature (62°F (16.7°C) in figure 3) i ts rate of change wil l be less signif icant than i f the product and ground temperatures were very d i f ferent . The temperature of the l iquid added to f i l l the f a c i l i t y wi l l immediately begin to change toward the temperature of the ground (56°F to 62°F (13.3°C to 16.7°C) in Figure 3). I f a 4,000 g a l (15 140L) tank was half fu l l pr ior to f i l l i n g for the test, with an observed average change of .06°F (0.17°C) per hour, this would mean a volume expansion of .06°F (0.17°C) X .007 X 4,000 gal (15 140L) = 1.68 gal (6.4L) per hour or 40 gal (150L) per day would be concealed by temperature rise. SUBSTANTIATION: I t is suggested that a specific rate not be used since an in f in i te number of circumstances exist in the combinations of in tank product, ground and product added temperatures. COMMITTEE ACTION: Accept in Part.

Delete 4-3.11.5 in i ts entirety. In 4-3.1i.2, start the section with the words "For example,". Also, delete Figure 3 ent i rely, and revise 4-3.11.4 as follows:

4-3.11.4 Another temperature effect that must be recognized and accounted for is temperature s t ra t i f i ca t ion or "layering." Layering occurs when product of a di f ferent temperature is added to product already in a tank ( i . e . , product is added to warmer product already in the tank); in addition, layering occurs as a result of ground temperature variations with depth. Temperature measurement must include a method for averaging any differences in temperature throughout the tank. COMMITTEE COMMENT: Section 4-3.11.5 was redundant to 4-3.11.2; without 4-3.11.5, Figure 3 is unnecessary. The revision to 4-3,11.4 elaborates on the explanation of s t ra t i f i ca t ion .

(Log #16) 329- 23 - (4-3.12 and 4-3.12.1): Accept SUBMITTER: Joyce A. Rizzo, Hunter Environmental Services, Inc. RECOMMENDATION: Revise as follows:

4-3.12 The Effect of Tank End Deflection. 4-3.12.1 Some techniques require f i l l i n g the tank to

a point abovegrade. This increase in height of l iquid increases the pressure inside the underground tank over the normal operating pressure. This is i l lust rated in Figure 4. SUBSTANTIATION: The language implies that the level must be brought above grade. See discussion of accuracy and test level.

NOTE: Supporting material available for review at NFPA Headquarters. COMMITTEE ACTION: Accept.

(Log #29) 329- 24 - (4-3.12.1): Accept in Principle SUBMITTER: Rudy White, American Petroleum Inst i tute RECOMMENDATION: A proposal is made to insert ' the word may in the following:

"Measuring very small volumetric changes in a storage f a c i l i t y (may) require the f i l l i n g of that f a c i l i t y to a point abovegrade where volumetric measuring equipment can be used . "

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SUBSTANTIATION: Not a l l precision tests for tanks require over f i l l ing . For those that do not, piping and associated product handling equipment can be precision tested separately using hydrostatic tests or other means. This fact may require changes in the def in i t ion of a precision test i .e. " I t should detect a leak anywhere in the complete underground storage and handling equipment." (Sec. 4-3.10.3) COMMITTEE ACTION: Accept in Principle. COMMITTEE COMMENT: See the action on 329-23.

(Log #17) 329- 2_5 - (4-3.12.5): Accept SUBMITTER: 3oyce A. Rizzo, Hunter Environmental Services, Inc. RECOMMENDATION: Add af ter Figure 6:

"The prec is ion tes t method employed should be able to c l e a r l y ind ica te the e f fec ts of tank end de f l ec t i on and e i t he r provide a means of compensation or e l im ina t i on of the e f f e c t s . " SUBSTANTIATION: Considerat ion should be given to eliminating the data in Table 6 since i t does not include the time factor for the deflection. Since the absolute volume must be related to the test time or period of leak rate determination in order to be useful. The suggested language offers more advice as to what to look for. Also, see attachment.

NOTE: Supporting material available for review at NFPA Headquarters. COMMITTEE ACTION: Accept.

Insert the word "possible" between "the" and "effects" in l ine 2.

(Log #18) 329- 26 - (4-3.12.6 and 4-3.18 (New)~: Accept in Part SUBMITTER: 3oyce A. Rizzo, Hunter Environmental Services, Inc. RECOMMENDATION: Renumber 4-3.12.6 to 4-3.18 and revise as follows:

4-3.18 In summary, major factors must be accounted for in the Precision Test to determine the presence or absence of a leak in an underground l iquid storage f ac i l i t y .

I. Leak detection accuracy. 2. The temperature change of the l iquid in that

period of time. 3. The complete tank and piping system is to be

included in the test. 4. The movement of tank ends as pressure is

increased. S. Water Table.

6. Vapor Pockets. 7. Evaporation.

SUBSTANTIATION: Addition of variables and reformat. COMMITTEE ACTION: Accept in Part.

Establish a new 4-3.18 or as ed i to r ia l l y appropriate and delete 4-3.12.6.

4-3.18 In summary, major factors must be accounted for in the Precision Test to determine the presence or absence of a leak in an underground l iquid storage f a c i l i t y .

1. The temperature change of the l i q u i d in tha t per iod of time.

2. The movement of tank ends as pressure is increased.

3. Water table. 4. Entrapped vapor. 5. Evaporation.

COMMITTEE COMMENT: The Committee does not agree that the numbers I and 3 are factors that should be included in the summary, but does accept the fact that 4-3.12.6 should be renumbered as 4-3.18 and that i t should be expanded•

(Log #20) 329- 2 7 - (4-3.13): Accept in Principle SUBMITTER: 3oyce A. Rizzo, Hunter Environmental Services, Inc. RECOMMENDATION: Revise to read as follows:

4-3.13 The Effects of Water Table. As stated in Section 4-3.9, there are many instances

where water may enter a tank system. Methods to handle a high water table in the area around a tank system are:

I. Determine water table level, 2. Be able to detect in leaks as well as out leaks. 3. Measure water levels in tanks. 4. Compensate for water pressure by increasing

pressure of product level to assure out-leak. SUBSTANTIATION: Effects of water table on tank testing are well known and should be addressed in NFPA 329. COMMITTEE AqT~QN: Accept in Principle.

Establish a new 4-3.13 to read: 4-3.13 The Effects of Water Table. As stated in

subsection 4-3.9, there are many instances where water may enter a tank system. The Precision Test method employed should be able to indicate clearly the possible effects of water in the backf i l l area around the tank system and either provide a means of compensation or elimination of the effects. COMMITTEE COMMENT: The Committee agrees that effects of water table should be addressed, and feels that i t s proposed wording is more suitable for NFPA 329.

(Log #6) 329- 28 - (4-3.13 and 4-3.13.1): Accept in Principle SUBMITTER: George Lomax, Heath Consultants RECOMMENDATRQN: Establish a new 4-3.13 and renumber present 4-3.13 accordingly.

4-3.13 The Effect of Subsurface Water Table. 4-3.13.1 The level of the water table adjacent to

the tank being tested must be determined. Calculate the pressure against the bottom of the tank caused by the height of the water table. Compensate via elevation of the product level for this water table to ef fect ive ly establish a dry soil condition. SUBSTANTIATION: We refer to this at Heath Consultants as the "Four Pound Rule," or the "Four Pound Pressure Advantage," When we consider the hydrostatic pressures affect ing a buried storage tank, we find pressure being applied from two sources: The f i r s t being the weight of the product in the tank; and the second being the weight of subsurface water outside of the tank.

I t is often assumed that water around the tank bottom and sides wi l l cause water to appear inside the tank as an indication of a leak. Should the leak be minor, a small corrosion hole or a series of small corrosion holes, i t is very possible water wi l l not enter the tank but gasoline wi l l leak out. This fact has to do with the surface tension of gasoline versus water. Gasoline wi l l leak through a smaller corrosion hole where water wi l l not.

With this in mind, we recommend the test operator determine the level of the water table adjacent to the tank being tested, calculate the pressure against the bottom of the tank caused by the height of the water table; and compensate via elevation of the product level for this water table. The goal is to establish a dry soil condition. COMMITTEE ACTION: Accept in Principle. COMMITTEE COMMENT: See action on propdsal 329-27.

• (Log #19) 329- 29 - (4-3.13 and 4-3.17 (New)): Accept SUBMITTER: Joyce A. Rizzo, Hunter Environmental Services, Inc. RECOMMENDATION: Renumber to 4-3.13 to 4-3.17.. SUBSTANTIATION: Reformat due to addition of new sections. COMMITTEE ACTION: Accept. COMMITTEE COMMENT: This is an edi tor ia l reorganization. Renumber as appropriate as the last section in Chapter 4.

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(Log #5) 329- 30 - (4-3.14 (New)): Accept in Part SUBMITTER: George Lomax, Heath Consultants R~qQMM~NDATION: Establish a new ~-3.14 and renumber present 4-3.13 as needed.

4-3.14 I f i t should be determined during the preparation of the tank for test that a vapor pocket is present, the entrapped vapor pocket must be vented or relieved. SUBSTANTIATION: Often I receive a tank test chart that hasn't fai led the tank, but indicates a bad test as the f inal result of the test shows a net gain in product in excess of the 0.050 per gallon per hour leak rate. This is often the result of entrapped vapors. The co-ef f ic ient of expansion of a given product by degree of temperature is a sc ient i f ic fact that is easily predictable. The co-ef f ic ient of expansion of an unknown vapor by degree of temperature cannot be determined. There is often a mixture of a i r and gasoline vapor entrapped in the tank and sometimes, the entrapped vapor is a product of the vaporization of the "Lighter Ends" of the material being tested.

I t is our experience, that a tank test is often invalidated by the rapid expansion or contraction of the vapor pocket. I know of no tank testing system that meets the precision test c r i te r ia as required by NFPA 329 that compensates for an entrapped vapor pocket in the test results. I t is impossible to perform a vali d test of an underground storage tank with an entrapped vapor pocket. COMMITTEE ACTION: Accept in Part.

Establish a new section 4-3.14 as follows: 4-3.14 Effects of Entrapped Vapor. High vapor

pressure'materials combined with a i r in the form of a vapor-air pocket wi l l be affected by both temperature and pressure changesi volume expansion or contraction w i l l occur. Precis ion Test methods employed should be able to ind ica te c l ea r l y the possible e f f ec t s o f entrapped vapor in the tank system and e l im ina te the e f f e c t s . COMMITTEE COMMENT: The Committee agrees to the need f o r a sect ion on entrapped vapor, and fee ls tha t i t s inc lus lon w i l l meet tha t need 'appropr la te ly , and in language that is cons is tent wi th s im i l a r sect ions.

(Log #23) 329- 31 - (4-3.16 (New) through 4-:3.16.4 (New)): Accept in Part SUBMITTER: 3oyce A. Rizzo, Hunter Environmental Services, Inc. RECOMMENDATION: Add a new 4-3.16 through 4-3.16.4 as follows:

4-3.16 Vapor Pockets. 4-3.16.1 High vapor pressure materials combined with

a i r in the form of a vapor/air pocket wi l l be affected by both temperature and pressure-changes; volume expansion or contraction wi l l occur. Vapor pockets are commonly formed in the high end of a tipped tank, a manway, around a drop tube and in abandoned lines,

4-3.16.2 The volume is indirect ly affected by pressure changes. To signi f icant ly affect a volume change in the vapor pocket, an ambient barometric pressure change would have to exceed 0.07 in. Hg in one hour, or 0.01GPH equivalent leak rate. Hydrostatic head pressures or external sources of pressure to the test system can also signi f icant ly affect the test.

4-3.16.3 Volume is direct ly affected by temperature. Significant temperature changes ~ i l l affect the

expansion or contraction of a trapped vapor pocket. Ambient exposure can cause severe changes.

4-3.16.4 Methods to Handle Vapor Pockets include: I. Assessment of their existence is not d i f f i c u l t

becase the test results wi l l be errat ic. 2. Eliminate pocket. a. Vent to atmosphere. b. F i l l slowly to minimize turbulence which

generates pockets. c. Take time to wait for the pocket's own natural

elimination. d. Cool down when temperatures are high.

SUBSTANTIATION: Vapor pockets represent a signi f icant variable not presently addressed in the document.

NOTE: Supporting material available for review at NFPA Headquarters. COMMITTEE ACTION: Accept in Part. COMMITTEE COMMENT: See action on 329-30.

(Log #21) 329- 32 - (4-3.14 (New)): Reject SUBMITTER: Joyce A. Rizzo, Hunter Environmental Services, Inc. RECOMMENDATION: Add a new 4-3.14 as f o l l ows :

4-3.14 Test Level. The leve l a t which a t es t is conducted should be standardized in order to assure tha t the resu l ts obtained from var ious methods are co r re l a tab le . There are three things to consider in se t t i ng tes t l e ve l .

1~ As stated in Section 4-3.10.3 the complete underground storage and handl ing equipment must be included in the t es t .

2. As stated in Section 4-3.12, the raising of product level above tank top can cause tank end deflection.

3. As stated in Section 4-3.13, Figure 7, there are minimum levels which are necessary to overcome the effects of water table.

Based on al l of these factors, Figure 7 should be used as the guideline for setting test level since i t sets the maximum level necessary to address al l three factors and minimize the pressure on the tank system. SUBSTANTIATION:

Introduction. The 0.05 GPH detection cr i ter ion established by NFPA

329 does not set an allowable leak rate for an underground storage system, but instead, defines the required accuracy of the test method employed to determine the leak rate of the system. However, the accuracy statement has the ef fect of setting an allowable leak rate for a storage system because corrective action is recommended only when the measured leak rate is greater than 0.05 GPH.

The Effect of Test Level on the Accuracy of a Test Method.

A leak may be enhanced by increasing the pressure of f lu id in the tank in the v ic in i t y of the leak. This increased pressure may be achieved by increasing the level of the product in the system. For any given leak in a system, the leak rate of the system wi l l increase in direct proportion to the level of product in the system. In theory then, a leak of any size may be detected simply by raising the test level to a point where a small leak becomes a large leak.

However, there are several practical concerns which impose l imitations on this approach.

Theproblem of greatest concern, as currently addressed by NFPA 329, Section 4-1.4.4 is that "Excessive pressures or tests by nonrepresentative l iquids may indicate leaks where none existed or conceal leaks where one, in fact, ex ists:" This risk is especlally great in older systems where corrosion has occured.

There are mechanical l imitat ions on the level to which product may be raised.

Safety is reduced when large volumes of flammable or otherwise dangerous l iquid are maintained above grade during a test. In addition, sp i l l s can become more frequent.

The thermal volume change of the product above grade may be di f ferent than the thermal volume change of the product below grade creating an error in the temperature compensation of test results. The loss of accuracy caused by this error may negate any improvement in test sensi t iv i ty . According to the present language in NFPA 329,

Section 4-I.4, " l iquid handling equipment should be tested in a condition as close as possible to normal operating conditions." The tanks in a storage system do not normally operate under extreme over f i l l conditions.

Excessive, abnormal pressures may cause additional tank end deflection. This may introduce additional error in the leak rate measurement thus eliminating any benefits gained from increased test sensi t iv i ty .

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The NFPA precision test guidelines could be signi f icant ly improved by addressing the question of the selection of the level of test for various tank environment conditions. Because tank environmental conditions vary from tank to tank, and from day to day and because each method o f tank t e s t i s d i f f e r e n t , t e s t l eve l se l ec t i on is d i f f i c u l t to s p e c i f y . However, s p e c i f i c environmental cond i t i ons may be addressed and t h e i r e f f e c t s on leak de tec t i on recognized. In a d d i t i o n , the t r a d e o f f between the de tec t i on o f very small leaks by i nc reas ing the t e s t l eve l and the r i s k o f c rea t i ng new leaks by t h i s increased t e s t l eve l should be recognized and addressed.

The E f f e c t o f the Water Table Level on the Se lec t ion o f Test Level

When the water table is above the bottom of the tank, i t wi l l have a very def in i te ef fect on the type of leak found and on the magnitude of the leak. When the water table level is below that of the leak, product wi l l leak out of the system at a rate proportional to the size (area) of the leak, the level of the product in the system, and the permeability of the soil which surrounds the leak. When the water table is above the leak, the water exerts a pressure which affects both the rate of leakage, and the direction of the leak.

I f a tank with a leak immersed in water is considered analogous to a manometer having water in one leg, and f lu id of a given density in the other leg, the level at which the water and the f lu id balance one another (zero leak rate) may be calculated. In addition, the direction of the leak ( into the tank system or out of the system) may be determined. The analogy is valid regardless of the elevation of the leak in the system. This analogy does not take into account the effect of the permeability of the soil in the v ic in i ty of a leak.

Figure 7 shows the relat ion between the level of the water table above the tank bottom, the level of the product in the system above the tank bottom, and the density of the product expressed as degrees API. For a given product density and water table level, the product level may be determined which balances the inward pressure of the water. Tests conducted at this balance point wi l l not indicate a leak. Tests conducted below this point wi l l indicate a leak into the system; tests conducted above this point wi l l indicate a leak out of the system. As the distance between the test level and the balance point leve l increases, either above the balance point, or below the balance point, the sensi t iv i ty of the test increases.

Any test method which is capable of detecting both a leak into a system and out of a system is adequate to detect leaks in a storage system when the water table is above the bottom of the tank. However, tests performed at a level near the balance point may not measure a leak rate greater than 0.05 GPH. A test method which wi l l only detect leak rates out of a system must be performed at a product level above the balance point.

The test should be performed at a level a suf f ic ient distance from the balance point, to insure that a leak which is detectable i f the water table was not present is detectable when the water table is present. COMMITTEE ACTION: Reject. COMMITT[[ COMMENT: The wording suggested would have an impact on al l tank testing methods, and tank testing methods are not, and cannot be, standardized. I t would be too restr ic t ive to some techniques that are now accepted and in use.

SUBSTANTIATION: Evaporation is a signif icant variable that is not presently addressed in NFPA 329. COMMITTEE ACTION: Accept in Principle.

Establish a new 4-3.15 as follows: 4-3.15 Effects of Evaporation. Some l iquids,

especlally highly vo la t i le l iquids, have high rates of evaporative losses i f their surfaces are exposed. The Prec is ion Test method employed should be able to indicate clearly the possible effects of evaporative losses and compensate for them. COMMITTEE COMMENT: The Committee agrees to including a section on evaporation and feels that i ts wording wi l l be suitable to meet the needs of the user of NFPA 329 in language that is consistent with similar sections.

(Log #22) 329- 33 - (4-3.15 (New)): Accept in Principle SUBMITT~R: 3oyce A. Rizzo, Hunter Environmental Services, Inc. RECOMMENDATION: Add a new 4-3.15 as follows:

4-3.15 Evaporation. Some products, especially highly vo la t i le petroleum products, have high rates of evaporative losses i f their surface areas are exposed. Methods to handle evaporation are:

I. Minimize surface area exposure. 2. Protect l iquid surfaces from exposure. 3. Insulate exposed product.

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