FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE COMMITTEE - NFPA · FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE COMMITTEE MEMORANDUM TO: NFPA 30 Technical Committee on Operations FROM: R. P. Benedetti

FLCOPS.2013-06 Agenda.doc

FLAMMABLE AND COMBUSTIBLE LIQUIDS CODE COMMITTEE

MEMORANDUM

TO: NFPA 30 Technical Committee on Operations

FROM: R. P. Benedetti

DATE: June 6, 2013

SUBJECT: Agenda for NFPA 30 Second Draft Meeting June 19, 2013 — 1:00 PM to 5:00 PM

_________________________________________________________________________________ Ladies and Gentlemen: Attached is the Agenda for the NFPA 30, Flammable and Combustible Liquids Code, Second Draft meeting of the NFPA 30 Technical Committee on Operations, to be held 1:00 PM to 5:00 PM, Wednesday, June 19, 2013, at the Doubletree Hotel – San Antonio Downtown, San Antonio TX. This Agenda will also be posted to the NFPA 30 Document Information Page at http://www.nfpa.org/aboutthecodes/list_of_codes_and_standards.asp If you have additional items for the Agenda, please bring them with you to the meeting. rpb/ cc FLCC Meeting Folder FLCOPS/NM

FLCOPS.2013-06 Agenda.doc


AGENDA — NFPA 30 Second Draft Meeting

NFPA 30 Technical Committee on Operations

Doubletree Hotel – San Antonio Downtown San Antonio TX

Wednesday, June 19, 2013, 1:00 PM to 5:00 PM

1. Call to Order. 2. Introduction of Attendees. Update of Committee Roster. [Attachment № A1] 3. Approval of Minutes of Last Meeting. [August, 2012, NFPA Headquarters, Quincy MA]

[Attachment № A2] 4. Report of Committee Chair. 5. Report of Staff Liaison.

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

6. Member Reports on Current Issues . [As Necessary] 7. Review and Act on Public Comments to NFPA 30 First Draft Report. [Attachment № A4] [See also Attachment No. A5, Related to Public Comment № 3.] [See also Attachments №s A6 and A7, Related to Public Comment № 11.] [See also Attachment № A8, Related to Public Comment № 18.] [NOTE: Attachment № A7 distributed separately.] 8. Recent Correspondence. [NONE] 9. Old Business. [NONE] 10. New Business.

Action Plan for 2018 edition of NFPA 30 – Identify Work Areas. Better Definitions for “Liquids in Process” and “Staged Liquids” – Chapter 18. Revise Allowed Quantities of Liquids in Incidental Use – Chapter 18.

11. Schedule Next Meeting(s). 12. Adjournment.

Address List No PhoneOperations FLC-OPS

Flammable and Combustible Liquids

Robert P. Benedetti06/10/2013

FLC-OPS

Dwight H. Havens

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

U 7/24/1997FLC-OPS

Gregory P. Bareta

PrincipalWisconsin Department of Commerce141 NW Barstow StreetWaukesha, WI 53188-3789

E 3/4/2008

FLC-OPS

Claire V. De Taeye

PrincipalTravelers Insurance Company75 Town Centre DriveRochester, NY 14623

I 10/4/2001FLC-OPS

Jonathan M. Eisenberg

PrincipalThe RJA Group, Inc.Rolf Jensen & Associates, Inc.1661 Worcester Road, Suite 501Framingham, MA 01701-5405Alternate: John J. Foley

SE 7/26/2007

FLC-OPS

Harold E. Grossman II

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

U 9/30/2004FLC-OPS

Richard J. Hild

PrincipalDuPont Performance Coatings1003 Bogart CircleBel Air, MD 21014

M 10/1/1993

FLC-OPS

Jay J. Jablonski

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

I 4/1/1996FLC-OPS

David C. Kirby

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

SE 1/1/1991

FLC-OPS

Gregory D. Kirby

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

M 1/17/1997FLC-OPS

Richard S. Kraus

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

M 10/1/1995

FLC-OPS

John A. LeBlanc

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

I 10/10/1997FLC-OPS

Jonathan P. Levin

PrincipalLiberty Mutual Commercial Markets20 Riverside Road, MS: 03BNWeston, MA 02493-2231Property Casualty Insurers Association of AmericaAlternate: David R. Hague

I 3/1/2011

FLC-OPS

Gregory A. Milewski

PrincipalShell Oil9018 Brook ShadowKingwood, TX 77345

M 1/14/2005

1

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Text Box

ATTACHMENT No. A1




FLC-OPS

Anthony M. Ordile

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

SE 10/1/1993FLC-OPS

Alfredo M. Ramirez

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

RT 4/15/2004

FLC-OPS

Robert N. Renkes

PrincipalPetroleum Equipment Institute6514 East 69th StreetTulsa, OK 74133

M 1/1/1984FLC-OPS

John W. Richmond, Sr.

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

M 4/14/2005

FLC-OPS

Douglas A. Rivers

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

U 1/1/1991FLC-OPS

Ronald G. Schaffhauser

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

M 1/15/2004

FLC-OPS

George A. Seuss, Jr.

PrincipalThe Hanover Insurance GroupVerlan Fire Insurance Company8403 Colesville Road, Suite 300Silver Spring, MD 20910-3352

I 7/22/1999FLC-OPS

Clark D. Shepard

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

M 7/12/2001

FLC-OPS

Michael D. Snyder

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

U 7/28/2006FLC-OPS

Beth Tate

PrincipalOffice of the Fire MarshalCommunity Safety & Correctional Services5775 Yonge Street, 7th FloorToronto, ON M2M 4J1 Canada

E 7/29/2005

FLC-OPS

Scott M. Tyler

PrincipalAREVA NP, Inc.1230 East Diehl Road, Suite 200Naperville, IL 60563Edison Electric InstituteAlternate: Sean Wallace

U 4/16/1999FLC-OPS

David B. Wechsler

Principal27706 Dalton Bluff CourtKaty, TX 77494American Chemistry Council

U 3/2/2010

2




FLC-OPS

Peter J. Willse

PrincipalXL Global Asset Protection Services100 Constitution Plaza, 12th FloorHartford, CT 06103Alternate: Mark Driscoll

I 3/21/2006FLC-OPS

Jack Woycheese

PrincipalHughes Associates, Inc.2195 Overlook DriveWalnut Creek, CA 94597Alternate: Joseph L. Scheffey

SE 1/1/1991

FLC-OPS

Tim D. Blackford

AlternateChevron Energy Technology Company3901 Briarpark DriveHouston, TX 77042American Petroleum InstitutePrincipal: Richard S. Kraus

M 3/1/2011FLC-OPS

Mark Driscoll

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

I 10/23/2003

FLC-OPS

John J. Foley

AlternateThe RJA Group, Inc.3384 Peachtree Road NE, Suite 550Atlanta, GA 30326Principal: Jonathan M. Eisenberg

SE 1/1/1997FLC-OPS

David R. Hague

AlternateLiberty Mutual Insurance20 Riverside RoadWeston, MA 02493-2231Property Casualty Insurers Association of AmericaPrincipal: Jonathan P. Levin

I 3/4/2009

FLC-OPS

Stephen W. Haines

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

SE 8/2/2010FLC-OPS

Donald B. Hicks

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

U 4/14/2005

FLC-OPS

David W. Owen

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

M 7/12/2001FLC-OPS

Duane L. Rehmeyer

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

SE 8/2/2010

FLC-OPS

Roland A. Riegel

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

RT 4/15/2004FLC-OPS

Joseph L. Scheffey

AlternateHughes Associates, Inc.3610 Commerce Drive, Suite 817Baltimore, MD 21227-1652Principal: Jack Woycheese

SE 1/10/2002

3




FLC-OPS

Richard E. Stutzki

Alternate3M Company3M Center, Building 224-6W-28St. Paul, MN 55144-1000Principal: Douglas A. Rivers

U 10/29/2012FLC-OPS

David Upchurch

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

I 10/29/2012

FLC-OPS

Sean Wallace

AlternateDominion Resources Services Inc.Corporate Risk Engineering701 East Cary Street; OJRP 4th FloorRichmond, VA 23219Edison Electric InstitutePrincipal: Scott M. Tyler

U 8/9/2011FLC-OPS

Christopher J. Wieczorek

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

I 1/14/2005

FLC-OPS

William R. Hamilton

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

E 3/4/2009FLC-OPS

Matthew I. Chibbaro

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

E 4/15/2004

FLC-OPS

Robert P. Benedetti

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

4

FLCOPS.2012-08 Minutes.doc


Minutes of NFPA 30 First Draft Meetings

NFPA 30 Technical Committee on Operations National Fire Protection Association Offices

Quincy, MA Thursday, August 30, 2012

The meeting was preceded by an introduction to the new NFPA standards development system

by G. Colonna, Division Manager – Industrial and Chemical Engineering.

I. Participation

C. V. De Taeye, Travelers Insurance Company M. Driscoll, XL Global Asset Protection Services J. M. Eisenberg, The RJA Group, Inc. H. E. Grossman II, Alcoa, Inc. S. W. Haines, Haines Fire & Risk Consulting Corporation D. H. Havens, Bechtel Marine Propulsion Corp. / Knowles Atomic Power Laboratory, CHAIR D. B. Hicks, Dow Corning Corporation (Rep. NFPA Industrial Fire Protection Section) J. J. Jablonski, HSB PLC R. S. Kraus, PSC Petroleum Safety Consultants (Rep. American Petroleum Institute) D. C. Kirby, Baker Engineering & Risk Consultants, Inc. G. D. Kirby, CYTEC Industries, Inc. J. A. LeBlanc, FM Global J. P. Levin, Liberty Mutual Commercial Markets (Rep. Property Casualty Insurers Association of America) G. A. Milewski, Shell Oil A. M. Ordile, Haines Fire & Risk Consulting Corporation D. W. Owen, ExxonMobil Corporation D. L. Rehmeyer, Baker Engineering & Risk Consultants, Inc. R. N. Renkes, Petroleum Equipment Institute J. W. Richmond, Sr., Eastman Chemical Company R. A. Riegel, UL LLC D. A. Rivers, 3M Company J. L. Scheffey, Hughes Associates, Inc. G. A. Seuss, Jr., Hanover Insurance Group / Verlan Fire Insurance Company M. D. Snyder, Dow Corning Corporation (Rep. NFPA Industrial Fire Protection Section) S. M. Tyler, AREVA NP, Inc. (Rep. Edison Electric Institute) J. Woycheese, Hughes Associates, Inc. R. P. Benedetti, National Fire Protection Association, STAFF LIAISON GUESTS: S. Bershad, National Fire Protection Association G. Brenneke, Liberty Northwest, Inc. A. Burke, Restaurant Technologies, Inc. G. R. Colonna, National Fire Protection Association R. Gunaratnam, U. S. Chemical Safety and Hazard Investigation Board

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ATTACHMENT No. A2


W. R. Hamilton, U. S. Occupational Safety and Health Administration B. Schoenbauer, Restaurant Technologies, Inc. J. J. Wanko, U. S. Occupational Safety and Health Administration Members Not in Attendance

G. P. Bareta, Wisconsin Department of Commerce T. D. Blackford, Chevron Energy Technology Company M. I. Chibbaro, U. S. Occupational Safety and Health Administration

J. J. Foley, The RJA Group, Inc. D. R. Hague, Liberty Mutual Insurance (Rep. Property Casualty Insurers Association of America) R. J. Hild, DuPont Performance Coatings D. J. Kohn, Kohn engineering, Inc. A. M. Ramirez, UL LLC

R. G. Schaffhauser, PPG Industries, Inc. C. D. Shepard, ExxonMobil Corporation B. Tate, Office of the Fire Marshal – Ontario S. Wallace, Dominion Resources Services Inc. (Rep. Edison Electric Institute) D. B. Wechsler, American Chemistry Council C. J. Wieczorek, FM Global P. J. G. Willse, XL Global Asset Protection Services II. Minutes 1. The meeting was called to order at 8:50 AM on Thursday, August 30, 2012 by Technical Committee

Chair Dwight Havens. 2. Attendees introduced themselves. The Technical Committee roster was corrected as needed. 3. The Minutes of the previous meeting (September 2010, Rosemont IL) were unanimously approved

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

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

Membership Status. The Staff Liaison reported on recent changes to committee membership and on the balance of interests on the committees. He also briefed the Technical Committee on emphasis programs to recruit alternate members (for those Principal members who do not have one) and enforcing officials.

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

6. There were no reports on current topics. There were no issues that needed to be reported to the

Technical Correlating Committee. 7. The Technical Committee reviewed and took action on 6 Public Inputs to amend the 2012 edition of

NFPA 30. Two First Revisions to NFPA 30 were created. No correlation issues were evident. In addition, five Committee Inputs were drafted to solicit information from the public: - Subsection 17.3.7. Amendments to provisions for heated process vessels. - Section 17.4. Development of new siting criteria for process vessels. - Subsection 17.11.4. Amendment to require floor level suction for ventilation systems. - Section 17.11. Addition of provision for ventilation in process areas during shutdown periods.


- Section 19.7. Proposed new section to address cooking oil storage and supply systems for commercial kitchens. The Staff Liaison was directed to circulate the First Revisions for letter ballot.

8. There was no recent correspondence requiring the Technical Committee’s attention. 9. Under “Old Business”, the Technical Committee discussed whether minimum separation distances

should be established between containers temporarily stored in a process area (e.g., to be used in the process) and the process itself. The Technical Committee determined that there is no apparent need to do so.

10. There was no new business requiring the Technical Committee’s attention. 11. The NFPA 30 Second Draft meeting was tentatively scheduled for Thursday, May 23, 2013, in San

Antonio TX. 12. The meeting adjourned at 12:45 PM.

2014 ANNUAL REVISION CYCLE *Public Input Dates may vary according to documents and schedules for Revision Cycles may change. Please check the NFPA Website for the most up‐to‐date information on Public Input Closing Dates and schedules at

www.nfpa.org/document # (i.e. www.nfpa.org/101) and click on the Next Edition tab

Process Stage

Process Step

Dates for TC

Dates forTC with

CC Public Input Closing Date* 6/22/2012 6/22/2012

Final Date for TC First Draft Meeting 11/30/2012 8/31/2012

Public Input Posting of First Draft and TC Ballot 1/18/2013 10/12/2012

Stage Final date for Receipt of TC First Draft ballot 2/8/2013 11/2/2012

(First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 2/15/2013 11/9/2012

Posting of First Draft for CC Meeting 11/16/2012

Final date for CC First Draft Meeting 12/28/2012

Posting of First Draft and CC Ballot 1/18/2013

Final date for Receipt of CC First Draft ballot 2/8/2013

Final date for Receipt of CC First Draft ballot ‐ recirc 2/15/2013

Post Final First Draft for Public Comment 2/22/2013 2/22/2013

Public Comment closing date 5/3/2013 5/3/2013

Final Date to Publish Notice of Consent Documents (Documents that received no Comments)

5/10/2013 5/10/2013

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

5/24/2013 5/24/2013

Final date for TC Second Draft Meeting 10/18/2013 7/12/2013

Comment Posting of Second Draft and TC Ballot 11/29/2013 8/23/2013

Stage Final date for Receipt of TC Second Draft ballot 12/20/2013 9/13/2013

(Second Final date for receipt of TC Second Draft ballot ‐ recirc 12/27/2013 9/20/2013

Draft) Posting of Second Draft for CC Meeting 9/27/2013

Final date for CC Second Draft Meeting 11/8/2013

Posting of Second Draft for CC Ballot 11/29/2013

Final date for Receipt of CC Second Draft ballot 12/20/2013

Final date for Receipt of CC Second Draft ballot ‐ recirc 12/27/2013

Post Final Second Draft for NITMAM Review 1/3/2014 1/3/2014

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 2/7/2014 2/7/2014

Preparation Posting of Certified Amending Motions (CAMs) and Consent Documents

4/4/2014 4/4/2014

(& Issuance) Appeal Closing Date for Consent Documents 4/18/2014 4/18/2014

SC Issuance Date for Consent Documents 5/9/2014 5/9/2014

Tech Session Association Meeting for Documents with CAMs 6/9‐12/2014 6/9‐12/2014

Appeals and Appeal Closing Date for Documents with CAMs 6/24/2014 6/24/2014

Issuance Council Issuance Date for Documents with CAMs 8/14/2014 8/14/2014

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ATTACHMENT No. A3

Public Comment No. 3-NFPA 30-2013 [ Section No.

17.4 ]

17.4 Location of Process Plant Permanent and Portable Buildings, Process Vessels and Process Equipment.17.4.1

Liquid-processing vessels and equipment shall be located in accordance with the requirements of this section.

17.4.2Processing vessels and buildings containing such processing

vessels shall be located so that a fire involving the vessels does not constitute an exposure hazard to other occupancies. 17.4. 2.1 Permanent process plant buildings shall be located in accordance with the requirements of API RP 752, "Manangement of Hazards Associated with Location of Permanent Process Buildings."

17.4.2.1 Portable process plant buildings shall be loacted in accordancw with the requirements of API RP 753, "Management of Hazards Associated with Location of Process Plant Portable Builtings."

17.4. 3The minimum distance of a processing vessel to a

property line that is or can be built upon, including the opposite side of a public way; to the nearest side of a public way; or to the nearest important building on the same property shall be one of the following:

(1) In accordance with Table 17.4.3

(2) Determined by an engineering evaluation of the process, followed by application of sound fire protection and process engineering principles

Table 17.4.3 Location of Process Vessels with Respect to Property Lines, Public Ways, and the Nearest Important Building on the Same Property —Protection for Exposures Is Provided

Page 9 of 56National Fire Protection Association Report

6/10/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?comm...

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ATTACHMENT No. A4

Vessel Maximum Operating Liquid Capacity

(gal)275 or less276 to 750

751 to 12,00012,001 to 30,00030,001 to 50,00050,001 to 100,000

Over 100,000

For SI units, 1 gal = 3.8 L; 1 ft = 0.3 m; 1 psi = a gauge pressure of 6.9 kPa.

Note: Double all of above distances where protection for exposures is not provided. *Gaugepressure.

17.4.4Where process vessels are located in a

building and the exterior wall facing theexposure (line of adjoining property that is or can be built upon or nearest important building on the same property) is greater than 25 ft (7.6 m) from the exposure and is a blank wall having a fire resistance rating of not less than 2 hours, any greater distances required by Table 17.4.3shall be permitted to be waived. If the exterior wall is a blank wall having a fire resistance rating of not less than 4 hours, all distances required by Table 17.4.3 shall be permitted to be waived.

17.4.5All the distances given in Table

17.4.3 shall be doubled where protection for exposures is notprovided.

17.4.6 *



Liquid-processing equipment, such as pumps, heaters, filters, and exchangers, shall not be located closer than 25 ft (7.6 m) to property lines where the adjoining property is or can be built upon or to the nearest important building on the same property that is not an integral part of the process. This spacing requirement shall be permitted to be waived where exposures are protected in accordance with17.4.3 .

17.4.7Processing equipment

in which unstable liquids are handled shall be separated from unrelated plant facilities by either of the following:

(1) 25 ft (7.6 m) clear spacing

(2) A wall having a fire resistance rating of not less than 2 hours and explosionresistance consistent with the expected hazard

Statement of Problem and Substantiation for Public Comment



This will bring the requirements of API RP 752 and 753 in the NFPA 30 code to provide for appropriate protection of new permanent structures in new and existing facilities and for the protection of temporary structures in new and extisting facilities, such as tents, trailers, etc used in turnaround and construction activities. .Copies of API safety related RPs are available to the public at http://publications.api.org/Default.aspx?status=1

Submitter Information Verification

Submitter Full Name: Richard KrausOrganization: API/Petroleum Safety ConsultanSubmittal Date: Fri Mar 01 09:02:58 EST 2013

Copyright Assignment

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

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



Public Comment No. 11-NFPA 30-2013 [ Section No.

18.4.4 ]

18.4.4Transfer of liquids among vessels, containers, tanks, and piping systems by means of air or inert gas pressure shall be permitted only under all of the following conditions:

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

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

(3) Only inert gas shall be used to transfer Class I liquids when pressures above 6 psig are used . Only inert gas shall be used to transfer Class II and Class III liquids that are heated above their flash points when pressures above 6 psig areused .

Additional Proposed Changes

File Name Description ApprovedCIBA_1.pdf CIBA Rpt #1 GT_PED_2.pdf GT PED #2 13756_GoatThroat_Pump_3.pdf 13756 GoatThroat Pump Rpt #3




RE Public Input No. 21-NFPA 30-2012Section No. 18.4.4

The NFPA 30 Technical Committee on Operations did not accept the amendment proposed by Westcott Distribution Inc for the change to the standard, which was,

“18.4.4 (3) Only inert gas shall be used to transfer Class 1 liquids when pressures above 8 psig are used. Only inert gas shall be used to transfer Class II and III liquids that are heated above their flash points when pressures above 8 psig are used.”

The reason this public input was not accepted was, “because of the absence of data showing that there is no hazard in the use of hand-operated compressed air devices to transfer Class I liquids or Class II or III liquids heated up to or above their flash points.” The Technical Committee requested that a public comment be submitted, at the appropriate time, along with a risk-based or technical analysis showing that the hazard of using such a device is no greater than that posed by other liquid transfer systems, i.e., gravity dispensing or use of a hand pump.

Based on our consultants’ advice, we suggest the following revision to NFPA 18.4.4 (3) :

“18.4.4 (3) Only inert gas shall be used to transfer Class 1 liquids when pressures above 6 psig are used. Only inert gas shall be used to transfer Class II and III liquids that are heated above their flash points when pressures above 6 psig are used.”

In support of this revised proposal and to comply with the request by the Technical Committee for a risk based analysis showing that the hazard of using such a devise is no greater than that posed by other liquid transfer systems, Westcott engaged Consultants to review and conduct such assessments.

Attached are 3 documents in support of our revised proposal:

1) CIBA 105-08 GoatThroatReport.pdf2) GT PED Statement 130321nw.pdf3) 13756 GoatThroat Pump Risk Desktop Assessment _Final Report_042613.pdf

A synopsis of the findings of each consultant are below:

1) CIBA 105-08 GoatThroatReport.pdf: The SCP line of pumps meets the criteria which prevents the accumulation of static electricity.

2) GT PED Statement 130321nw.pdf

T.U.V. Sud America evaluated the SCP pump lines with regard to P.E.D. Pressure Equipment Directive 97/23/EC, requirements. Their conclusions, are:

(A) Regarding the SCP Line (Static Conductive Pump) and the standard line which both have automatic pressure relief at 8psig: “… the above mentioned GoatThroat Pumps (drawings #s s. Table II are subject to the Pressure Equipment Directive (97/23/EC) and do fall under Article 3(3) of the Pressure Equipment directive….”

And,

(B) Regarding the SCP – 6 Line (Static Conductive Pump) and the GT-6 which both have automatic pressure relief at 6psig: “…the above mentioned GoatThroat Pump (drawing #s s. Table 1) are not subject to the Pressure Equipment Directive (97/23/EC) since the design pressure is identified below the applicability limits for the Pressure Equipment Directive (97/23/ED) of 0.5 bar.”

3) 13756 GoatThroat Pump Risk Desktop Assessment _Final Report_042613.pdf



Westcott then engaged Chilworth Technology Inc. to conduct a risk based assessment of the GT SCP line of Pumps which have automatic pressure relief at 6psig.

Their conclusion regarding Flammable Atmosphere:

“The flash point of a liquid increases with increased pressure. … At a system pressure of 6.0 psig (1070 mm Hg) and 12 degrees C, … the concentration is too lean to ignite. … A flammable atmosphere will exist inside of vessels containing flammable liquids, in many cases. This atmosphere will not significantly change regardless of whether the vapor space is at ambient pressure or pressures above ambient. Furthermore, there is no oxygen enrichment at elevated pressures which could increase the sensitivity of the flammable atmosphere to ignition. For these reasons, there is no additional flammability risk posed by using low pressure (6 psig or less) air to dispense liquids as compared to a dispensing system that uses suction.”

Their conclusions regarding Explosion Severity are:

As regards rotary and piston pumps “…(the) gap around the bung … may allow a weak explosion occurring at a temperature near the flash point (LFL) to vent in the form of a flame jet exiting near the bung at high velocity and high temperature. … This jet could injure personnel working in close proximity to the container.”

As regards GoatThroat Pumps “… A reduced risk would be expected where a pressure pump is being used and the vessel does not rupture as a result of an ignition inside. In this case, the energy from the ignition will be confined to the vessel and not escape to possibly injure personnel.”

Their conclusions regarding risk assessment are:“…use of the GoatThroat SCP line of pressure pumps to dispense flammable or combustible liquids, at pressure up to 6psig, is not considered to present any additional ignition, flammable atmosphere or leak/spill hazard when compared to suction pumps used for the same purpose.”

Thank you for your consideration..


Submitter Full Name: NANCY WESTCOTTOrganization: Westcott Distribution Inc., GOATTHROAT PUMPS DivisionSubmittal Date: Sat Apr 27 07:15:28 EDT 2013


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

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



Public Comment No. 18-NFPA 30-2013 [ New

Section after 19.6.5 ]

19.7 Cooking Oil Storage Tank Systems in Commercial Kitchens.19.7.1 Scope. 19.7.1.1 This section shall apply to cooking oil storage tank systems located in commercial kitchens where tank capacities are greater than 60 gallons. 19.7.1.2 This section applies to both fresh and waste cooking oil storage tanksystems. 19.7.1.3 Where there are conflicts in the requirements of other chapters of this code and this section, the requirements of this section shall take precedent.19.7.2 Design and Construction of Cooking Oil Storage Tanks.19.7.2.1 Materials of Construction. Tanks shall be of metallic or nonmetallicconstruction. 19.7.2.1.1 The materials of construction for tanks and their appurtenances shall be compatible with cooking oil. 19.7.2.1.2* For tanks storing waste cooking oil, the materials of construction for tanks and their appurtenances shall be compatible with cooking oil at minimum temperatures of 140° F (60° C) continuous and 235° F (113° C) intermittent.A.19.7.2.1.2 Waste oil is drained from a commercial fryer, via a transfer pump and lines, to a waste oil storage tank. The oil in the fryer may be hot, up to 375° F, still well below the oil flash point. Experience shows that the oil loses significant heat in the transfer process. The maximum temperature of waste cooking oil entering the storage tank are typically below 235° F (113° C). The materials of construction must be designed to be used with cooking oil in this temperature range.19.7.2.2 Design Standards. 19.7.2.2.1* Metallic cooking oil storage tanks shall be listed in accordance withANSI/UL 142, Standard for Steel Aboveground Tanks for Flammable andCombustible Liquids, or ANSI/UL 80, Standard for Steel Tanks for Oil-Burner Fuels and Other Combustible Liquids.A.19.7.2.2.1 Existing steel tanks listed for flammable and combustible liquids are considered acceptable for waste oil use. These tank standards contain design and construction requirements that would not meet food code requirements, making the tanks unacceptable for storage of liquid food products (fresh cooking oil).19.7.2.2.2 Nonmetallic cooking oil storage tanks shall be in accordance with all of the following:

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

(2) Tanks shall not exceed 200 gallons per tank.

19.7.2.3 Normal Venting. 19.7.2.3.1 Normal venting shall be located above the maximum normal liquid line.19.7.2.3.2 The size of the vent shall have a minimum effective area at least as large as the largest filling or withdrawal connection.



19.7.2.3.3 Normal vents, including vent piping, smaller than 1.25 in. (32 mm) nominal inside diameter shall be tested to verify internal tank pressures remain below a gauge pressure of 0.5 psi (3.5 kPa) under maximum flow rates for tank filling and withdrawal. These tests shall be permitted to be conducted by a qualified,impartial outside agency or by the manufacturer if certified by a qualified, impartial observer. 19.7.2.3.4* Normal vents shall be permitted to vent inside the building.A.19.7.2.3.4 Ignitable vapors are not created with high flash point cooking oil stored under the conditions required in Section 19.7.19.7.2.4 Emergency Venting. 19.7.2.4.1 Cooking oil storage tanks shall contain emergency relief venting in accordance with Chapter 22. 19.7.2.4.2* For non-metallic cooking oil storage tanks, emergency relief venting shall be permitted to be in the form of construction. This includes the low melting point of the tank material.A.19.7.2.4.2 Nonmetallic tanks will melt above the liquid line as an exposure fireprogresses, venting the vapor space of the tank.19.7.2.4.3 Emergency relief venting in the form of construction for metallic tanks shall be prohibited.19.7.2.4.4 Emergency vents shall be permitted to vent inside the building.19.7.2.5* Prevention of Overfilling of Cooking Oil Storage Tanks. Every cooking oil storage tank shall be provided with means to prevent an accidental overfill. Such means shall be automatic and fail-safe in nature.A19.7.2.5 Although generally not required for tank storage of Class IIIB liquids, overfill protection is provided for the cooking oil storage to prevent inadvertent spillage from a tank.19.7.2.6 Tank Heating. 19.7.2.6.1* Electrical equipment used for heating cooking oil shall be listed to ANSI/UL 499, Standard for Electrical Heating Appliances, and shall comply withNFPA 70, National Electric Code. Use of electrical immersion heaters shall be prohibited in nonmetallic tanks.A.19.7.2.6.1 The prohibition of an electrical immersion heater in nonmetallic tanks eliminates a primary ignition scenario for the oil stored in a nonmetallic tank.19.7.2.6.2* Electrical equipment used for heating cooking oil shall comply with NFPA 70 and shall be equipped with automatic means that limit the temperature of the contents of the tank to less than 140° F (60° C).A.19.7.2.6.2 The temperature limitation of 140°F corresponds to ASTM C1055 (ISO 13732-1) restrictions for maximum allowable temperatures of nonmetallic industrialsurfaces for human contact.19.7.3 Tank Installation and Testing.19.7.3.1 Location of Cooking Oil Storage Tanks. Tanks shall be installed in locations appropriate for storage of foodstuffs or inventory, and shall not be installed in areas designated as cooking areas. 19.7.3.1.1* Tanks shall be spaced at least 3 ft. (0.9 m) away from any cooking appliance or surface heated to above 140° (60° C) continuous, and at least 6 ft. (1.8 m) away from any open flame.A.19.7.3.1.1 The kitchen cooking area has historically been an area where fires occur. It is appropriate to locate tanks away from this potential ignition source.19.7.3.1.2* Tanks shall not be installed under commercial kitchen ventilation hoods.A.19.7.3.1.2 This is an area of potential accidental ignition.



19.7.3.1.3 Tanks shall not be required to be separated from one another. 19.7.3.2 Foundations for and Anchoring of Cooking Oil Storage Tanks. 19.7.3.2.1 Tanks supports shall be secured to the tank and the floor to prevent the tank from tipping over. For flat-bottom tanks resting directly on the floor, the tank shall be secured to the floor to prevent the tank from tipping over.19.7.3.2.2 In areas subject to earthquakes, tank supports, foundation and anchoring shall meet the requirements of the applicable building code for the specific seismic zone. Engineering evaluation by a qualified, impartial outside agency shall be an acceptable method of meeting this requirement.19.7.3.2.3 Where a tank is located in areas subject to flooding, the method foranchoring the tank to the floor shall be able to prevent the tank, either full or empty, from floating during a rise in water level up to the established maximum flood stage. Engineering evaluation by a qualified, impartial outside agency shall be an acceptable method of meeting this requirement.19.7.3.3 Tank Openings Other than Vents. 19.7.3.3.1 Each connection to the tank below the normal liquid line through which liquid can normally flow shall be provided with an internal or external valve located as close as possible to the shell of the tank, in accordance with Chapter 22. 19.7.3.3.2* Each connection to the tank above the normal liquid line through which liquid can normally flow shall not be required to have a valve, provided there exists a liquid-tight closure at the opposite end of the line. The liquid-tight closure shall be in the form of a valve, a plug, or a coupling or fitting with positive shut-off.A19.7.3.3.2 An example of a fitting with a positive shut-off is a spring-loaded check valve or a hydraulic quick-coupler with a spring-loaded poppet.19.7.3.4 Field Testing.19.7.3.4.1* As an alternate method to testing requirements in Chapter 21, cooking oil storage tanks shall be tested for leaks at the time of installation by filling the tankwith cooking oil to a liquid level above the highest tank seam or connection within the normal liquid level. Before the tank is placed in service, all leaks shall be corrected in an approved manner or the tank shall be replaced.A.19.7.3.4.1 Cooking oil storage tanks are atmospheric tanks with open vents. The requirement in Chapter 21 to pressurize the tank for leak testing would be difficult to achieve in the field due to tank construction and configuration. It is also desirable toprevent the contamination of water in a cooking oil tank. A more appropriate test would be to fill the tank with cooking oil to cover all connections and seams below the normal liquid level line.19.7.3.4.2 An approved listing mark on a cooking oil storage tank shall be considered to be evidence of compliance with tank testing requirements.19.7.4 Fire Protection for Cooking Oil Storage Tanks.19.7.4.1 Identification for Emergency Responders. A sign or marking that meets the requirements of NFPA 704, Standard System for the Identification of the Hazards of Materials for Emergency Response, or another approved system, shall be applied to each cooking oil storage tank in accordance with Chapter 21. Additional signage shall be applied to each tank identifying the contents of the tank as cooking oil, either fresh or waste.19.7.4.2* In areas where tanks are located, no additional ventilation is required provided adequate general human occupancy ventilation is provided, and all cooking equipment is provided with exhaust systems in accordance with NFPA 96, Standard for Ventilation Control and Fire Protection of Commercial Cooking Operations.A.19.7.4.2 Supplemental ventilation, as is required for cooking operations, is not needed for cooking oil storage tanks.



19.7.4.3 If ventilation is not provided as described in Step 19.7.4.2, then the tank shall be vented to another room inside the building that meets these requirements, or the tank shall be vented to outside the building.19.7.5 Transfer Lines.19.7.5.1* Design and Construction of Fresh Cooking Oil Transfer Lines. Fresh cooking oil transfer lines shall be permitted to be constructed of metallic or nonmetallic materials which are compatible with cooking oil and food products. Inaddition, nonmetallic transfer lines shall also meet the following requirements:

(1) Transfer lines used for pressure applications shall be rated for 100 psi (689 kPa) working pressure at 70° F (21° C), or the maximum output pressure of the transfer pump, whichever is higher.

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

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

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

(5) Leakage shall be controlled through the use of check valves or anti-siphon valves at points where the lines connect to the fresh oil tank.

A.19.7.5.1 Transfer lines will contain oil during fill and removal operations. Waste oil lines are generally pumped until there is little residual oil remaining in the lines. Fresh cooking oil lines are likely to contain residual oil after fill and removal operations. Restricting the fresh oil line size to 1.25 inches maximum inside diameter limits the amount of oil in the line. Additionally, the requirement for check valves or anti-siphon valves on the lines at points where the lines connect to the tank eliminates the possibility of a compromised line siphoning the contents of the tank.19.7.5.2* Design and Construction of Waste Cooking Oil Transfer Lines. Waste cooking oil transfer lines shall be permitted to be constructed of metallic or nonmetallic materials which are compatible with cooking oil.19.7.5.2.1 Transfer lines shall be rated for use with cooking oil at elevated temperatures of 275° F (135° C) continuous and 350° F (177 ° C) intermittent.19.7.5.2.2 Nonmetallic transfer lines shall be rated for pressures up to 250 psi (1724 kPa) working pressure at 275° F (135° C). A.19.7.5.2 The temperature and pressure ratings for the waste oil lines are consistent with the maximum expected conditions. 19.7.5.3 Flow Control. Cooking oil transfer lines shall be equipped with means to prevent unintended transfer or dispensing of cooking oil. These means are allowed to be in the form of momentary control switches, valves, check valves, anti-siphon valves, plugs, couplings, fittings, or any combination thereof that are fail-safe in nature.19.7.5.4 Pressure Control. Pumping systems used to transfer cooking oil shall have means to prevent over-pressurization of transfer lines. These means shall be in the form of relief valves, bypass valves, pressure sensor devices, or the pressure limitation of the pump itself.19.7.5.5 Installation of Cooking Oil Transfer Lines in Plenum-rated Spaces. Cooking oil transfer lines installed in plenum-rated spaces shall be enclosed in noncombustible raceways or enclosures, or shall be covered with a material listed and labeled for installation within a plenum. 19.7.5.6 Testing of Cooking Oil Transfer Lines. Cooking oil transfer lines shall be tested after installation and prior to use. Testing shall be with cooking oil at the normal operating pressures. Any leaks discovered in transfer lines as a result of testing shall be repaired or the transfer lines replaced prior to placing the transfer lines into service.Section/paragraph – Chapter 19, Section 19.2



Add a new definition and associated annex material19.2.1* Cooking Oil. Where used in this chapter, cooking oil shall be defined as a Class IIIB combustible liquid. This definition shall apply to both fresh, or new, cooking oil and waste, or used, cooking oil.A.19.2.1 Cooking oil is a Class IIIB liquid with a high flash point typically above 500° F. Because of this high flash point, it represents a lower fire hazard than other Class IIIB liquids having a flash point lower than 500° F. Fresh, or new, cooking oil is supplied to the user for cooking operations. As the oil becomes degraded through repeated use, it must be replaced with fresh oil. This waste oil, or used oil, is recovered from the cooking appliance and temporarily stored for offsite removal. To maintain fluidity in the transfer process, the waste oil must be heater. This heating is on the order of 100° F, well below the flash point temperature.Section/paragraph – Chapter 2, Sections 2.2 and 2.3Add the following reference standard to Chapter 2, Section 2.2:NFPA 96, Standard for Ventilation Control and Fire Protection of Commercial Cooking Operations, 2011 edition.Add the following reference standard to Chapter 2, Section 2.3.9:ANSI/UL 499, Electric Heating Appliances, 2008.




Substantiation:The revised material has been developed based on the direction provided by NFPA 30 Technical Committee at the Public Input Meeting. Committee Input #20 30-2012 was created, originally based on Public Input #115, during this meeting.

Current NFPA 30 requirements present a practical challenge to new restaurant technologies, which entirely eliminate manual handling of cooking oil. These systems provide personnel safety and environmental improvements to existing manual or semi-manual oil handling operations.

1. Current fire codes have added requirements for the storage of cooking oil in commercial kitchens. These codes reference or adopt NFPA 30 requirements for specific attributes of Class IIIB storage and handling systems.a. The fire code requirements as written emphasize used, spent, and inedible cooking oil.b. For systems which include fresh cooking oil supply, tanks and components must be food grade. The steel oil burner and industrial aboveground storage tank standards currently referenced in the fire codes do not anticipate food grade processes.2. The current requirements in NFPA 30 do not explicitly recognize non-metallic systems currently approved for food grade processes. There are limitations in listing metallic tanks, using the standards specified, for food grade processes. These limitations include requirements for welds and fillets for metallic tanks which conflict with food grade requirements. The proposal addresses this limitation by adding requirements for non-metallic tanks, with a requirement for listing tanks used with cooking oil.3. Current design criteria in NFPA 30 are more relevant to industrial flammable and combustible liquid tank requirements. High flash point cooking oil in a restaurant back-of-house setting represents a different, and generally lower, hazard than commonly anticipated by NFPA 30. The revised Operations Section unifies all pertinent fire safety requirements into Section 19.7, providing ease of use for users and fire officials. This establishes the level of safety applicable to this hazard.4. Modifications to current requirements for venting and electrical design have been made to accurately reflect the level of protection for this hazard as established in NFPA 30. Recognizing the low fire hazard associated with high flash point Class IIIB liquids, NFPA 30 permits vents from tanks storing Class IIIB liquids to discharge within a building, and permits non-classified electrical equipment for Class IIIB storage installations inside buildings.5. Associated requirements for liquid transfer lines have been included.

A companion code change has been made to NFPA 1, which has passed the Public Input stage. The approval of this proposal would allow the new NFPA 1 language to correlate with NFPA 30, since NFPA 1 adopts NFPA 30 in its entirety.


Submitter Full Name: ANDREW BURKEOrganization: RESTAURANT TECHNOLOGIES INCSubmittal Date: Thu May 02 17:05:39 EDT 2013


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



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



Modify Code Section 17.4.3 as noted below (red):

17.4.3 * The minimum distance of a processing vessel to a property line that is or can be built upon, including the opposite side of a public way; to the nearest side of a public way; or to the nearest important building on the same property shall be one of the following:

(1) In accordance with Table 17.4.3

(2) Determined by an engineering evaluation of the process, followed by application of sound fire protection and process engineering principles

(3) Processing vessels used solely to process stable Class IIIB liquids below flash point may be located in accordance with Table 22.4.1.6.

A17.4.3. See also 17.15.3. Minimum distances provided in Table 17.4.3 are extracts from similar tables in Chapter 22, Tank Storage. Processing vessels are at greater risk of upset and/or experience a wider range of process parameters (i.e., flow, temperature, pressure, level, reactivity, vapor density and potential for vapors to reach ignition sources if released, etc.) when compared to storage tanks. Evaluations for minimum distance should take these factors into account and establish the “stability” of the material and the maximum pressure in the tank/vessel(s) considering credible process deviations with due consideration for the design and reliability of safeguards that prevent/control process upsets. Minimum distance(s) for property lines, important buildings, and public ways should consider the risk (i.e., likelihood and consequence) to persons, property, and adjacent processes/ storage from vapor cloud ignition, blast overpressure, and thermal flux (i.e., burn injury and adjacent structure fire).

Additional guidance can be found in the following standards/recommended practices:

(1) NFPA 497: Recommended Practice for the Classification of Flammable Liquids, Gases, or Vapors and of Hazardous (Classified) Locations for Electrical Installations in Chemical Process Areas

(2) NFPA 551: Guide for the Evaluation of Fire Risk Assessments (3) American Institute of Chemical Engineers (AIChE), Guidelines for Evaluating Process Plant Buildings for

External Explosions & Fires (4) AIChE, Guidelines for Facility Siting & Layout (5) AIChE, Guidelines for Vapor Cloud Explosion, Pressure Vessel Burst, BLEVE, and Flash Fire Hazards (6) Society of Fire Protection Engineers (SFPE), Handbook of Fire Protection Engineering (7) SFPE, Engineering Standard on Calculating Fire Exposures to Structures (8) SFPE, Engineering Guide: Predicting First & Second Degree Skin Burns (9) SFPE, Engineering Guide to Fire Exposures to Structural Elements (10) SFPE, Engineering Guide: Assessing Flame Radiation to External Targets from Pool Fires (11) American Petroleum Institute (API) Recommended Practice (RP) 500, Recommended Practice for

Classification of Locations for Electrical Installations at Petroleum Facilities Classified as Class I, Division 1 and Division 2

(12) ANSI/API RP505, Recommended Practice for Classification of Locations for Electrical Installations at Petroleum Facilities Classified as Class I, Zone 0, Zone 1 and Zone 2

(13) API RP752, Management of Hazards Associated with Location of Process Plant Buildings (14) API RP753, Management of Hazards Associated with Location of Process Plant Portable Buildings

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NFPA 30 Resolution of CSB Public Input

Processing Tank/Vessel Siting Criteria

CSB Public Input Resolution At First Draft Meeting, CSB made the following

recommendation: Revise NFPA 30, Chapter 17, to include a section requiring a

written engineering analysis to determine the safe separation distance for occupied buildings, control rooms, and operating areas. The analysis must be acceptable to the authority having jurisdiction.

Based on Veolia, May ‘09 incident Tetrohydrofuran release from solvent recovery process Delayed ignition and VCE 4 injuries - 2 critical; significant property damage Ignition believed to be from boiler front in adjacent control

building

CSB Public Input Resolution Unclear if CSB recommendation for “safe separation

distance” was related to reducing the likelihood of ignition, reducing the severity of a VCE, or both.

Task Force formed: Scott Tyler Jay Jablonski Jack Woycheese Bob Benedetti Mark Kaszniak (CSB liaison)

CSB Public Input Task Force Meetings Received subsequent CSB letter noting Veolia Control

Bldg at 25 feet. . . .NFPA 30 would allow at 10 feet Reviewed Veolia report Reviewed Chapter 6 & 17 requirements that invoke

Hazards Analysis Numerous citations, nevertheless code allows following Table

17.4.3 siting distances without requiring engineering analysis

Researched code history to determine basis for PROCESSING spacing requirements in 17.4.3 Extract from STORAGE requirements

Tank Siting - Storage vs Processing History TANK STORAGE siting tables go back over 50 years Six separate siting tables Base Reference table sets distance (by tank volume) Modifiers applied to base reference distance depending

on tank type, emergency relief pressure and “stability” Roof type Stable/Unstable, < 2.5psig emergency relief Stable/Unstable, > 2.5psig emergency relief

Separate chapters for Industrial Plants; Bulk Plants; Processing Plants; and Refineries/Chemical Plants/Distilleries

Tank Siting - Storage vs Processing History All the Plants Chapters except for Processing Plants

referred to Tank Storage chapter for siting Processing Plants chapter applied modifiers to the Base

Reference Table distances for siting Stable, <2.5 psig: multiplier = 1 Stable, >2.5 psig: multiplier = 1.5 Unstable, <2.5 psig: multiplier = 2.5 Unstable, >2.5 psig: multiplier = 4

All distance requirement above are doubled when no “protection of exposures” is provided

Tank Siting - Storage vs Processing History In 1987, the individual “Plant” Chapters were consolidated

into “Operations” without technical commentary The modifiers were applied to populate the “Process

Vessels” siting Table (now 17.4.3) and Chapters divorced Storage chapter always applied several NOT LESS THAN

minimums for STORAGE tanks that are not applied to PROCESSING Not applied in earlier editions nor in 1987 extract

Compared Chapter 17, Table 17.4.3 versus comparable Chapter 22 requirements [Tables 22.4.1.1(a) and (b); 22.4.1.3; and 22.4.1.5] for like conditions of pressure, stability, and with/without “protection for exposures”:

Comparison of Ch. 17 versus Ch. 22 Minimum Distance from Property Line

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Protected for Exposures NOT Protected for Exposures Stable Liquid

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Emergency Relief <2.5 psi >2.5 psi <2.5 psi >2.5 psi <2.5 psi >2.5 psi <2.5 psi >2.5 psi

275 or less 5 10 15 20 10 20 30 40 276 to 750 10 15 25 40 20 30 50 80

751 to 12,000 15 25 40 60 30 50 80 120 12,001 to 30,000 20 30 50 80 40 60 100 160 30,001 to 50,000 30 45 75 120 60 90 150 240 50,001 to 100,000 50 75 125 200 100 150 250 400

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Emergency Relief <2.5 psi 4.1.1(a)

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275 or less 5 25 50 100 10 50 100 150 276 to 750 10 25 50 100 20 50 100 150

751 to 12,000 15 25 50 100 30 50 100 150 12,001 to 30,000 20 30 50 100 40 60 100 160 30,001 to 50,000 30 45 75 120 60 90 150 240 50,001 to 100,000 50 75 125 200 100 150 250 400 100,001 to 0.5M 80 120 200 320 160 240 400 640

Comparison of Ch. 17 versus Ch. 22 Distance from Public Way/Important Bldg

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Emergency Relief <2.5 psi >2.5 psi <2.5 psi >2.5 psi <2.5 psi >2.5 psi <2.5 psi >2.5 psi

275 or less 5 10 15 20 10 20 30 40 276 to 750 5 10 15 20 10 20 30 40

751 to 12,000 5 10 15 20 10 20 30 40 12,001 to 30,000 5 10 15 20 10 20 30 40 30,001 to 50,000 10 15 25 40 20 30 50 80 50,001 to 100,000 15 25 40 60 30 50 80 120

Over 100,000 25 40 65 100 50 80 130 200

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Emergency Relief <2.5 psi 4.1.1(a)

>2.5 psi 4.1.3

<2.5 psi 4.1.5

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275 or less 5 25 50 100 5 25 100 150 276 to 750 5 25 50 100 5 25 100 150

751 to 12,000 5 25 50 100 5 25 100 150 12,001 to 30,000 5 25 50 100 5 25 100 150 30,001 to 50,000 10 25 50 100 10 25 100 150 50,001 to 100,000 15 25 50 100 15 25 100 150 100,001 to 0.5M 25 37.5 50 100 25 37.5 100 150

Task Force Discussion / Issues Illogical for storage to be more restrictive than process Processing – as described in earlier editions – included

oxidation, reduction, halogenation, hydrogenation, alkylation, polymerization, and other chemical process, but shall not apply to chemical plants, refineries, or distilleries

Processing has inherently higher risk of process upsets Typically more staff near process operations vs. storage

No allowances are made for Class IIIB liquids in Table 17.4.3. In Chapter 22, IIIB tanks have their own table with greatly reduced siting distances Inconsistent and fails to acknowledge reduced hazard

Task Force Recommendation Modify Table 17.4.3 to match comparable Ch. 22 tables Add reference to Class IIIB table to allow reduced siting Add annex language to provide supplemental guidance for

engineering analysis Better ties with existing Ch. 6 and 17 language that requires

analysis for other concerns

Eliminate rows for vessels <750 gallons Spacing at 5 – 10 feet is unrealistic; insufficient access for

maintenance and firefighting Vapor travel / fire size depend on spill diameter not volume

Why committee should adopt change Applies code consistency as related to hazard Historically Industrial Plants, Bulk Plants, and Refineries/Chemical

Plants/Distilleries all required tank siting per Tank Storage Basis for treating Processing Plants separately is not known Removes ambiguity for AHJ’s

Adding provisions for IIIB liquids in Ch. 17 is appropriate for reduced hazard

Chapters 17 and 22 would be aligned / consistent Satisfies intent of CSB Recommendation by

recommending analysis while allowing continued use of prescriptive requirements with more defendable margin

TÜV SÜD America Inc. Phone: (847) 397-9847 1821 Walden Office Square Fax: (847) 397-9849 Suite 400 E-mail: [email protected] Schaumburg, IL 60173 www.TUVamerica.com

Management Service • Product Service • Industry Service • Automotive

March 21, 2013 Nancy Westcott

Westcott Distribution, Inc. 60 Shell Avenue Milford, CT 06460

Pressure Equipment Directive 97/23/EC (PED)

Applicability and Classification / Categorization Evaluation for

GoatThroat Pumps Dear Nancy, The GoatThroat Pumps (drawing#s s. Table I and II) have been assessed for applicability of the PED and categorized. According to your letter dated February 20, 2013 the GoatThroat Pumps are being operated on tanks with flammable liquids, which are considered dangerous fluids per the definitions of PED Article 9. It is identified that those stay in the liquid stage for the given operating conditions, which were identified as up to 26ºC. Maximum system pressure is identified as 0.41bar (6 psig) (drawing#s s. Table I) and 0.55bar (8 psig) (drawing#s s. Table II) respectively. The GoatThroat Pumps will fit onto a DN50 (2”) opening. The GoatThroat Pumps are to be assessed as “Pressure Accessories”. Based on the information provided, and intended use, the above mentioned GoatThroat Pumps (drawing#s s. Table I) are not subject to the Pressure Equipment Directive (97/23/EC) since the design pressure is identified below the applicability limits for the Pressure Equipment Directive (97/23/EC) of 0.5bar. Based on the information provided, and intended use, the above mentioned GoatThroat Pumps (drawing#s s. Table II) are subject to the Pressure Equipment Directive (97/23/EC) and do fall under Article 3(3) of the Pressure Equipment Directive (97/23/EC). The GoatThroat Pumps (drawing#s s. Table II) must be designed and manufactured in accordance with the Sound Engineering Practice of a Member State of the European Community to ensure safe use. The GoatThroat Pumps (drawing#s s. Table II) must be accompanied by adequate instructions for use and must bear markings to permit identification of the manufacturer or of his authorized representative established within the European Community. The GoatThroat Pumps (drawing#s s.

Table II) must not bear the marking referred to in Article 15 of the Pressure Equipment Directive (97/23/EC).

bbenedetti

Text Box

ATTACHMENT No. A6

TÜV SÜD America Inc. Phone: (847) 397-9847 1821 Walden Office Square Fax: (847) 397-9849 Suite 400 E-mail: [email protected] Schaumburg, IL 60173 www.TUVamerica.com

Management Service • Product Service • Industry Service • Automotive

If you have any further questions, please do not hesitate to contact us. Best regards,

Dirk Schroeter Technical Certifier TÜV SÜD Industrie Service GmbH Product Manager Industry Service TÜV SÜD America, Inc.

Table I SCP-6-GT100 Rev. A SCP-6-GT200 Rev. A SCP-6-GT200S Rev. A SCP-6-GT300 Rev. A SCP-6-7600 Rev. A GT100-6 Rev. A GT200-6 Rev. A GT200S-6 Rev. A GT300-6 Rev. A GT7600-6 Rev. A Table II SCP-8-GT100 Rev. A SCP-8-GT200 Rev. A SCP-8-GT200S Rev. A SCP-8-GT300 Rev. A SCP-8-7600 Rev. A GT100 Rev. A GT200 Rev. A GT200S Rev. A GT300 Rev. A GT7600 Rev. A

Table 1

SCP-6-GT100 Rev. A SCP-6-GT200 Rev. A SCP-6-GT200S Rev. A SCP-6-GT300 Rev. A SCP-6-7600 Rev. A GT100-6 Rev. A GT200-6 Rev. A GT200S-6 Rev. A GT300-6 Rev. A GT7600-6 Rev. A

WORK TO SPECIFICATIONS ONLYFITS: 2-INCH OPENING MATERIALS OF CONSTRUCTIONDRN: N.Westcott DATE 3.6.13 PLASTIC: PolypropyleneCHK: DATE Static Conductive PolypropyleneAPP: R. Pocock DATE 3;6.13 METAL: 304 Stainless Steel

ITEM NUMBER REV. SHEET SIZEELASTOMER: Nitrile

OTHER: SHEET 1 OF 1 SHEETS SCALE:AUTOMATIC INTERNAL PRESSURE VENT: 6 PSIG

Manufacture to signed original only and to comply with any

relevant US Standards

SCP-6-GT100

A 8.5" X 11"SCP-6-GT100


ITEM NUMBER REV. SHEET SIZEELASTOMER: EPDM




SCP-6-GT200

A 8.5" X 11"SCP-6-GT200



SantopreneOTHER: SHEET 1 OF 1 SHEETS SCALE:AUTOMATIC INTERNAL PRESSURE VENT: 6 PSIG



SCP-6-GT200S

A 8.5" X 11"SCP-6-GT200S


ITEM NUMBER REV. SHEET SIZEELASTOMER: Viton




SCP-6-GT300

A 8.5" X 11"SCP-6-GT300


ITEM NUMBER REV. SHEET SIZEELASTOMER: FFMK

OTHER: PFTE SHEET 1 OF 1 SHEETS SCALE:AUTOMATIC INTERNAL PRESSURE VENT: 6 PSIG



SCP-6-7600

A 8.5" X 11"SCP-6-7600

WORK TO SPECIFICATIONS ONLYFITS: 2-INCH OPENING MATERIALS OF CONSTRUCTIONDRN: N.Westcott DATE 3.6.13 PLASTIC: PolypropyleneCHK: DATEAPP: R. Pocock DATE 3;6.13 METAL: 304 Stainless Steel





GT100

A 8.5" X 11"GT100






GT200-6

A 8.5" X 11"GT200-6






GT200S-6

A 8.5" X 11"GT200S-6






GT300-6

A 8.5" X 11"GT300-6



PFTEOTHER: SHEET 1 OF 1 SHEETS SCALE:AUTOMATIC INTERNAL PRESSURE VENT: 6 PSIG



GT7600-6

A 8.5" X 11"GT7600-6

Table 2

SCP-8-GT100 Rev. A SCP-8-GT200 Rev. A SCP-8-GT200S Rev. A SCP-8-GT300 Rev. A SCP-8-7600 Rev. A GT100-8 Rev. A GT200-8 Rev. A GT200S-8 Rev. A GT300-8 Rev. A GT7600-8 Rev. A






SCP-8-GT100

A 8.5" X 11"SCP-8-GT100






SCP-8-GT200

A 8.5" X 11"SCP-8-GT200






SCP-8-GT200S

A 8.5" X 11"SCP-8-GT200S






SCP-8-GT300

A 8.5" X 11"SCP-8-GT300






SCP-8-7600

A 8.5" X 11"SCP-8-7600






GT100

A 8.5" X 11"GT100






GT200

A 8.5" X 11"GT200






GT200S

A 8.5" X 11"GT200S

FITS: 2-INCH OPENING WORK TO SPECIFICATIONS ONLYMATERIALS OF CONSTRUCTION

DRN: N.Westcott DATE 3.6.13 PLASTIC: PolypropyleneCHK: DATEAPP: R. Pocock DATE 3;6.13 METAL: 304 Stainless Steel





GT300-8

A 8.5" X 11"GT300-8






GT-7600

A 8.5" X 11"GT-7600

Client: Goat Throat Pumps

60 Shell Avenue

Milford, CT 06460

Contact: Nancy Westcott

Job title: President

Report no: R/13756/0413/SJL

Report date: April 26, 2013

CTI Ref: GT/13756/SL

Prepared by Reviewed by

Steven J Luzik PE, CFEI Chantell Laing

Senior Process Safety Specialist Senior Process Safety Specialist

FOR AND ON BEHALF OF CHILWORTH TECHNOLOGY, INC.

Risk Assessment of a Goat Throat hand

SCP-6500 Pressure Pump for Dispensing Flammable and Combustible Liquids

The Global Experts in Explosion & Process Safety Chilworth Technology, Inc. Goat Throat Pumps CTI Ref: GT/13756/SJL Page 2 of 25

CONTENTS PAGE NO.

1 SUMMARY ........................................................................................................................ 3

2 STATEMENT OF PROBLEM ............................................................................................. 4

3 CODES AND STANDARDS .............................................................................................. 6

4 RISK ASSESSMENT ......................................................................................................... 7 4.1 Flammable Atmosphere ............................................................................................. 7 4.2 Control of Ignition Sources ...................................................................................... 13 4.3 Explosion Severity ................................................................................................... 14 4.4 Leakage and Spills .................................................................................................. 16 4.5 Conformance with NFPA 30 .................................................................................... 17 4.6 Non-Conformance with NFPA 30 ............................................................................. 18

5 CONCLUSION ................................................................................................................. 19

6 APPENDIX A - NFPA 30 REQUIREMENTS FOR DISPENSING, HANDLING, TRANSFER AND USE ............................................................................................................................... 21

7 APPENDIX B - CONTAINER TESTING REQUIREMENTS (DOT TITLE 49, PART 178.605 TESTING STANDARD FOR DRUMS) ...................................................................... 23

8 APPENDIX C – LEGAL DISCLAIMER AND LIABILITY .................................................... 25


1 SUMMARY

The services of a Chilworth Technology Inc. (CTI) Senior Process Safety Specialist were requested by the Goat Throat Pump Co. to perform a risk assessment on their Model SCP-6500 pressure pump proposed for use in dispensing of Class I and Class II liquids in the industrial plant setting. The assessment considered the relative risk of flammable atmospheres, ignition sources, potential explosion severity and leakage/spill scenarios for traditional suction dispensing devices compared to the Goat Throat hand pump. Based on the results of the risk assessment, use of the Goat SCP line of pressure pumps to dispense flammable or combustible liquids, at pressures up to 6 psig, is not considered to present any additional ignition, flammable atmosphere or leak/spill hazards when compared to suction pumps used for the same purpose. However, the severity of an ignition of a flammable atmosphere inside of a pressurized container may increase, slightly increasing the risk, when compared to an event occurring at atmospheric pressure. If the complete absence of ignition sources within the container can be assured, there will be no additional risk from the use of the Goat SCP line of pressure pumps. Since the pump uses pressure to dispense Category 1 (Class I) liquids and the OSHA safety standards currently prohibit this practice a variance may be required in order to satisfy OSHA. The OSHA website www.OSHA.gov can be visited to obtain information regarding the variance procedure.


2 STATEMENT OF PROBLEM

The client, Goat Throat Pumps, manufactures a line of industrial, hand-operated drum pumps that dispense liquids, from containers up to 55 gallons in size, by developing small pressures (less than 6 psig) on the vapor space over the fluid in the container. According to Goat Throat, these types of pumps have been used for years to dispense Class I and Class II flammable liquids, without incident. Recently some of Goat Throat s' customers have requested that they engineer a pump which meets strict safety requirements for dispensing of these classes of liquids. Currently NFPA 30, which is the governing standard for handling of flammable and combustible liquids, requires that: (Section 18.3.4) Transfer of liquids among vessels, containers, tanks, and piping systems by means of air or inert gas pressure shall be permitted only under all of the following conditions: (1) The vessels, containers, tanks, and piping systems shall be designed for such pressurized transfer and shall be capable of withstanding the anticipated operating pressure. (2) Safety and operating controls, including pressure-relief devices, shall be provided to prevent overpressure of any part of the system. (3) Only inert gas shall be used to transfer Class I liquids. Only inert gas shall be used to transfer Class II and Class III liquids that are heated above their flash points. In addition, NFPA 30 also requires (Section 18.4.2.2) that a "Means shall be provided to minimize generation of static electricity. Such means shall meet the requirements of 6.5.4" Section 6.5.4 requires that equipment be designed to prevent electrostatic ignition and that all conductive parts be bonded and grounded. Goat Throat has developed a pump (Model SCP-6500) which they believe can safely be used to dispense flammable and combustible liquids. They have also been in contact with the NFPA 30 technical committee regarding the pump's conformance to the standard requirements. According to Goat Throat 1, the NFPA committee is not aware of any hazard data, regulations, or other information regarding the use of low pressure air to move flammable liquids or combustible liquids heated above their flash points but the standard, as currently written, (Section 18.3.4 (3) requires use of inert gas to transfer Class I liquids or Class II and Class III liquids heated to temperatures above their flash point. It should be noted , for the record, that OSHA safety standards prohibit transfer of flammable liquids using compressed air as follows: 29 CFR Part 1910.1061910.106(e) Industrial plants (2) Incidental Storage or Use of Flammable and

combustible Liquids (iv) Handling Liquids at Point of Final use (d) Flammable liquids shall be drawn

from or transferred into vessels, containers, or portable tanks within a building only through a closed

piping system, from safety cans, by means of a device drawing through the top, or from a container or

1 Letter from Goat Throat (Nancy Westcott-President) to Brian Kingsley of CTI dated March 2013.


portable tanks by gravity through an approved self-closing valve. Transferring by means of air pressure

on the container or portable tanks shall be prohibited.

and

29 CFR 1910.106(g) Service Stations (3)Dispensing Systems (iv) Dispensing Units (c) Category 1 or 2

flammable liquids, or Category 3 flammable liquids with a flashpoint below 100 °F (37.8 °C), shall not

be dispensed by pressure from drums, barrels, and similar containers. Approved pumps taking suction

through the top of the container or approved self-closing faucets shall be used.

and

29 CFR 1910.106(h) Processing Plants (4) Liquid Handling (iii) Transfer (a) The transfer of large

quantities of flammable liquids shall be through piping by means of pumps or water displacement.

Except as required in process equipment, gravity flow shall not be used. The use of compressed air as

a transferring medium is prohibited.

The committee suggested that a risk-based or technical analysis be prepared with the intent of demonstrating that the risk of using a pressure based pump, for dispensing of Class I and Class II liquids, is no greater than that posed by other liquid transfer systems, i.e., gravity dispensing or standard rotary or piston pumps. The committee has posed2 the following questions: (1) Does the Goat Throat pump, when used to transfer Class I flammable liquids, present a risk that is comparable to that posed by piston or rotary pumps (which pull liquids from their containers by suction) or does it present a significantly greater risk for spill or ignition? (2) Does the operation of the Goat Throat hand-operated pump induce dangerous levels of static electric charge in the liquid as it is pumped, again to a risk level that is greater than would be posed by other pumps? (3) Will a static conductive version of the pump present a risk that is comparable to that posed by FM approved metal pumps by piston or rotary pumps (which pull liquids from their containers by suction) or does it present a significantly greater risk for spill or ignition? This report addresses the questions posed by the committee and includes a risk assessment regarding the operation of the pump for the dispensing of Class I and Class II liquids.

2 Ibid Ref 1.


3 CODES AND STANDARDS

This risk assessment follows the guidance of the National Fire Protection Association (NFPA) consensus codes and standards for the processing and handling of combustible particulate solids. Specific codes and standards considered are listed below:

29 CFR Part 1910.106 Flammable and Combustible liquids

NFPA 30 (2012) "Flammable and Combustible Liquid Code"

NFPA 51B (2009) "Fire Prevention During Welding, Cutting and other Hot Work"

NFPA 68 (2007) "Standard on Explosion Protection by Deflagration Venting"

NFPA 70 (2011) "The National Electrical Code"

NFPA 77 (2007) “Recommended Practice on Static Electricity”


4 RISK ASSESSMENT

Three elements are required for a fire (1) a fuel; (2) an oxidant, typically the oxygen in air; and (3) a sufficiently energetic ignition source. If any one of these three elements can be removed, fire cannot be initiated. The first two of these elements (fuel and oxidant) when in an appropriate ratio, are referred to as a flammable atmosphere.

For an explosion involving a flammable liquid to occur, two additional requirements are necessary: (4) mixing of the flammable liquid vapors in air above the lower explosive limit and (5) confinement. Mixing with air naturally occurs under steady state conditions and if the liquid is at a temperature above its flash point there will be sufficient vapor to burn if an ignition source is present. Under these conditions either a flash fire or explosion will result. If the event occurs in a confined space, such as inside of a vessel or a room that is not adequately vented, then pressure will develop that causes damage to the vessel or room. In this case the classical definition of explosion is met.

The risk of an event will be the product of the likelihood of the event multiplied by the severity of the event.

Risk = Likelihood*Severity

The likelihood component will be determined by examination of the potential for flammable atmosphere and a credible ignition source. The severity can be estimated by an understanding of the burning or explosibility characteristics of the fuel.

The purpose of the risk assessment is to analyze the liquid dispensing conditions with regard to suction pumps and the Goat Throat hand pressure pump and to identify and assess potential fire and explosion hazards, with regard to each, in order to make comparisons between the two systems. Currently piston and rotary hand pumps that employ suction to remove liquids from containers are accepted in the industry and judged to meet NFPA 30 requirements.

4.1 Flammable Atmosphere

The presence of a flammable atmosphere can be expected inside of a vessel containing a flammable liquid, at ambient temperatures, in many cases. Table 1 provides flammability data for selected flammable liquids to demonstrate this point. The Table lists both volume percentage and temperature flammability limits at ambient pressure (one atmosphere - 760 mm of mercury). The flash point is defined as the minimum temperature of a liquid at which sufficient vapor is given off to form an ignitible mixture with the air, near the surface of the liquid, or within the vessel used, as determined by an appropriate test procedure and apparatus as specified in Section 4.4 of the standard. It is important to note that an external ignition source must be present to ignite a mixture within the flammable limits. The temperatures listed in the Table for Lower Flammable Limit (LFL) are flash point temperatures.


Table 1 - Flammability/Ignitibility/Explosibility Properties of Selected Flammable Liquids *HE No.

Liquid LEL (vol%)

UEL (vol%)

LEL Temp (°C)

UEL Temp (°C)

LEL Temp (°F)

UEL Temp (°F)

**MIE (mJ)

***Kg bar·m/sec

***Pmax (bar)

101 Methanol 7.3 36 12 42 54 108 0.14 75 7.5 103 Isopropyl Alcohol 2.3 12.7 12 38 53 102 0.65 83 7.8 104 Acetone 2.6 12.8 -17.8 7 0 45 1.15 NA NA 106 Ethyl Acetate 2.5 9.0 5 18 41 64 0.46 NA NA 107 Toluene 1.27 7.0 4.4 37 40 99 0.24 94 7.8 117 Ethanol 3.3 19 121.8 42 55 108 NA 78 7.0 119 Xylene 1.0 7.0 29 62 84 144 0.2 NA NA 138 Hexane 1.2 7.4 -21.7 6 -7 43 0.24 NA NA 139 Heptane 1.05 6.7 3.9 26 39 79 0.24 NA NA * Source - HERC Data Guides, Hercules Inc. PO Box 210, Cumberland, MD 21502

** Source - NFPA 77 - Annex B Table B-1

*** Source - NFPA 68 - Annex E - Table E.1

NA - not available


The flash point of a liquid increases with increased pressure. This is because the vapor pressure of the liquid is strictly dependent upon temperature. At the flash point, the vapor concentration is high enough such that, when mixed with air, the lower flammable limit exists. The volume percentage of the vapor can be calculated if the vapor pressure of the liquid at the flash point temperature is known. For example, from Figure 1(the flammability diagram for methanol, a Class I liquid (flash point below 37.8° C - 100°F)), at the flash point the vapor pressure of methanol at the flash point (12°C) is 55 mm mercury (Hg). The volume percent of methanol vapor can be calculated by dividing the vapor pressure by atmospheric pressure of 760 mm Hg. This produces a lower flammable limit of 7.3% methanol in air. At a system pressure of 6.0 psig (1070 mm Hg) and 12°C, the vapor pressure of methanol will still be 55 mm Hg, but the concentration of the vapors in the system will now be 55/1070*100% or 5.14%. This concentration is too lean to ignite. and it would be necessary to heat the liquid up to a higher temperature, to produce a vapor pressure of 78 mm Hg (0.073*1074 mm Hg), to create a flammable mixture in the vessel. This temperature would be about 15°C according to Figure 1. Figure 23 shows the effect of increasing system pressure for selected paraffinic hydrocarbons. It is also well known4 that increasing pressure will increase the limits of flammability with the lower flammable limit decreasing slightly and the upper limit more significantly. Figure 3 shows this effect for mixtures of pentane, nitrogen, and air. The broadening of the flammable range due to small changes in system pressure (below 100 psig) is relatively insignificant, however.

3 Bulletin 626 Bureau of Mines, "Flammability Characteristics of Combustible Gases and Vapors,

Michael Zabetakis, Washington DC Dept of Interior, 1965 Page 28. 4 ibid footnote 1, page 41.


Figure 1 - Flammability Diagram - Methanol (Re: Hercules Data Sheet No. 101)


Figure 2 - 5Effect of Pressure on Lower Temperature Limits of Flammability of Pentane, Hexane, Heptane and Octane in Air.

5 Note these values may differ from temperature limit values reported in the literature since they were

calculated based on equations designed to predict the behavior.


Figure 3 - Effect of Pressure on Limits of Flammability of Propane-Nitrogen Air Mixtures The percentage of oxygen in a pressurized system will be dictated by the vapor temperature of the flammable or combustible liquid inside the vessel and the system pressure. Table 2 shows percentages of the three components at two system pressures. The percentage of oxygen can never exceed 21% regardless of the system pressure but will trend towards this value as the system pressure increases. A flammable atmosphere will exist inside of vessels containing flammable liquids, in many cases. This atmosphere will not significantly change regardless of whether the vapor space is at ambient pressure or pressures above ambient. Furthermore, there is no oxygen enrichment at elevated pressures which could increase the sensitivity of the flammable atmosphere to ignition. For these reasons, there is no additional flammability risk posed by using low pressure air (6 psig or less) to dispense liquids from the vessel compared to a dispensing system that uses suction.


Table 2 - Percentages of Methanol, Oxygen and Nitrogen in closed vessel at 12°C, 0 and 7.5 psig. System Pressure (psig) % methanol vapor in air % oxygen % Nitrogen

0 7.30 19.47 73.23

6.0 5.14 19.92 74.94

4.2 Control of Ignition Sources

The primary 6basis of safety inside of a vessel containing a flammable atmosphere is prevention of ignition sources. Flammable vapors typically have Minimum Ignition Energies of less than 1 mJ (See Table 1) and can easily be ignited by weak electrostatic discharges including brush discharges generated from nonconductive materials such as plastics. At elevated pressures the MIE will decrease even further. Since the energy required to ignite flammable vapors at ambient pressure is so low, any further reduction of these energies, at elevated pressures, would not further increase the risk. NFPA 30 requires (Section 18.4.2.2) a means to be provided that prevents static electricity during transfer/dispensing operations. Typical strategies include bonding and grounding of all conductive pump components and designing nonmetallic components of the system to prevent electrostatic ignition. The Goat Throat hand SCP-6500 pump is designed to prevent generation of electrostatic charges. The tap, body, siphon dip tube and pump components have been 7tested and resistivity between parts does not exceed 1 megohm. This requirement originates from NFPA 778 which states (Section 7.4.1.3), "To prevent the accumulation of static electricity in conductive equipment, the total resistance of the ground path to earth should be sufficient to dissipate charges that are otherwise likely to be present. A resistance of 1 megohm (106 ohms) or less generally is considered adequate." The Goat Throat hand pump is designed so that once connected there will be no movement of the siphon tube and thus no friction will be generated while operating. Other pumps such as rotary and piston pumps may generate small amounts of friction due to contact of moving components (vanes or pistons) with the pump housings but these movements are not considered to be able to produce significant friction that would be required to ignite a flammable vapor cloud. Both suction and pressure dispensing pumps that are designed for control of static electricity meet the intent of the standard. There is no additional static discharge risk associated with the use of the pressure pump in this case.

6 A Basis of Safety is a strategy that is employed to remove one or more of the legs of the fire triangle

or explosion pentagon. 7 Ciba Report 105-08, Resistance Measurements of Goat Throat Pumps, Ciba Expert Services, Ciba

Safety Testing Laboratory, 1379 Ciba Rd., McIntosh, AL 36553. 8 NFPA 77 (2007 Edition) "Recommended Practice on Static Electricity", The National Fire Protection

Association, 1 Batterymarch Park, Quincy, MA 02169-7471.


Control of ignition sources is further addressed in areas where flammable liquids are being dispensed by both OSHA and the NFPA 30 standard. Both require use of electrical equipment rated for use in Class I atmospheres (Hazardous (classified locations)) where liquids are being dispensed or where flammable vapors can be released. In addition, OSHA requires that ignition sources be controlled in areas where flammable liquids are handled or dispensed as follows: 1910.106 (e) Industrial plants (6) "Sources of ignition" (i) "General." Adequate precautions shall be

taken to prevent the ignition of flammable vapors. Sources of ignition include but are not limited to open

flames; lightning; smoking; cutting and welding; hot surfaces; frictional heat; static, electrical, and

mechanical sparks; spontaneous ignition, including heat-producing chemical reactions; and radiant

heat.

1910.106 (f) Bulk plants (6) Sources of ignition. Category 1 or 2 flammable liquids, or Category 3

flammable liquids with a flashpoint below 100 °F (37.8 °C), shall not be handled, drawn, or dispensed

where flammable vapors may reach a source of ignition. Smoking shall be prohibited except in

designated localities. "No Smoking" signs shall be conspicuously posted where hazard from flammable

liquid vapors is normally present.

1910.106 (g) Service Stations (8) "Sources of ignition." In addition to the previous restrictions of this

paragraph, the following shall apply: There shall be no smoking or open flames in the areas used for

fueling, servicing fuel systems for internal combustion engines, receiving or dispensing of flammable

liquids. Conspicuous and legible signs prohibiting smoking shall be posted within sight of the customer

being served. The motors of all equipment being fueled shall be shut off during the fueling operation.

Being compliant with the OSHA requirements will further reduce the likelihood of ignition inside of a vessel containing a flammable liquid when air is introduced into the vessel when dispensing using either a suction or pressure pump.

4.3 Explosion Severity

A property known as Kg or the deflagration index of a gas cloud is an excellent predictor of the violence or severity of an explosion for a particular gas or vapor. The index is a measure of the maximum rate of pressure rise (change in pressure over time) of a burning gas or vapor cloud in a confined atmosphere. The faster a flammable cloud burns the more propensity for damage. The property can be determined in a laboratory test vessel and is reported along with Pmax, the maximum pressure developed in the test vessel. These two properties are used to design explosion vents for vessels requiring protection. (See Table 1 for Kg data on selected flammable liquid vapors) The test is performed at ambient conditions of pressure and temperature in the laboratory. The Kg and Pmax values increase with increasing initial vessel pressure so at elevated pressures, such as would be produced inside a container where a pressure pump was being used, the rate of burning and maximum pressures that can be


achieved will increase. The ideal gas law can be used to calculate the corresponding increase in Kg and Pmax. For a drum containing methanol (Kg of 75 bar·m/sec and a Pmax of 8.4 bar (122 psig)), for example, using a pressure dispensing pump that pressurized the container to 6 psig (0.41 bar), the Kg and Pmax values would increase according to this equation (P1abs/P1max = P2abs/P2max). Thus:

(1barabs)/(8.4 + 1 bar) = (1 bar + 0.41 bar)/P2max

Solving for P2max

P2max = 1.41*9.4/1 = 13.25 barabs or 12.25 barg (177 psig)

Kg would increase correspondingly Kg2 = Kg1*P2max/P1max = 75*1.41 = 106 bar·m/sec. This translates to an increase in rate of burning of about 41% compared to an ignition at ambient pressure.

It is problematical to predict or estimate whether or not the ignition of a flammable vapor inside of a vessel will cause the vessel to deform or rupture. There are many factors that will dictate the energy and pressure that can be produced by the ignition. These factors include the percentage of the vapor within the flammable range, the amount of liquid present inside the vessel, vessel pressure, turbulence and the design pressure of the vessel. A worst case scenario must be assumed as part of the risk assessment. In this scenario the effect of increased Pmax on a pressurized container is not expected to significantly affect probability of the explosion damaging the container since the containers used for dispensing liquids are neither designed to be pressure vessels nor are they protected against damage from explosion through the use of a deflagration vent. They are tested at 15 or 30 psig (1 - 2 bar) and a vapor cloud explosion inside would be expected to develop pressures from 2 to 9 bar and in most cases rupture the container whether at ambient pressure or pressurized to a slight overpressure up to 1.41 bar (6 psig).

In the case of the container using a suction pump, there is a small gap around the bung where the dip tube enters that is used to allow air from the room to enter the container to replace the liquid that is being dispensed. This small opening may allow a weak explosion occurring at a temperature near the flash point (LFL) to vent in the form of a flame jet exiting near the bung at high velocity and high temperature. This jet could injure personnel working in close proximity to the container. A reduced risk would be expected where a pressure pump is being used and the vessel does not rupture as a result of an ignition inside. In this case, the energy from the ignition will be confined to the vessel and not escape to possibly injure personnel.

An explosion that occurs in a situation where the vapor is near the stoichiometric concentration will produce a fast burning, high pressure explosion that will likely deform or rupture the vessel since it will not be able to adequately vent the rapidly developing deflagration pressure. This would occur in either suction or pressure pumps. Deformation or rupture of the vessel will also be more likely if the vessel contains only a small amount of liquid. In this case a large volume of flammable vapor will exist generating a more energetic


explosion. In the event of vessel rupture injury to personnel working nearby would be expected.

The effect of increased Kg at the elevated pressure would increase the risk slightly since increased Kg is proportional to increasing severity. If the likelihood factor is very small overall risk does not change significantly.

4.4 Leakage and Spills

4.4.1 Rotary and Hand Suction Pumps

Piston and rotary hand pumps are open systems that inherently have openings from the inside of the container to atmosphere. They dispense liquids from the containers using negative pressure. These methods require a path for air to ingress into the containers to replace the liquid being removed. Typically there is the small gap between the container opening (bung) and the pump dip tube that allows for this ingress of air. This opening naturally allows for some vapor release into the atmosphere when the pumps are not being used and are not disconnected from the container. If the vapor specific gravity is greater than 1.0 the amount of vapor leaking out should be insignificant. In addition, the mechanism for removing liquids from containers used by these pumps allows for some spillage since there is no mechanism for sudden stoppage of flow once the pumps are primed. If a seal fails, it is also possible for liquid to be expelled from the containers.

4.4.2 Goat Throat Hand Pressure Pump

The Goat Throat hand pump is a sealed system designed with adapters to provide a tight fit between the liquid containing vessels. This design prevents liquid vapors from exiting the container when the pump is not being used. If a seal fails, it is possible for liquid to be expelled from the containers. The pump can be provided with seals manufactured with various elastomers that are compatible with the liquid being dispensed. The tap handle can be closed immediately in the event of an emergency, if attended, to prevent any further release of liquid from the container. Currently the pump incorporates a hold open latch for dispensing of liquids. This design allows for potential spillage of liquid if the operator leaves the location while dispensing activities are taking place. It is recommended that the tap be redesigned with a self-closing feature to prevent dispensing of liquids when personnel are not attending the pump. The pump operates on the principal of pressurization of the inside of the vessel to dispense the liquid. A pressurized vessel is likely to release liquid if it leaks or fails. Pressures are regulated through use of a spring loaded pressure relief valve designed to relieve at 6 psig. The pump is also equipped with a manual pressure relief "O" ring valve designed to relieve pressure after dispensing operations are completed. This valve could also be employed in the event of a container leak to remove system pressure.


The Department of Transportation (DOT) requires testing of drums designed to handle liquids. The standard (See Appendix B) requires the containers to be tested at least 15 psig for at least 5 minutes (composites for 30 minutes). Since the containers that will be used with the pump require this testing and the test pressure is at least 250 % of the applied pressure, the risk of container failure during dispensing is very small. NFPA 30 requires (Section 18.4.2) that provisions be made to promptly and safely mitigate and dispose of leakage and spills. Also (Section 18.4.3) requires the areas where Class I liquids are being used must be free of open flames and other ignition sources. Use of electrical equipment rated for Class I Division 1 areas is required where dispensing of flammable liquids takes place. The primary basis of safety for prevention of fires in these areas is control of ignition sources. This requirement affords additional protection against fire, in the event of a spill or leak. The risk of leakage or spill associated with use of the pump is considered to be no greater than the risk associated with the use of suction pumps.

4.5 Conformance with NFPA 30

The Goat Throat hand SCP line pressure pumps are compliant with the following requirements of NFPA 30 with regard to dispensing of Class I and Class II liquids:

18.4 Dispensing, Handling, Transfer, and Use. 18.4.1 Class I liquids shall be kept in closed tanks or containers when not actually in use. Class II and Class III liquids shall be kept in closed tanks or containers when not actually in use when ambient or process temperature is at or above their flash point. 18.4.2 Where liquids are used or handled, provisions shall be made to promptly and safely mitigate and dispose of leakage or spills. 18.4.3 Class I liquids shall not be used outside closed systems where there are open flames or other ignition sources within the classified areas set forth in Chapter 7. 18.4.4 Transfer of liquids among vessels, containers, tanks, and piping systems by means of air or inert gas pressure shall be permitted only under all of the following conditions: (2) Safety and operating controls, including pressure-relief devices, shall be provided to prevent overpressure of any part of the system. 18.5 Incidental Operations 18.5.2.2 Means shall be provided to minimize generation of static electricity. Such means shall meet the requirements of 6.5.4. 18.5.2.3 Where pumps are used for liquid transfer, means shall be provided to deactivate liquid transfer in the event of a liquid spill or fire.


4.6 Non-Conformance with NFPA 30

The Goat Throat hand SCP line pressure pumps would not comply with the following requirement of NFPA 30 with regard to dispensing of Class I and Class II liquids:

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

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


5 CONCLUSION

Table 3 compares operational features and fire and explosion hazard conditions for suction and the Goat Throat hand pressure pumps. Based on the results of the risk assessment, use of the Goat SCP line of hand pressure pumps to dispense flammable or combustible liquids, at pressures up to 6 psig, is not considered to present any additional ignition, flammable atmosphere or leak/spill hazards when compared to suction pumps used for the same purpose. However, the severity of an ignition of a flammable atmosphere inside of a pressurized container may increase, slightly increasing the risk, when compared to an event occurring at atmospheric pressure. If the complete absence of ignition sources within the container can be assured, there will be no additional risk from the use of the Goat SCP line of hand pressure pumps. Since the pump uses pressure to dispense Category 1 (Class I) liquids and the OSHA safety standards currently prohibit this practice a variance may be required in order to satisfy OSHA. The OSHA website www.OSHA.gov can be visited to obtain information regarding the variance procedure.


Table 3 - Comparison of Flammable Liquid Dispensing Pumps from a Risk Standpoint

Pump

Type

Method of

Delivery

Vapor

Leakage

Flammable

Atmosphere in

Container

Ignition Sources Spill or

Leakage

Risk

Damage from

Explosion

Piston Suction Some

expected

In most cases, but

depends upon limits

of flammability.

None expected for pump meeting

NFPA requirements for static

control and bonding and

grounding.

Small

risk

Ignition of vapors

likely to cause

container

damage/rupture.

Personnel injury

likely.

Plunger Suction Some

expected

In most cases, but

depends upon limits

of flammability.




grounding.

Small

risk

Ignition of vapors

likely to cause

container

damage/rupture.

Personnel injury

likely.

Pressure Pressure up

to 6 psig

None

expected

In most cases, but

depends upon limits

of flammability.




grounding.

Small

risk

Effects of ignition

inside container

could be more

severe, compared to

suction or piston

pump.


6 APPENDIX A - NFPA 30 REQUIREMENTS FOR DISPENSING, HANDLING, TRANSFER AND USE

18.4 Dispensing, Handling, Transfer, and Use. 18.4.1 Class I liquids shall be kept in closed tanks or containers when not actually in use. Class II and Class III liquids shall be kept in closed tanks or containers when not actually in use when the ambient or process temperature is at or above their flash points. 18.4.2 Where liquids are used or handled, provisions shall be made to promptly and safely mitigate and dispose of leakage or spills. 18.4.3 Class I liquids shall not be used outside closed systems where there are open flames or other ignition sources within the classified areas set forth in Chapter 7. 18.4.4 Transfer of liquids among vessels, containers, tanks, and piping systems by means of air or inert gas pressure shall be permitted only under all of the following conditions: (1) The vessels, containers, tanks, and piping systems shall be designed for such pressurized transfer and shall be capable of withstanding the anticipated operating pressure. (2) Safety and operating controls, including pressure-relief devices, shall be provided to prevent overpressure of any part of the system. (3) Only inert gas shall be used to transfer Class I liquids. Only inert gas shall be used to transfer Class II and Class III liquids that are heated above their flash points. 18.4.5 Positive displacement pumps shall be provided with pressure relief that discharges back to the tank, pump suction, or other suitable location or shall be provided with interlocks to prevent overpressure. 18.4.6 Piping, valves, and fittings shall meet the requirements of Chapter 27. 18.4.7 Listed flexible connectors shall be permitted to be used where vibration exists. Approved hose shall be permitted to be used at transfer stations. 18.4.8* The staging of liquids in containers, intermediate bulk containers, and portable tanks shall be limited to the following: (1) Containers, intermediate bulk containers, and portable tanks that are in use (2) Containers, intermediate bulk containers, and portable tanks that were filled during a single shift (3) Containers, intermediate bulk containers, and portable tanks needed to supply the process for one continuous 24-hour period (4) Containers, intermediate bulk containers, and portable tanks that are stored in accordance with Chapter 9 18.4.9 Class I, Class II, or Class IIIA liquids used in a process and staged in the process area shall not be filled in the process area. Exception No. 1: Intermediate bulk containers and portable tanks that meet the requirements of Chapter 9. Exception No. 2: Intermediate products that are manufactured in the process area. 18.5 Incidental Operations. 18.5.1* This section shall apply to areas where the use, handling, and storage of liquids is only a limited activity to the established occupancy classification.


18.5.2 Class I liquids or Class II and Class III liquids that are heated up to or above their flash points shall be drawn from or transferred into vessels, containers, or portable tanks as follows: (1) From original shipping containers with a capacity of 5.3 gal (20 L) or less (2) From safety cans (3) Through a closed piping system (4) From portable tanks or containers by means of a device that has antisiphoning protection and that draws through an opening in the top of the tank or container (5) By gravity through a listed self-closing valve or self-closing faucet 18.5.2.1 If hose is used in the transfer operation, it shall be equipped with a self-closing valve without a hold-open latch in addition to the outlet valve. Only listed or approved hose shall be used. 18.5.2.2 Means shall be provided to minimize generation of static electricity. Such means shall meet the requirements of 6.5.4. 18.5.2.3 Where pumps are used for liquid transfer, means shall be provided to deactivate liquid transfer in the event of a liquid spill or fire.


7 APPENDIX B - CONTAINER TESTING REQUIREMENTS (DOT TITLE 49, PART 178.605 TESTING STANDARD FOR DRUMS)

(d) Test method and pressure to be applied. Metal packagings and composite packagings other than plastic ( e.g. , glass, porcelain or stoneware), including their closures, must be subjected to the test pressure for 5 minutes. Plastic packagings and composite packagings (plastic material), including their closures, must be subjected to the test pressure for 30 minutes. This pressure is the one to be marked as required in §178.503(a)(5). The receptacles must be supported in a manner that does not invalidate the test. The test pressure must be applied continuously and evenly, and it must be kept constant throughout the test period. In addition, packagings intended to contain hazardous materials of Packing Group I must be tested to a minimum test pressure of 250 kPa (36 psig). The hydraulic pressure (gauge) applied, taken at the top of the receptacle, and determined by any one of the following methods must be: (1) Not less than the total gauge pressure measured in the packaging (i.e., the vapor pressure of the filling material and the partial pressure of the air or other inert gas minus 100 kPa (15 psi)) at 55 °C (131 °F), multiplied by a safety factor of 1.5. This total gauge pressure must be determined on the basis of a maximum degree of filling in accordance with §173.24a(d) of this subchapter and a filling temperature of 15 °C (59 °F); (2) Not less than 1.75 times the vapor pressure at 50 °C (122 °F) of the material to be transported minus 100 kPa (15 psi) but with a minimum test pressure of 100 kPa (15 psig); or (3) Not less than 1.5 times the vapor pressure at 55 °C (131 °F) of the material to be transported minus 100 kPa (15 psi), but with a minimum test pressure of 100 kPa (15 psig). Packagings intended to contain hazardous materials of Packing Group I must be tested to a minimum test pressure of 250 kPa (36 psig). (e) Criteria for passing the test. A package passes the hydrostatic test if, for each test sample, there is no leakage of liquid from the package. Container Testing Requirements (DOT Title 49, Part 178.605 Testing standard for Drums) (d) Test method and pressure to be applied. Metal packagings and composite packagings other than plastic ( e.g. , glass, porcelain or stoneware), including their closures, must be subjected to the test pressure for 5 minutes. Plastic packagings and composite packagings (plastic material), including their closures, must be subjected to the test pressure for 30 minutes. This pressure is the one to be marked as required in §178.503(a)(5). The receptacles must be supported in a manner that does not invalidate the test. The test pressure must be applied continuously and evenly, and it must be kept constant throughout the test period. In addition, packagings intended to contain hazardous materials of Packing Group I must be tested to a minimum test pressure of 250 kPa (36 psig). The hydraulic pressure (gauge) applied, taken at the top of the receptacle, and determined by any one of the following methods must be: (1) Not less than the total gauge pressure measured in the packaging (i.e., the vapor pressure of the filling material and the partial pressure of the air or other inert gas minus 100 kPa (15 psi)) at 55 °C (131 °F), multiplied by a safety factor of 1.5. This total gauge pressure must be


determined on the basis of a maximum degree of filling in accordance with §173.24a(d) of this subchapter and a filling temperature of 15 °C (59 °F); (2) Not less than 1.75 times the vapor pressure at 50 °C (122 °F) of the material to be transported minus 100 kPa (15 psi) but with a minimum test pressure of 100 kPa (15 psig); or (3) Not less than 1.5 times the vapor pressure at 55 °C (131 °F) of the material to be transported minus 100 kPa (15 psi), but with a minimum test pressure of 100 kPa (15 psig). Packagings intended to contain hazardous materials of Packing Group I must be tested to a minimum test pressure of 250 kPa (36 psig). (e) Criteria for passing the test. A package passes the hydrostatic test if, for each test sample, there is no leakage of liquid from the package. Container Testing Requirements (DOT Title 49, Part 178.605 Testing standard for Drums) (d) Test method and pressure to be applied. Metal packagings and composite packagings other than plastic ( e.g. , glass, porcelain or stoneware), including their closures, must be subjected to the test pressure for 5 minutes. Plastic packagings and composite packagings (plastic material), including their closures, must be subjected to the test pressure for 30 minutes. This pressure is the one to be marked as required in §178.503(a)(5). The receptacles must be supported in a manner that does not invalidate the test. The test pressure must be applied continuously and evenly, and it must be kept constant throughout the test period. In addition, packagings intended to contain hazardous materials of Packing Group I must be tested to a minimum test pressure of 250 kPa (36 psig). The hydraulic pressure (gauge) applied, taken at the top of the receptacle, and determined by any one of the following methods must be: (1) Not less than the total gauge pressure measured in the packaging (i.e., the vapor pressure of the filling material and the partial pressure of the air or other inert gas minus 100 kPa (15 psi)) at 55 °C (131 °F), multiplied by a safety factor of 1.5. This total gauge pressure must be determined on the basis of a maximum degree of filling in accordance with §173.24a(d) of this subchapter and a filling temperature of 15 °C (59 °F); (2) Not less than 1.75 times the vapor pressure at 50 °C (122 °F) of the material to be transported minus 100 kPa (15 psi) but with a minimum test pressure of 100 kPa (15 psig); or (3) Not less than 1.5 times the vapor pressure at 55 °C (131 °F) of the material to be transported minus 100 kPa (15 psi), but with a minimum test pressure of 100 kPa (15 psig). Packagings intended to contain hazardous materials of Packing Group I must be tested to a minimum test pressure of 250 kPa (36 psig). (e) Criteria for passing the test. A package passes the hydrostatic test if, for each test sample, there is no leakage of liquid from the package.


APPENDIX C – LEGAL DISCLAIMER AND LIABILITY

(a) Limitation of Liability. The consulting services conducted by Chilworth Technology Inc. (the “Company”) were performed using generally accepted guidelines, standards, and/or practices, which the Company considers reliable. Although the Company performed its consulting services pursuant to reliable and generally accepted practices in the industry, the Company does not guarantee or provide any representations or warranties with respect to Client’s use, interpretation or application of the findings, conclusions, and/or suggestions of the consulting services provided by the Company. Moreover, the findings, conclusions, and the suggestions resulting from the consulting service are based upon certain assumptions, information, documents, and procedures provided by the Customer. AS SUCH, IN NO EVENT AND UNDER NO CIRCUMSTANCE SHALL THE COMPANY BE LIABLE FOR SPECIAL, INDIRECT, PUNITIVE OR CONSEQUENTIAL DAMAGES OF ANY NATURE WHATSOEVER, INCLUDING WITHOUT LIMITATION, ANY LOST REVENUE OR PROFITS OF THE CUSTOMER OR ITS CUSTOMERS, AGENTS AND DISTRIBUTORS, RESULTING FROM, ARISING OUT OF OR IN CONNECTION WITH, THE SERVICES PROVIDED BY THE COMPANY. The Customer agrees that the Company shall have no liability for damages, which may result from Client’s use, interpretation or application of the consulting services provided by the Company.

(b) The Company’s pricing of the consulting services provided does not contemplate that the Company shall have any liability resulting from its performance of the consulting services, except as otherwise set forth in the Quotation from the Company. Accordingly, the Customer shall indemnify and hold harmless the Company, its shareholders, directors, officers, employees and agents (the “Indemnified Parties”) from and against any and all loss, cost, liability and expense, including reasonable attorney’s fees and costs, which any of the Indemnified Parties may incur, sustain or be subject to, as a result of any claim, demand, action, investigation or proceeding arising out of or relating to either: (a) the consulting services provided by the Company; or (b) any material, equipment, specifications or safety information (or lack thereof) supplied to the Company (or which should have been supplied to the Company) by Customer and/or any failure of such materials, equipment, specifications and safety information to comply with any federal, state or local law or safety standard.

(c) For additional terms and conditions, which apply with respect to the provision of this report, see the Quotation provided by the Company and executed by Customer. If any terms set forth in the Quotation conflict with the terms set forth herein, the terms set forth herein shall apply.

Public Input - NFPA 30 (5-2-13) A. Burke

Page 1 of 6

©2013 Restaurant Technologies, Inc. All rights reserved. Proprietary and Confidential.

Submitter: Andy Burke Restaurant Technologies, Inc. Title of NFPA Standard: NFPA 30, Flammable and Combustible Liquids Code Section/paragraph – Chapter 19, new Section 19.7 Title of New Content: Public Comment on Committee Input #20-NFPA 30-2012, Chapter 19, New Section 19.7 (Originally based on Public Input #115) Proposed Text or Public Input: Delete Committee Input #20-NFPA30-2012 language in its entirety and add new Section 19.7 and associated annex material, plus associated changes to 19.2.1 and Section 2.2 as follows: 19.7 Cooking Oil Storage Tank Systems in Commercial Kitchens. 19.7.1 Scope. 19.7.1.1 This section shall apply to cooking oil storage tank systems located in commercial kitchens where tank capacities are greater than 60 gallons. 19.7.1.2 This section applies to both fresh and waste cooking oil storage tank systems. 19.7.1.3 Where there are conflicts in the requirements of other chapters of this code and this section, the requirements of this section shall take precedent. 19.7.2 Design and Construction of Cooking Oil Storage Tanks. 19.7.2.1 Materials of Construction. Tanks shall be of metallic or nonmetallic construction. 19.7.2.1.1 The materials of construction for tanks and their appurtenances shall be compatible with cooking oil. 19.7.2.1.2* For tanks storing waste cooking oil, the materials of construction for tanks and their appurtenances shall be compatible with cooking oil at minimum temperatures of 140° F (60° C) continuous and 235° F (113° C) intermittent. A.19.7.2.1.2 Waste oil is drained from a commercial fryer, via a transfer pump and lines, to a waste oil storage tank. The oil in the fryer may be hot, up to 375° F, still well below the oil flash point. Experience shows that the oil loses significant heat in the transfer process. The maximum temperature of waste cooking oil entering the storage tank are typically below 235° F (113° C). The materials of construction must be designed to be used with cooking oil in this temperature range.

19.7.2.2 Design Standards.

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

A.19.7.2.2.1 Existing steel tanks listed for flammable and combustible liquids are considered acceptable for waste oil use. These tank standards contain design and construction requirements that would not meet food code requirements, making the tanks unacceptable for storage of liquid food products (fresh cooking oil).

19.7.2.2.2 Nonmetallic cooking oil storage tanks shall be in accordance with all of the following: (1) Tanks shall be listed in for use with cooking oil, unless otherwise approved. (2) Tanks shall not exceed 200 gallons per tank. 19.7.2.3 Normal Venting.

19.7.2.3.1 Normal venting shall be located above the maximum normal liquid line.

bbenedetti

Text Box

ATTACHMENT No. A8


Page 2 of 6


19.7.2.3.2 The size of the vent shall have a minimum effective area at least as large as the largest filling or withdrawal connection. 19.7.2.3.3 Normal vents, including vent piping, smaller than 1.25 in. (32 mm) nominal inside diameter shall be tested to verify internal tank pressures remain below a gauge pressure of 0.5 psi (3.5 kPa) under maximum flow rates for tank filling and withdrawal. These tests shall be permitted to be conducted by a qualified, impartial outside agency or by the manufacturer if certified by a qualified, impartial observer.

19.7.2.3.4* Normal vents shall be permitted to vent inside the building.

A.19.7.2.3.4 Ignitable vapors are not created with high flash point cooking oil stored under the conditions required in Section 19.7. 19.7.2.4 Emergency Venting. 19.7.2.4.1 Cooking oil storage tanks shall contain emergency relief venting in accordance with Chapter 22. 19.7.2.4.2* For non-metallic cooking oil storage tanks, emergency relief venting shall be permitted to be in the form of construction. This includes the low melting point of the tank material.

A.19.7.2.4.2 Nonmetallic tanks will melt above the liquid line as an exposure fire progresses, venting the vapor space of the tank. 19.7.2.4.3 Emergency relief venting in the form of construction for metallic tanks shall be prohibited.

19.7.2.4.4 Emergency vents shall be permitted to vent inside the building.

19.7.2.5* Prevention of Overfilling of Cooking Oil Storage Tanks. Every cooking oil storage tank shall be provided with means to prevent an accidental overfill. Such means shall be automatic and fail-safe in nature.

A19.7.2.5 Although generally not required for tank storage of Class IIIB liquids, overfill protection is provided for the cooking oil storage to prevent inadvertent spillage from a tank. 19.7.2.6 Tank Heating. 19.7.2.6.1* Electrical equipment used for heating cooking oil shall be listed to ANSI/UL 499, Standard for Electrical Heating Appliances, and shall comply with NFPA 70, National Electric Code. Use of electrical immersion heaters shall be prohibited in nonmetallic tanks.

A.19.7.2.6.1 The prohibition of an electrical immersion heater in nonmetallic tanks eliminates a primary ignition scenario for the oil stored in a nonmetallic tank.

19.7.2.6.2* Electrical equipment used for heating cooking oil shall comply with NFPA 70 and shall be equipped with automatic means that limit the temperature of the contents of the tank to less than 140° F (60° C).

A.19.7.2.6.2 The temperature limitation of 140°F corresponds to ASTM C1055 (ISO 13732-1) restrictions for maximum allowable temperatures of nonmetallic industrial surfaces for human contact.

19.7.3 Tank Installation and Testing. 19.7.3.1 Location of Cooking Oil Storage Tanks. Tanks shall be installed in locations appropriate for storage of foodstuffs or inventory, and shall not be installed in areas designated as cooking areas.

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

A.19.7.3.1.1 The kitchen cooking area has historically been an area where fires occur. It is appropriate to locate tanks away from this potential ignition source.


Page 3 of 6


19.7.3.1.2* Tanks shall not be installed under commercial kitchen ventilation hoods.

A.19.7.3.1.2 This is an area of potential accidental ignition.

19.7.3.1.3 Tanks shall not be required to be separated from one another. 19.7.3.2 Foundations for and Anchoring of Cooking Oil Storage Tanks.

19.7.3.2.1 Tanks supports shall be secured to the tank and the floor to prevent the tank from tipping over. For flat-bottom tanks resting directly on the floor, the tank shall be secured to the floor to prevent the tank from tipping over.

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

19.7.3.2.3 Where a tank is located in areas subject to flooding, the method for anchoring the tank to the floor shall be able to prevent the tank, either full or empty, from floating during a rise in water level up to the established maximum flood stage. Engineering evaluation by a qualified, impartial outside agency shall be an acceptable method of meeting this requirement.

19.7.3.3 Tank Openings Other than Vents.

19.7.3.3.1 Each connection to the tank below the normal liquid line through which liquid can normally flow shall be provided with an internal or external valve located as close as possible to the shell of the tank, in accordance with Chapter 22.

19.7.3.3.2* Each connection to the tank above the normal liquid line through which liquid can normally flow shall not be required to have a valve, provided there exists a liquid-tight closure at the opposite end of the line. The liquid-tight closure shall be in the form of a valve, a plug, or a coupling or fitting with positive shut-off.

A19.7.3.3.2 An example of a fitting with a positive shut-off is a spring-loaded check valve or a hydraulic quick-coupler with a spring-loaded poppet. 19.7.3.4 Field Testing.

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

A.19.7.3.4.1 Cooking oil storage tanks are atmospheric tanks with open vents. The requirement in Chapter 21 to pressurize the tank for leak testing would be difficult to achieve in the field due to tank construction and configuration. It is also desirable to prevent the contamination of water in a cooking oil tank. A more appropriate test would be to fill the tank with cooking oil to cover all connections and seams below the normal liquid level line.

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

19.7.4 Fire Protection for Cooking Oil Storage Tanks.

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


Page 4 of 6


19.7.4.2* In areas where tanks are located, no additional ventilation is required provided adequate general human occupancy ventilation is provided, and all cooking equipment is provided with exhaust systems in accordance with NFPA 96, Standard for Ventilation Control and Fire Protection of Commercial Cooking Operations.

A.19.7.4.2 Supplemental ventilation, as is required for cooking operations, is not needed for cooking oil storage tanks.

19.7.4.3 If ventilation is not provided as described in Step 19.7.4.2, then the tank shall be vented to another room inside the building that meets these requirements, or the tank shall be vented to outside the building. 19.7.5 Transfer Lines. 19.7.5.1* Design and Construction of Fresh Cooking Oil Transfer Lines. Fresh cooking oil transfer lines shall be permitted to be constructed of metallic or nonmetallic materials which are compatible with cooking oil and food products. In addition, nonmetallic transfer lines shall also meet the following requirements:

(1) Transfer lines used for pressure applications shall be rated for 100 psi (689 kPa) working pressure at 70° F

(21° C), or the maximum output pressure of the transfer pump, whichever is higher. (2) Transfer lines used for suction applications shall be rated for full vacuum at 70° F (21° C). (3) Transfer lines shall be rated for temperatures up to 120° F (49° C) continuous. (4) The maximum nominal inside diameter shall be no larger than 1.25 in. (32 mm). (5) Leakage shall be controlled through the use of check valves or anti-siphon valves at points where the lines

connect to the fresh oil tank. A.19.7.5.1 Transfer lines will contain oil during fill and removal operations. Waste oil lines are generally pumped until there is little residual oil remaining in the lines. Fresh cooking oil lines are likely to contain residual oil after fill and removal operations. Restricting the fresh oil line size to 1.25 inches maximum inside diameter limits the amount of oil in the line. Additionally, the requirement for check valves or anti-siphon valves on the lines at points where the lines connect to the tank eliminates the possibility of a compromised line siphoning the contents of the tank. 19.7.5.2* Design and Construction of Waste Cooking Oil Transfer Lines. Waste cooking oil transfer lines shall be permitted to be constructed of metallic or nonmetallic materials which are compatible with cooking oil.

19.7.5.2.1 Transfer lines shall be rated for use with cooking oil at elevated temperatures of 275° F (135° C) continuous and 350° F (177 ° C) intermittent.

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

A.19.7.5.2 The temperature and pressure ratings for the waste oil lines are consistent with the maximum expected conditions.

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

19.7.5.4 Pressure Control. Pumping systems used to transfer cooking oil shall have means to prevent over-pressurization of transfer lines. These means shall be in the form of relief valves, bypass valves, pressure sensor devices, or the pressure limitation of the pump itself.

19.7.5.5 Installation of Cooking Oil Transfer Lines in Plenum-rated Spaces. Cooking oil transfer lines installed in plenum-rated spaces shall be enclosed in noncombustible raceways or enclosures, or shall be covered with a material listed and labeled for installation within a plenum. 19.7.5.6 Testing of Cooking Oil Transfer Lines. Cooking oil transfer lines shall be tested after installation and prior to use. Testing shall be with cooking oil at the normal operating pressures. Any leaks discovered in transfer


Page 5 of 6


lines as a result of testing shall be repaired or the transfer lines replaced prior to placing the transfer lines into service.

Section/paragraph – Chapter 19, Section 19.2 Add a new definition and associated annex material 19.2.1* Cooking Oil. Where used in this chapter, cooking oil shall be defined as a Class IIIB combustible liquid. This definition shall apply to both fresh, or new, cooking oil and waste, or used, cooking oil. A.19.2.1 Cooking oil is a Class IIIB liquid with a high flash point typically above 500° F. Because of this high flash point, it represents a lower fire hazard than other Class IIIB liquids having a flash point lower than 500° F. Fresh, or new, cooking oil is supplied to the user for cooking operations. As the oil becomes degraded through repeated use, it must be replaced with fresh oil. This waste oil, or used oil, is recovered from the cooking appliance and temporarily stored for offsite removal. To maintain fluidity in the transfer process, the waste oil must be heater. This heating is on the order of 100° F, well below the flash point temperature. Section/paragraph – Chapter 2, Sections 2.2 and 2.3 Add the following reference standard to Chapter 2, Section 2.2: NFPA 96, Standard for Ventilation Control and Fire Protection of Commercial Cooking Operations, 2011 edition. Add the following reference standard to Chapter 2, Section 2.3.9: ANSI/UL 499, Electric Heating Appliances, 2008. Substantiation: The revised material has been developed based on the direction provided by NFPA 30 Technical Committee at the Public Input Meeting. Committee Input #20 30-2012 was created, originally based on Public Input #115, during this meeting. Current NFPA 30 requirements present a practical challenge to new restaurant technologies, which entirely eliminate manual handling of cooking oil. These systems provide personnel safety and environmental improvements to existing manual or semi-manual oil handling operations.

1. Current fire codes have added requirements for the storage of cooking oil in commercial kitchens. These codes reference or adopt NFPA 30 requirements for specific attributes of Class IIIB storage and handling systems. a. The fire code requirements as written emphasize used, spent, and inedible cooking oil. b. For systems which include fresh cooking oil supply, tanks and components must be food grade.

The steel oil burner and industrial aboveground storage tank standards currently referenced in the fire codes do not anticipate food grade processes.

2. The current requirements in NFPA 30 do not explicitly recognize non-metallic systems currently approved for food grade processes. There are limitations in listing metallic tanks, using the standards specified, for food grade processes. These limitations include requirements for welds and fillets for metallic tanks which conflict with food grade requirements. The proposal addresses this limitation by adding requirements for non-metallic tanks, with a requirement for listing tanks used with cooking oil.

3. Current design criteria in NFPA 30 are more relevant to industrial flammable and combustible liquid tank requirements. High flash point cooking oil in a restaurant back-of-house setting represents a


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different, and generally lower, hazard than commonly anticipated by NFPA 30. The revised Operations Section unifies all pertinent fire safety requirements into Section 19.7, providing ease of use for users and fire officials. This establishes the level of safety applicable to this hazard.

4. Modifications to current requirements for venting and electrical design have been made to accurately reflect the level of protection for this hazard as established in NFPA 30. Recognizing the low fire hazard associated with high flash point Class IIIB liquids, NFPA 30 permits vents from tanks storing Class IIIB liquids to discharge within a building, and permits non-classified electrical equipment for Class IIIB storage installations inside buildings.

5. Associated requirements for liquid transfer lines have been included. A companion code change has been made to NFPA 1, which has passed the Public Input stage. The approval of this proposal would allow the new NFPA 1 language to correlate with NFPA 30, since NFPA 1 adopts NFPA 30 in its entirety.

New Code Section Correlation w/ Existing NFPA 30

Rationale Potential UL Test/Criteria Questions for UL

19.2.1* Cooking Oil. Where used in this chapter, cooking oil shall be defined as a Class IIIB combustible liquid. This definition shall apply to both fresh, or new, cooking oil and waste, or used, cooking oil.

Class IIIB liquid Establishes terminology

A.19.2.1 Cooking oil is a Class IIIB liquid with a high flash point typically above 500° F. Because of this high flash point, it represents a lower fire hazard than other Class IIIB liquids having a flash point lower than 500° F. Fresh, or new, cooking oil is supplied to the user for cooking operations. As the oil becomes degraded through repeated use, it must be replaced with fresh oil. This waste oil, or used oil, is recovered from the cooking appliance and temporarily stored for offsite removal. To maintain fluidity in the transfer process, the waste oil must be heated. This heating is on the order of 100° F, well below the flash point temperature.

Hazard is less than lower flash point IIIB liquids - harder to ignite. Notes that flash point is usually greater than 500F; some may be slightly below, fat in used oil may slightly lower FP

Approval for use with new and used cooking oil only

19.7 Commercial Kitchen Cooking Oil Storage Tank Systems.

Chapters 18, 21, 22 and 27 Current chapters do not anticipate this situation - more industrial applications

New special investigation - new technology. UL to establish approval method (to meet listing requirement) for tank and system components, i.e. a listing for a system

tank vs. system

19.7.1 Scope.

19.7.1.1 This section shall apply to cooking oil storage tank systems located in commercial kitchens where tank capacities are greater than 60 gallons.

Not a container, Chapter 9 does not apply

Intended for requirements inside a building; not applicable to outside storage

Proposed New Section 19.7, NFPA 30 6/10/2013 Restaurant Technologies, Inc. Page 1 of 17



19.7.1.2 This section applies to both fresh and waste cooking oil storage tank systems.

New language added to 2012 editions of NFPA 1 and IFC for cooking oil systems in commercial kitchens addresses waste cooking oil only. Fresh cooking oil systems were not anticipated.

19.7.1.3 Where there are conflicts in the requirements of other chapters of this code and this section, the requirements of this section shall take precedent.

Chapters 18, 21, 22, 27 New section, Chapter 19.7, is being proposed at the request of NFPA 30 TC on Fundamentals and TC on Operations. The goal in creating this new section is to capture modifications or exceptions to current NFPA 30 requirements in Chapter 18, 20, 22 and 27. There are a number of chapters in NFPA 30 that apply to these systems, including chapters on storage tanks, transferring and dispensing liquids, piping systems, etc. These chapters have been reviewed in detail. Those specific requirements that are in potential conflict with the plastic storage tank and transfer system, the new steel tank system (NFPA 1 and IFC), and known other installed systems, have been identified and alternate methods or exceptions developed where appropriate. This is a cleaner approach than trying to add exceptions everywhere in the existing code, and is an approach that is easier for users, particularly fire officials, to use.




A.19.7.1.3 The goal in creating new section is to consolidate in one location all requirements for commercial kitchen cooking oil storage and operations. There are a number of chapters in NFPA 30 that apply to these systems, including chapters on storage tanks, transferring and dispensing liquids, piping systems, etc. Many of these requirements are more applicable to industrial or process situations. Commercial kitchen cooking oil storage and use was not anticipated. All applicable chapters have been assessed in detail. Those specific requirements that are in potential conflict with the plastic or steel storage tank and piping systems have been identified and alternate methods or exceptions developed where appropriate. This approach eliminates the need to add exceptions throughout the existing code, and is an approach that is easier for users, particularly fire officials.

Inserted at the request of the TG reviewing this proposal

19.7.2 Design and Construction of Cooking Oil Storage Tanks.

21.3.5 tanks to be design IAW standards for the material of construction

It could be argued that cooking oil storage tanks are part of a process, thereby making them something other than storage tanks by definition (see 3.3.51.6).




19.7.2.1 Materials of Construction. Tanks shall be of metallic or nonmetallic construction.

21.4.1 allows steel or other noncombustible materials 21.4.1.2 states where tanks of combustible construction are permitted. The commercial cooking oil tank meets 21.4.1.2c aboveground storage of Class IIIB liquids not exposed to a spill or leak of Class I or II liquid

Combustible (plastic) construction allowed because of limitations of tank construction requirements in metallic tank standards, which do not anticipate food grade applications.

19.7.2.1.1 The materials of construction for tanks and their appurtenances shall be compatible with cooking oil.

21.4.1.1

19.7.2.1.2* For tanks storing waste cooking oil, the materials of construction for tanks and their appurtenances shall be compatible with cooking oil at minimum temperatures of 140°F (60° C) continuous and 235°F (113° C) intermittent.

21.4.1.1 Establishes additional criteria for storing waste cooking oil at temperatures above ambient. Waste oil must be kept at or above 100°F to maintain fluidity needed to transfer oil. Maximum intermittent temperatures based on actual field conditions.

yes

A.19.7.2.1.2 Waste oil is drained from a commercial fryer, via a transfer pump and lines, to a waste oil storage tank. The oil in the fryer may be hot, up to 375° F, still well below the oil flash point. Experience shows that the oil loses significant heat in the transfer process. The maximum temperature of waste cooking oil entering the storage tank are typically below 235° F (113° C). The materials of construction must be designed to be used with cooking oil in this temperature range.

Information based on actual field conditions.

19.7.2.2 Design Standards.




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

Current NFPA 1 Section 50.6.3 and IFC Chapter 6 requirements; 21.4.2.1 Design Standards for Atmospheric Tanks references these standards

A.19.7.2.2.1 Existing steel tanks listed for flammable and combustible liquids are considered acceptable for waste oil use. These tank standards contain design and construction requirements that would not meet food code requirements, making the tanks unacceptable for storage of liquid food products (fresh cooking oil).

19.7.2.2.2 Nonmetallic cooking oil storage tanks shall be in accordance with all of the following:

Nonmetallic tanks storing IIIB liquids are permitted to be used where they are not exposed to a spill or leak from Class I or II liquids (21.4.1.2). Criteria needs to be established. Chapter 18 permits "open" tanks of Class IIIB liquid in use ( 18.4.1;18.4.2)

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

Based on feedback from IFC code hearing - explicitly state that the tank will be listed; deleted reference to ASTM D1998 in recognition that new cooking oil tank standard and system listing should be created

UL to establish approval method (to meet listing requirement) for tank and system components, i.e. a listing for a system.

Describe differences between listing/classification/labeling; New and Innovative Product Outline of Investigation - that is the process they anticipate




(2) Tanks shall not exceed 200 gallons per tank.

Input from NFPA 1 Committee - suggested limiting the overall tank size. Qualitatively established based on market of tanks used. Note, Chapter 18.85.4.1 would permit 20 unprotected IBCs ,each not exceeding 793 gallons, for Class IIIB liquids in Incidental Operations. The IFC would permit 3300 gal of IIIB liquid in an open system (5003.1). The proposed limitation on storage quantitiy is a balance between essentially unrestricted quantities, in unprotected IBCs for example, and the recognition that this is for a restaurant occupancy.

19.7.2.3 Normal Venting. Normal vents - No restrictions for IIIB liquid in 21.4.3, Chapters 22 and 27.

Comments from T.Ordile and J. Shapiro. This is already permitted by NFPA 30; it is in conflict with IFC Section 5704.2.7.3.3, which permits normal tank venting inside the building when the vent is normally closed (pressure/vacuum vent), which requires normally closed vent. No technical rationale provided in the original IFC code change to require normally closed vent. Rationale for IFC requirement evidently relates to overfill protection. Overfill protection is provided in Proposed Section 19.7.2.4

19.7.2.3.1 Normal venting shall be located above the maximum normal liquid line.

21.4.3.1 Same requirement as in 21.4.3.1. Reiterating to minimize possibility of spills from filling tank.




19.7.2.3.2 The size of the vent shall have a minimum effective area at least as large as the largest filling or withdrawal connection.

21.4.3.3 Requires minimum equal to largest fill or withdrawal opening, but not less than 1.25 inch diameter

Performance-based approach. To meet food safety standards, RTI vent procedure is to use cap with a number of small holes, understanding that vent is located above the maximum normal liquid line. Intent of proposed language is to permit this approach, as long as effect vent area has a minimum effective area at least as large as the largest filling or withdrawal connection. Should be ok for steel also.

Verify vent size meets or exceeds largest fill or withdrawal connection.

19.7.2.3.3 Normal vents, including vent piping, smaller than 1.25 in. (32 mm) nominal inside diameter shall be tested to verify internal tank pressures remain below a gauge pressure of 0.5 psi (3.5 kPa) under maximum flow rates for tank filling and withdrawal. These tests shall be permitted to be conducted by a qualified, impartial outside agency or by the manufacturer if certified by a qualified, impartial observer

21.4.3 The basis of this concept comes from 22.7.3.10.3 for emergency venting pressure relief devices. It is adapted to the normal venting. RTI tank technically does not meet the minimum specified single vent size of 1.25 in specified in 21.4.3.3.

Include test to verify vent device maintains pressure/vacuum inside tank of less than 0.5 psi, per 21.4.2.1.2, during maximum fill and withdrawal operations.

19.7.2.3.4* Normal vents shall be permitted to vent inside the building

Permitted by NFPA 30; permitted by IBC if vent is a normally closed vent (pressure vacuum vent)

A.19.7.2.3.4 Ignitable vapors are not created with high flash point cooking oil stored under the conditions required in Section 19.7.

19.7.2.4 Emergency Venting.

19.7.2.4.1 Cooking oil storage tanks shall contain emergency relief venting in accordance with Chapter 22.

22.7 Required per 22.7.1.1




19.7.2.4.2* For non-metallic cooking oil storage tanks, emergency relief venting shall be permitted to be in the form of construction. This includes the low melting point of the tank material.

22.7.1.1 Meets current current requirement - device or construction; the proposal is to permit construction feature (melting and holing of tank) to provide emergency venting.

A.19.7.2.4.2 Nonmetallic tanks will melt above the liquid line as an exposure fire progresses, venting the vapor space of the tank.

For example, as described in FM 7-28, emergency vents for GRP tanks not required since they will self vent.

19.7.2.4.3 Emergency relief venting in the form of construction for metallic tanks shall be prohibited.

22.7.1.1 permits venting by construction for any tank material

Addresses comment by Jeff Shapiro that steel tanks should not be permitted to vent via construction design

19.7.2.4.4 Emergency vents shall be permitted to vent inside the building.

Permitted by NFPA 30 (not explicitly prohibited). Permitted by IFC (5704.2.7.4).

19.7.2.5* Prevention of Overfilling of Cooking Oil Storage Tanks. Every cooking oil storage tank shall be provided with means to prevent an accidental overfill. Such means shall be automatic and fail-safe in nature.

18.5.2.3 deactivate pump in event of spill or fire

21.7.1 requires overfill protection for Class I and II liquids only (Class III not required). Proposed langauge provides extra level of safety; cooking oil overfill would present slip hazard. Also intended to meet IFC intent to have overfill protection through use of pressure vacuum vent device in the venting requirements of 5704.2.7.3.3; IFC 5001.4.1 requires liquid level control for open tanks

A19.7.2.5 Although generally not required for tank storage of Class IIIB liquids, overfill protection is provided for the cooking oil storage to prevent inadvertent spillage from a tank.

19.7.2.6 Tank Heating.




19.7.2.6.1* Electrical equipment used for heating cooking oil shall be listed to ANSI/UL 499, Standard for Electrical Heating Appliances , and shall comply with NFPA 70, National Electric Code . Use of electrical immersion heaters shall be prohibited in nonmetallic tanks.

Basic safety feature for plastic tank - do not allow electric immersion heater. This supports the original intent of NFPA 1 and IFC language for cooking oil storage tanks, added in 2012.

UL 499 listed equipment as part of system approval

A.19.7.2.6.1 The prohibition of an electrical immersion heater in nonmetallic tanks eliminates a primary ignition scenario for the oil stored in a nonmetallic tank.

19.7.2.6.2* Electrical equipment used for heating cooking oil shall comply with NFPA 70 and shall be equipped with automatic means that limit the temperature of the contents of the tank to less than 140° F (60° C).

Basic safety feature. Temperature limits based on maximum allowable continuous temperature to maintain structural integrity of nonmetallic tanks.

A.19.7.2.6.2 The temperature limitation of 140°F corresponds to ASTM C1055 (ISO 13732-1) restrictions for maximum allowable temperatures of nonmetallic industrial surfaces for human contact.

19.7.3 Tank Installation and Testing.

19.7.3.1 Location of Cooking Oil Storage Tanks. Tanks shall be installed in locations appropriate for storage of foodstuffs or inventory, and shall not be installed in areas designated as cooking areas.




19.7.3.1.1* Tanks shall be spaced at least 3 ft. (0.9 m) away from any cooking appliances or surfaces heated to above 140° (60° C) continuous, and at least 6 ft. (1.8 m) away from any open flame.

Prevent potential ignition of tank from adjacent heat source. Came up in prior NFPA 30 meeting. Spacing based on engineering judgment; in some situations, NFPA 96 allows closer spacing, combustible permitted within 16 inches of adjacent cooking equipment

A.19.7.3.1.1 The kitchen cooking area has historically been an area where fires occur. It is appropriate to locate tanks away from this potential ignition source.

19.7.3.1.2* Tanks shall not be installed under commercial kitchen ventilation hoods.

May void listing of existing suppression system if installed under an active hood system. Installation under an inactive hood is probably ok.

A.19.7.3.1.2 This is an area of potential accidental ignition.

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

22.4.2.1.2 Section 22.4.2.1.2 implies IIIB liquid tanks should be spaced 3 feet from one another. This anticipates an industrial situation with large outdoor tanks. No need for this requirement.

19.7.3.2 Foundations for and Anchoring of Cooking Oil Storage Tanks.

Basis - 22.5.1, 22.5.2 and 21.7.3 - Requirements reflect actual installation practice.

19.7.3.2.1 Tanks supports shall be secured to the tank and the floor to prevent the tank from tipping over. For flat-bottom tanks resting directly on the floor, the tank shall be secured to the floor to prevent the tank from tipping over.

22.5.2




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

22.5.1.3

19.7.3.2.3 Where a tank is located in areas subject to flooding, the method for anchoring the tank to the floor shall be able to prevent the tank, either full or empty, from floating during a rise in water level up to the established maximum flood stage. Engineering evaluation by a qualified, impartial outside agency shall be an acceptable method of meeting this requirement.

21.7.3

19.7.3.3 Tank Openings Other than Vents.

19.7.3.3.1 Each connection to the tank below the normal liquid line through which liquid can normally flow shall be provided with an internal or external valve located as close as possible to the shell of the tank, in accordance with Chapter 22.

22.13.2 Basis of this requirement comes from Sections 22.13.1 and 22.13.2 For cooking oil tanks, openings in tank above the liquid line are for filling or removal of oil. Proposal is performance based, to prevent continuous inadvertent discharge of oil from the tank.




19.7.3.3.2* Each connection to the tank above the normal liquid line through which liquid can normally flow shall not be required to have a valve, provided there exists a liquid-tight closure at the opposite end of the line. The liquid-tight closure shall be in the form of a valve, a plug, or a coupling or fitting with positive shut-off.

22.13.1 Basis of this requirement comes from Sections 22.13.1 and 22.13.2 For cooking oil tanks, openings in tank above the liquid line are for filling or removal of oil. Proposal is performance based, to prevent continuous inadvertent discharge of oil from the tank.

A19.7.3.3.2 An example of a fitting with a positive shut-off is a spring-loaded check valve or a hydraulic quick-coupler with a spring-loaded poppet.

Devices for flow control that are common to commercial fryers, filteration devices, and cooking oil storage systems.

19.7.3.4 Field Testing. 19.7.3.4.1* As an alternate method to testing requirements in Chapter 21, cooking oil storage tanks shall be tested for leaks at the time of installation by filling the tank with cooking oil to a liquid level above the highest tank seam or connection within the normal liquid level. Before the tank is placed in service, all leaks shall be corrected in an approved manner or the tank shall be replaced.

21.5; 21.5.2.5 Hydrostatic testing would contaminate the tank with water. Would be very difficult to remove all the moisure from a tank installed in the field prior to placing the tank in service. Testing with air pressure would be problematic based on some top connections on nonmetallic tanks not being air-tight.




A.19.7.3.4.1 Cooking oil storage tanks are atmospheric tanks with open vents. The requirement in Chapter 21 to pressurize the tank for leak testing would be difficult to achieve in the field due to tank construction and configuration. It is also desirable to prevent the contamination of water in a cooking oil tank. A more appropriate test would be to fill the tank with cooking oil to cover all connections and seams below the normal liquid level line.

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

21.5.1.1

19.7.4 Fire Protection for Cooking Oil Storage Tanks.

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

27.7.2.1 Tank identification IAW 27.7.2.1. Additional requirement to identify contents, to aid firefighters in indentifying contents of tanks, based on input from several fire code officials.




19.7.4.2* In areas where tanks are located, no additional ventilation is required provided adequate general human occupancy ventilation is provided, and all cooking equipment is provided with exhaust systems in accordance with NFPA 96, Standard for Ventilation Control and Fire Protection of Commercial Cooking Operations .

Establish that special ventilation requirements for active cooking areas (hoods) is not required for tank storage. This addresses a comment by Tony Ordile.

A.19.7.4.2 Supplemental ventilation, as is required for cooking operations, is not needed for cooking oil storage tanks.

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

Normal natural or mechanical ventilation should be provided in areas with tank storage.

19.7.5 Transfer Lines.




19.7.5.1* Design and Construction of Fresh Cooking Oil Transfer Lines. Fresh cooking oil transfer lines shall be permitted to be constructed of metallic or nonmetallic materials which are compatible with cooking oil and food products. In addition, nonmetallic transfer lines shall also meet the following requirements:

Hoses only addressed in Chapter 18; 18.5.2.1, hoses need to be approved. Means of conveyance for piping systems 27.4.1;27.4.4;27.4.6.

Concepts in Chapter 18 and 27 used to establish proposed requirements, which does not address this specific situation other than hoses have to be "approved". 27.4.4 low melting point pipe materials requires locating these materials where they are: resistant to damage by fire; or, where leakage doesn’t expose persons, important buildings or structures; or, where leakage can be controlled by valves. Criteria developed to: specify construction materials which will be resistant to normal operating conditions anticipated; limit the possibility of overflow or inadvertent discharge of liquid from cooking oil lines usually installed above drop ceiling.

Most of Section 19.7.5 could use acceptance criteria/tests

(1) Transfer lines used for pressure applications shall be rated for 100 psi (689 kPa) working pressure at 70° F (21° C), or the maximum output pressure of the transfer pump, whichever is higher.

Actual practice - set pressure limit

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

Actual practice - set vacuum limit

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

Actual practice - set temperature limit

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

Actual practice - limit diameter so quantity of residual oil in fresh oil line is kept at a minimum. Waste lines typically empty.

(5) Leakage shall be controlled through the use of check valves or anti-siphon valves at points where the lines connect to the fresh oil tank.

18.5.2.1 and 22.13.1 Also address concern raised at NFPA Public Input meeting




A.19.7.5.1 Transfer lines will contain oil during fill and removal operations. Waste oil lines are generally pumped until there is little residual oil remaining in the lines. Fresh cooking oil lines are likely to contain residual oil after fill and removal operations. Restricting the fresh oil line size to 1.25 inches maximum inside diameter limits the amount of oil in the line. Additionally, the requirement for check valves or anti-siphon valves on the lines at points where the lines connect to the tank eliminates the possibility of a compromised line siphoning the contents of the tank.

19.7.5.2* Design and Construction of Waste Cooking Oil Transfer Lines. Waste cooking oil transfer lines shall be permitted to be constructed of metallic or nonmetallic materials which are compatible with cooking oil.

19.7.5.2.1 Transfer lines shall be rated for use with cooking oil at elevated temperatures of 275° F (135° C) continuous and 350° F (177 ° C) intermittent.

Establish test parameters for waste oil cooking lines that may handle oil at above ambient temperature - based on actual practice

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

Actual practice - set pressure limit

A.19.7.5.2 The temperature and pressure ratings for the waste oil lines are consistent with the maximum expected conditions.




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

18.5.2.1, 18.5.2.3, and 18.5.6 Based on requirements in Section 18.5.2 -Provide fail safe flow control feature

19.7.5.4 Pressure Control. Pumping systems used to transfer cooking oil shall have means to prevent over-pressurization of transfer lines. These means shall be in the form of relief valves, bypass valves, pressure sensor devices, or the pressure limitation of the pump itself.

18.4.5, 27.3.1, and 27.4.1 To address intent of requirements in 27.3.1 and 27.4.1

19.7.5.5 Installation of Cooking Oil Transfer Lines in Plenum-rated Spaces. Cooking oil transfer lines installed in plenum-rated spaces shall be enclosed in noncombustible raceways or enclosures, or shall be covered with a material listed and labeled for installation within a plenum.

NFPA 90A Similar to existing requirements in the IMC; gypsum protection eliminated based on comment at IFC Public Hearings. Note - NFPA 90A would prohibit this condition.

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

27.7 Proposed language is more appropriate for hose.
