TECHNICAL COMMITTEE ON INTERNAL COMBUSTION ENGINES · PDF file · 2012-05-17Technical Committee on Internal Combustion Engines March 4, ... The combustion gas turbine starting sequence

TECHNICAL COMMITTEE ON INTERNAL COMBUSTION ENGINES

AGENDA

Technical Committee on Internal Combustion Engines National Fire Protection Association Offices

Quincy, MA Wednesday, May 23, 2012, 8:00 AM to 5:00 PM Thursday, May 24, 2012, 8:00 AM to 12:00 PM

1. Call to Order. 2. Introduction of Attendees. Update of Committee Roster. (Attachment № A1) 3. Approval of Minutes of Last Meeting. (March 2011 Web Conference) (Attachment № A2) 4. Report of Committee Chair. 5. Report of Staff Liaison.

Review of Technical Committee Scope. (Attachment № A3) Review of Technical Committee Membership. (Attachment № A3)

- Replacements for B. Bischoff, M. Gustafson, D. Hollinger Enforcer Participation Emphasis Program. Alternate Member Emphasis Program. Review of Fall 2013 Document Revision Schedule. (Attachment № A4)

6. Report on Status of NFPA 56PS. (L. Danner) 7. Report on Wind / Seismic Issues. (R. Shaffer) 8. Status of Proposed Tentative Interim Amendment to 9.3.3 of 2010 Edition of NFPA 37.

(Attachment № A5) 9. Report of Chapter Task Groups. 10. Proposed Amendments to Chapter 4 of 2010 Edition of NFPA 37. (Attachment № A6) 11. Review and Action on Proposals to Amend 2010 Edition of NFPA 37. (Attachment № A7) 12. Review and Action on Additional Suggested Amendments to 2010 Edition of NFPA 37. (Attachment № A8) 13. Recent Correspondence & Communications. (Attachment № A9)

14. Other Old Business. (NONE) 15. New Business.

Proposed Air Toxic Rules – US EPA. (Attachment № A10) Requirement for Oil Safety Valve – NFPA 31 vs. NFPA 37.

[NFPA31 requires such valves; NFPA 37 does not.] Termination of Normal vents for Sub-Base Tanks. (Attachment № A11) RE: Subsection 4.1.4 of NFPA 37, can an intervening barrier wall be considered as equivalent to

separation distance? (Attachment № A12) Application of Subsection 4.1.2 to stationary engines and their fuel tanks in garages.

(Attachment № A13) Engines in Dedicated Enclosures Installed in Buildings. (Attachment № A14) Changes in NFPA 85 Provisions for HRSG and Correlation with NFPA 37. (J. Biggins)

16. Schedule Next Meeting(s). 17. Adjournment.

Address List No PhoneInternal Combustion Engines INT-AAA

Robert P. Benedetti05/17/2012

INT-AAA

Clifford C. Roberts

ChairChartis InsuranceGlobal Marine & Energy15019 Eaglerise DriveLithia, FL 33547

I 10/6/2000INT-AAA

Stephen P. Wetter

SecretaryCaterpillar, Inc.Electric Power Division560 Rehoboth RoadGriffin, GA 30224

M 1/1/1996

INT-AAA

James B. Biggins

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

SE 1/1/1992INT-AAA

Lawrence M. Danner

PrincipalGeneral Electric, Energy300 Garlington RoadGTTC Room 200DGreenville, SC 29615-0648

M 7/19/2002

INT-AAA

Kenneth M. Elovitz

PrincipalEnergy Economics, Inc.26 Elm StreetFoxboro, MA 02035

SE 1/1/1994INT-AAA

Fred L. Hildebrandt

PrincipalJanus Fire Systems1102 Rupcich Drive, Millennium ParkCrown Point, IN 46307Fire Suppression Systems Association

IM 8/2/2010

INT-AAA

Zuhair M. Ibrahim

PrincipalExponent, Inc.5401 McConnell AvenueLos Angeles, CA 90066

SE 3/4/2009INT-AAA

David Nieman

PrincipalBechtel Power Corporation5275 Westview DriveFrederick, MD 21703

SE 8/5/2009

INT-AAA

Steven H. Pasternack

PrincipalIntertek Testing Services3933 US Route 11Cortland, NY 13045

RT 4/17/2002INT-AAA

Owen M. Preston

Principal3221 Blair DrivePalatka, FL 32177

SE 7/1/1994

INT-AAA

Y. R. Reddy

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

U 4/1/1994INT-AAA

John E. Reiter

PrincipalAES Corporation237 Tall Pines DriveMineral, VA 23117

U 7/19/2002

INT-AAA

Richard Scott

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

I 1/1/1994INT-AAA

Ron Shaffer

PrincipalIEA Incorporated9625 55th StreetKenosha, WI 53144

M 4/28/2000

1

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ATTACHMENT No. A1

Address List No PhoneInternal Combustion Engines INT-AAA

Robert P. Benedetti05/17/2012

INT-AAA

Milan Tretinjak

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

M 4/17/2002INT-AAA

Bruce J. Wertz

PrincipalPower Plant Management Consulting LLC4332 Austin Farm TrailAcworth, GA 30101

SE 8/9/2011

INT-AAA

Gerard J. Schnee

AlternateSolar Turbines Incorporated9250 Skypark CourtSan Diego, CA 92123Principal: Milan Tretinjak

M 10/27/2009INT-AAA

Robert P. Benedetti

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

7/2/2002

2

INT.2011-03-04 Web Conference Minutes.doc

TECHNICAL COMMITTEE ON

INTERNAL COMBUSTION ENGINES

MINUTES of WEB CONFERENCE

Technical Committee on Internal Combustion Engines March 4, 2011

I. ATTENDANCE

B. G. Bischoff, Chemetron Fire Systems L. M. Danner, General Electric Energy K. M. Elovitz, Energy Economics, Inc. F. L. Hildebrandt, Janus Fire Systems D. W. Hollinger, District of Columbia Fire/EMS Department Z. M. Ibrahim, Exponent, Inc. D. Nieman, Bechtel Power Corporation S. H. Pasternack, Intertek Testing Services O. M. Preston, Palatka FL J. E. Reiter, AES Corporation C. C. Roberts, Chartis Global Marine & Energy, CHAIR G. J. Schnee, Solar Turbines Incorporated R. Shaffer, IEA Incorporated R. P. Benedetti, National Fire Protection Association, STAFF LIAISON

II. MINUTES 1. The web conference was called to order at 11:00 AM (Eastern Time) by Technical Committee Chair

Cliff Roberts. 2. Participants introduced themselves. The Staff Liaison reported on reappointment of Jim Biggins to

the Technical Committee. 3. The Minutes of the last meeting (April 21, 2009 conference call) were unanimously approved as

submitted. 4. The Staff Liaison and Larry Danner reported on the status of the new NFPA project on Gas Process

Safety (NFPA 56). The NFPA Standards Council has approved the scope of the project and the start-up roster.

5. Larry Danner presented a summary of the issues related to “gas blow” processes, including the

attendant safety issues.

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ATTACHMENT No. A2


6. The Technical Committee discussed Tentative Interim Amendment (TIA) 37-10-1, which amended

Paragraphs 11.4.4.1.1 and 11.4.4.2, regarding the duration of maintaining the design concentration of gaseous extinguishing agents. Action Item: Technical Committee members are directed to review this issue and submit appropriate concerns to the Staff Liaison for inclusion in the next meeting’s Agenda.

7. The Technical Committee agreed to establish Chapter Task Groups to review the 2010 edition of

NFPA 37 for needed improvements. Task Group leaders are as follows: Chapters 1, 2, 3 [R. Benedetti] Chapter 4 [O. M. Preston] Chapter 5 [L. Danner] Chapters 6 & 7 [D. Hollinger] Chapter 8 [Z. Ibrahim] Chapter 9 [G. Schnee] Chapter 10 [R. Shaffer] Chapter 11 [C. Roberts]

Action Item: Technical Committee members who wish to participate on any of the Task Groups should contact the Task Group leader and the Staff Liaison. Action Item: Task Group reports should be submitted to the Staff Liaison by Friday, September 30, 2011.

8. The Technical Committee discussed the need for a Tentative Interim Amendment to reinstate the

requirement for a purge cycle for gas turbines (Subsection 9.3.2 of the 2006 edition of NFPA 37). The Technical Committee decided to proceed as quickly as possible and developed a draft of a TIA to reinstate the language as new Subsection 9.3.3 in the current edition. Larry Danner agreed to develop a statement to justify emergency nature. The proposed TIA reads: Add a new Section 9.3.3 to read as follows: “9.3.3 The combustion gas turbine starting sequence shall include a purge cycle that will result in a nonignitible atmosphere in the turbine and its exhaust system prior to the start of the ignition sequence and the introduction of fuel.” Submitter’s Reason: The purpose of this Tentative Interim Amendment (TIA) is to reinstate an important safety provision of earlier editions of NFPA 37 that was inadvertently deleted in the processing of the current 2010 edition. This requirement appears in the 2006 edition of NFPA 37 as Subsection 9.3.2. Technical Validity: Proposal 37-20 (Log #CP19) in the Fall 2009 Report on Proposals (ROP) proposed a rewrite of Chapter 9 of NFPA 37. This proposal was accepted by the Technical Committee on Internal Combustion Engines and the text being proposed for addition by this Tentative Interim Amendment (TIA) appears in the proposal as Subsection 9.3.2. Comment 37-7 (Log #6) proposed amendments to this rewrite of Chapter 9 in the form of a new rewrite of the text from Subsection 9.2.1 to the end of the chapter. This comment also was accepted. Unfortunately, the text of Subsection 9.3.2 from the 2006 edition was not included in the text of the public comment and, therefore, does not appear in the text accepted by the rewrite. A poll of the Technical Committee members disclosed that it was never anyone’s intent to delete this provision and all agreed the text needs to be reinstated. Emergency Nature: [text to come] Action Item: The Staff Liaison was directed to prepare the Tentative Interim Amendment and circulate it for letter ballot to the Technical Committee.


9. The Technical Committee determined that the next revision cycle for NFPA 37 will be the Fall 2013 cycle. The cycle schedule is attached. Action Item: The Staff Liaison was directed to notify NFPA Standards Administration Department of the Technical Committee’s intent.

10. The Technical Committee discussed the following items of new business:

Ken Elovitz brought up the issue of UL 900 dropping Class 1 vs. Class 2 designations for air filters. This has impact on 4.1.1.5 of NFPA 37, which states: “For reciprocating engines fueled with a Class I liquid or with a flammable gas, combustion air filters shall be listed as Class 1 when tested in accordance with UL 900, Standard for Air Filter Units. For all other applications, air filters for engine combustion shall be listed as Class 1 or Class 2 when tested in accordance with UL 900.” Action Item: Ken Elovitz agreed to research this issue.

The Technical Committee discussed how NFPA 37 should deal with wind-loading issues and seismic loading issues. Action Item: Ron Shaffer agreed to research this issue.

11. The web conference ended at 12:30 PM (Eastern Time).

INT Scope Statement & Member Balance.doc - 5/16/2012

ATTACHMENT No. A3

TECHNICAL COMMITTEE ON INTERNAL COMBUSTION ENGINES

SCOPE STATEMENT

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

COMMITTEE MEMBERSHIP BALANCE

Members: 16 M: 4 (25%)* U: 2 (12%) Voting Alternates: 0 I/M: 1 (6%) L/C: L/C: 0 Alternates: 1 R/T: 1 (6%) E: 0

Non-Voting: 0 I: 2 (12%) SE: 6 (38%) Emeritus 0

Task Group: 0 Hold List: 0 Balance: Overbalanced by 1 SE *(fire suppression systems: 0 prime movers: 1 system components: 1 turbines: 2)

2013 FALL 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* 1/4/2012 1/4/2012

Final Date for TC First Draft Meeting 6/22/2012 3/16/2012

Public Input Posting of First Draft and TC Ballot 8/3/2012 4/27/2012

Stage Final date for Receipt of TC First Draft ballot 8/24/2012 5/18/2012

(First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 8/31/2012 5/25/2012

Posting of First Draft for CC Meeting 6/1/2012

Final date for CC First Draft Meeting 7/13/2012

Posting of First Draft and CC Ballot 8/3/2012

Final date for Receipt of CC First Draft ballot 8/24/2012

Final date for Receipt of CC First Draft ballot ‐ recirc 8/31/2012

Post Final First Draft for Public Comment 9/7/2012 9/7/2012

Public Comment closing date 11/16/2012 11/16/2012

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

11/23/2012 11/23/2012

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

12/8/2012 12/8/2012

Final date for TC Second Draft Meeting 5/3/2013 1/25/2013

Comment Posting of Second Draft and TC Ballot 6/14/2013 3/8/2013

Stage Final date for Receipt of TC Second Draft ballot 7/5/2013 3/29/2013

(Second Final date for receipt of TC Second Draft ballot ‐ recirc 7/12/2013 4/5/2013

Draft) Posting of Second Draft for CC Meeting 4/12/2013

Final date for CC Second Draft Meeting 5/24/2013

Posting of Second Draft for CC Ballot 6/14/2013

Final date for Receipt of CC Second Draft ballot 7/5/2013

Final date for Receipt of CC Second Draft ballot ‐ recirc 7/12/2013

Post Final Second Draft for NITMAM Review 7/19/2013 7/19/2013

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 8/23/2013 8/23/2013

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

10/18/2013 10/18/2013

(& Issuance) Appeal Closing Date for Consent Documents 11/2/2013 11/2/2013

SC Issuance Date for Consent Documents 11/12/2013 11/12/2013

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. A4

ATTACHMENT No. A5

Proposed Tentative Interim Amendment to NFPA 37, Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines

New Subsection 9.3.3

NFPA 37-2010 Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines TIA Log No.: Reference: 9.3.3 Comment Closing Date: Submitter: Clifford C. Roberts, Chartis Global Marine and Energy Property Add a new Section 9.3.3 to read as follows: “9.3.3 The combustion gas turbine starting sequence shall include a purge cycle that will result in a nonignitible atmosphere in the turbine and its exhaust system prior to the start of the ignition sequence and the introduction of fuel.” Submitter’s Reason: The purpose of this Tentative Interim Amendment (TIA) is to reinstate an important safety provision of earlier editions of NFPA 37 that was inadvertently deleted in the processing of the current 2010 edition. This requirement appears in the prior (2006) edition of NFPA 37 as Subsection 9.3.2. Technical Validity: Proposal 37-20 (Log #CP19) in the Fall 2009 Report on Proposals (ROP) proposed a rewrite of Chapter 9 of NFPA 37. This proposal was accepted by the Technical Committee on Internal Combustion Engines and the text being proposed for reinstatement by this TIA appears in the proposal as Subsection 9.3.2. Comment 37-7 (Log #6) proposed amendments to this rewrite of Chapter 9 in the form of a new rewrite of the text beginning with Subsection 9.2.1 and extending to the end of the chapter. This comment also was accepted. Unfortunately, the text of Subsection 9.3.2 from the 2006 edition was not included in the text of the public comment and, therefore, does not appear in the text accepted therein. A poll of the Technical Committee members disclosed that it was never anyone’s intent to delete this provision and all agreed the text needs to be reinstated. This TIA reinstates the provision, numbered accordingly. Emergency Nature: Failure to properly purge the exhaust system of a gas turbine can result in a significant quantity of fuel remaining in the system. History has shown that this residual fuel can ignite explosively during turbine light off, resulting in significant damage to the system, including catastrophic rupture of the exhaust system with attendant release of projectiles that can injure persons in the area and damage other equipment in the area."

ATTACHMENT № A6 PROPOSED REVISIONS TO NFPA 37

FOR DISCUSSION AT MAY 2012 TC MEETING 1) 4.1.1.5 Proposal. The section currently reads: “For reciprocating engines fueled with a Class I liquid or with a flammable gas, combustion air filters shall be listed as Class I when tested in accordance with UL 900, Standard for Air Filter Units. For all other applications, air filters for engine combustion shall be as Class I or Class 2 when tested in accordance with UL 900.” Revise to read: “Air filters for engine combustion air shall be tested and classified in accordance with UL 900, Standard for Air Filter Units. Reason: UL 900 previously defined Class 1 filters as those that, “when clean, do not contribute fuel when attacked by flame and which emit only negligible amounts of smoke”. UL 900 previously defined Class 2 filters as those that, “when clean, burn moderately when attacked by flame or emit moderate amounts of smoke or both”. UL 900 eliminated the Class 1/Class 2 designation in September 2009. Under the current version of UL 900,

A UL 900 Classified filter is an air filter which, when clean, will burn moderately when attacked by flame, or emit moderate amounts of smoke, or both. The air filter unit shall not produce flame or extensive sparks, which are sustained beyond the discharge end of the test duct described in the Standard, when subjected to the flame exposure test. In addition, the burn shall not cause the development of an area of more than 9 square inches as measured below the smoke-density time curve. Additionally, the adhesive material used for coating the filtering media, or other parts of an air filter unit, shall have a flash point of not less than 325 degrees F, Cleveland Open-Cup Method ASTM D92-5a (ANSI Z11.6-1966).

See Camfil Farr Technical Bulletin "UL 900 and UL 586 Filter Classifications". The original reason for referring to UL 900 was to provide guidance on how to comply with the requirement introduced to section 3-1.1.5 of the 1998 edition of the standard that air filters be "of the type that will not burn freely when exposed to a fire". With UL 900 eliminating the Class 1/Class 2 designations, NFPA 37 can no longer make that reference. Research has not uncovered a more suitable standard or other way to define the fire protection requirements for combustion air filters. 2) 4.1.2.1 Proposal: Add Annex item as follows: “NFPA 37 does not require engines to be installed in enclosed spaces or engine rooms. There are applications where there is no fire protection need to enclose the engine in a room. For example, a gas engine-driven air compressor that might be on a large manufacturing floor need not be enclosed in a separate room. Likewise, there is no fire protection need to enclose an engine-driven generator in a parking garage. If an engine is enclosed within a room section 4.1.2.1 establishes requirements for the enclosure. NFPA 37 does not define the term "engine room" even though it is used as the title to section 4.1.2. A reasonable definition might be "an engine room is a room primarily utilized for the installation of an engine". That definition follows the format of the 2009 International Mechanical Code definition of a boiler room. NFPA 37 does not need a definition for "engine room", and Including one might create confusion or conflict with other standards. For example, if an engine-driven emergency or standby generator is located in a room with the standby or emergency electrical equipment it supplies, is the room utilized primarily for the engine or primarily for the electrical equipment? Is the room then an engine room, an electrical room, or a generator room? Similarly, would a room with a diesel engine-driven fire pump be an engine room or a fire pump room? In almost every case, the engine serves some other piece of equipment, so the primary purpose of the room is almost never for the engine. The term "engine room" as used in NFPA 37 is short hand for "a room containing an engine". Adding a definition would not enhance NFPA 37.

Page 2 of 2 Reason: To clarify that NFPA 37 does not require engines installed inside structures to be in engine rooms and to explain why NFPA 37 does not define the term.

Ken / Bob, I inquired about filters for reciprocating engines with the team in Austria. The only applicable filter standard they are aware of is DIN 4102 - this is a Germany specific document so it is not something we will want to reference. Regards, Larry Danner, CSP Principal Engineer GE Energy Product Safety Engineering _____________________________________________________________________________ -----Original Message----- From: Ken Elovitz [mailto:[email protected]] Sent: Monday, March 07, 2011 7:54 AM To: Benedetti, Bob Cc: Danner, Lawrence M (GE Energy) Subject: NFPA 37 4.1.1.5 Filters I talked with Charlie Seyffer of Camfil Farr about the UL 900 change to eliminate the Class 1 designation. Charlie wrote the article I sent that brought this issue to my attention. (1) The new UL 900 comes into effect in May 2012, so the Class 1 designation will remain until then. That timing solves the immediate problem for NFPA 37, so we do not need to address the issue until our ROP meeting. (2) The filter manufacturers are going to continue making products that meet the Class 1 characteristics. As a reminder, the current UL 900 defines Class 1 filters as those that, "when clean, do not contribute fuel when attacked by flame and which emit only negligible amounts of smoke". UL 900 defines Class 2 filters as those that, "when clean, burn moderately when attacked by flame or emit moderate amounts of smoke or both". Charlie is on a committee that is working on what to call the "Class 1" product. I expect to hear from him before our ROP meeting, so we will have something to include in NFPA 37 if we want to maintain the requirement. (3) Charlie mentioned that UL 900 Class 2 filters are self extinguishing when the flame is removed. He also pointed out that the dirt on the filter is a fuel source, so depending on the type and amount of dirt loading, there might not be an appreciable fire protection difference between Class 1 and Class 2 filters. I agree with that reasoning for HVAC applications where much of the filter dirt loading is fibers from recirculated indoor air. I'm not sure it applies to our application, where the dirt loading is mostly sand-like particulates from outdoors (though there are some organic materials like pollen and cottonwood fluff in outdoor air). (4) When I told Charlie about the reason for my inquiry, he offered to check with his locomotive engineering counterparts to see how they address the problem and if they have any suggestions that might be useful for NFPA 37. The end result is that we need to include this topic in the next revision of NFPA 37, we don't need to take any action before then, and I expect to have some information and probably some proposals for committee consideration at our ROP meeting in 2012. Please let me know if you have any questions or need any further information. ENERGY ECONOMICS, INC. Kenneth M. Elovitz, PE 508-543-2447 _____________________________________________________________________________

On 3/4/2011 1:50 PM, Danner, Lawrence M (GE Energy) wrote: Gents, I have queried my counterparts in the GE Jenbacher team if they know of any other standards we might consider. Clearly, a European Normative document is unacceptable but I am hoping there might be another standard under ISO that would be appropriate to consider. Regards, Larry Danner, CSP/*// Principal Engineer***//**//* GE Energy Product Safety Engineering _____________________________________________________________________________ From: Danner, Lawrence M (GE Energy) Sent: Friday, March 04, 2011 1:26 PM To: 'Benedetti, Bob'; 'Ken Elovitz' Subject: RE: Today's Web Conference Bob / Ken, Regarding the discussion of filters, I don't know if this provides a suitable alternate to UL 900 Class 1, but ISO 1182 is a test protocol for non-flammability of materials that we may be able to leverage. Regards, Larry Danner, CSP Principal Engineer GE Energy Product Safety Engineering ------------------------------------------------------------------------------------------------------------------ From: Ken Elovitz Sent: Friday, July 23, 2010 4:09 PM To: Benedetti, Bob Cc: Roberts, Clifford Subject: NFPA 37 4.1.1.5 Hi Bob. NFPA 37 currently calls for combustion air filters on reciprocating engines fueled with a Class I liquid or with a flammable gas to be listed to UL 900 Class 1 (4.1.1.5). I just read an article in the July 2010 issue of Engineered Systems (see attached) that says UL is going to eliminate the Class 1/Class 2 designations in UL 900 for air filters. All filters will have to meet the former Class 2 requirements. Once UL makes that change, NFPA 37 will have a requirement that is impossible to meet. The requirement was added to NFPA 37 in the 1998 edition by CP#24. The justification in the ROP was that NFPA 37 did not previously address filters. I was not the originator of this requirement, though I will take credit (or blame) for the reference to UL 900 as a way to identify at least one way to meet the requirement. Near as I can tell, the language was developed when the committee met in San Antonio in June 1996. I believe the purpose of the requirement is to reduce the chance of a combustion air filter fire in case the engine backfires. Reverting to the former language in NFPA 37-2006 (Air filters shall be of a type that will not burn freely when exposed to a fire) is not enough - the standard has to show users at least one way to meet the requirement and AHJs at least one way to tell when the requirement has been met.

What action can we take so NFPA 37 will not call for something that does not exist? Depending on when UL makes their change, this problem should not wait for the next NFPA 37 revision cycle. Please let me know if you have any questions or need any further information. ENERGY ECONOMICS, INC. Kenneth M. Elovitz, PE 508-543-2447

UL Clears The Airby Charlie Seyffer

Posted: July 1, 2010

What does a simplified Standard 900 mean for manufacturers and users?

Air filter manufacturers have always presented many numbers that users included intheir evaluations. These include dust spot efficiency, arrestance, dust holding capacity,and minimum efficiency reporting value (MERV), among others.

ASHRAE greatly simplified the selection process when they introduced MERV. This valuesupplied the user with the filter’s minimum particle capture efficiency, ensuring that thefilter would provide the protection level required for the process, or protect buildingoccupants in specific applications.

In 2007, ASHRAE also added Appendix J, an additional testing step designed to exposefilters that may not maintain their efficiency over time.

NEW CRITERIA

Now, Underwriters Laboratories (UL) has simplified its Standard UL 900 for evaluating afilter’s combustibility and smoke generating potential when the filter is exposed to directflame. The designations UL Class 2 and UL Class 1 designations are now outdated. UL900 covers both washable and throwaway filters used for the removal of dust and otherairborne particles from mechanically circulated air in equipment and systems.

The vast majority of air filters have historically tested as UL Class 2. The criterion forthis filter classification is that when tested, the clean air filter burns moderately whenattacked by flame, or emits moderate amounts of smoke, or both. A UL Class 1 filter,when clean, did not contribute fuel when attacked by flame and emitted only negligibleamounts of smoke.

Some municipalities required the UL Class 1 product through local codes. In manycases, because of the different construction of Class 1 and Class 2 rated products, theuser paid two to three times the cost of a UL Class 2 product.

Additionally, there was a widespread misconception within engineering circles that a ULClass 1 product was “fireproof.” This was not the case, since a Class 1 product couldburn if submitted directly to an open flame, although it was less likely to contributecombustion byproducts. Both classes, when clean, would self-extinguish when theflame source was removed from contact with the filter.

In the future, filters will only be required to meet the requirements that were formallyrecognized as UL Class 2. Filter frames and labels will carry one marking to designatethat they meet the requirements of the standard. Most filter manufacturers have started

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the conversion process and will be in compliance well before the effective date of May2012. The Underwriters Laboratories website provides complete listings as to whichmanufacturers follow the procedures as prescribed in the Standard and which of theirfilters are in compliance.

It is important to note, after a period of service, that the combustibility and smokegeneration of an air filter depends upon the nature and quantity of the material collectedby the filter. The test requirements of this Standard, for classification purposes, applyonly to air filters in a clean condition. This is a critical step forward. UL is a recognizedleader in independent safety certification and has facilitated a simplified, cost-consciousrevision.

For more information on this subject, see www.filterair.info/ULCert. ES

Charlie [email protected] is manager of marketing and technical materials for Camfil Farr. Contact him [email protected].

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Prop # Log#Comm.Action

Tech.Comm. Section

Sort Listing

Seq#

2 1.3.1, 4.4.1, and 8.2.3.3- ( ):37- INT-AAA F2013

11 1.5.2- ( ):37- INT-AAA F2013

5 2.3.4- ( ):37- INT-AAA F2013

12 3.3.11.3 Secondary Containment Tank- ( ):37- INT-AAA F2013

13 3.3.12.5 Vent Valve- ( ):37- INT-AAA F2013

6 4.1.1.5- ( ):37- INT-AAA F2013

10 4.1.4 and A.4.1.4(2)- ( ):37- INT-AAA F2013

4 5.2.1 and A.5.2.1- ( ):37- INT-AAA F2013

14 6.3.2.5 (New)- ( ):37- INT-AAA F2013

15 6.8.5 (New)- ( ):37- INT-AAA F2013

16 6.9.2 (New)- ( ):37- INT-AAA F2013

17 8.2.6 (New)- ( ):37- INT-AAA F2013

18 9.2.1.4 (New)- ( ):37- INT-AAA F2013

19 10.2.4 (New)- ( ):37- INT-AAA F2013

3 11.4.4.1.1- ( ):37- INT-AAA F2013

1 11.4.4.1.1 and 11.4.4.2- ( ):37- INT-AAA F2013

9 11.4.7- ( ):37- INT-AAA F2013

8 A.11.4.7- ( ):37- INT-AAA F2013

7 B.1.2.5- ( ):37- INT-AAA F2013

Page 1F2013Cycle

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ATTACHMENT No. A7

Report on Proposals – November 2013 NFPA 37_______________________________________________________________________________________________37- Log #2

_______________________________________________________________________________________________Richard Jones, Baker Hughes

Add to Section 1.3.1 as follows:This standard applies to temporary equipment that is being placed in a hazardous area or being used for pumping of

hazardous fluids other than their own fuel for any duration.Exhaust systems equipped with spark-arresting mufflers shall be permitted to terminate in Division 2 or Zone 2

locations as defined in Article 500 and 505 of NFPA 70, National Electrical Code and provided that exhaust gas coolingsystems are employed to insure that the exhaust gas temperatures and exhaust system surface temperatures do notexceed the conditions of temperature rating for the hazardous area.

(Add) If a temporary engine driven unit compressing a flammable gas or pumping a flammable liquid is placed inarea that is not having a similar hazard than the area where the unit is placed must be declared hazardous based on thepumped flammable gas or liquid according to the NFPA 70 and comply with NFPA 70 and this standard in that area. Ifthe area of placement for temporary equipment is already a hazardous area then the temporary unit must comply withthe hazardous area where it is placed in addition to the area created by compressing flammable gas or pumpingflammable liquid as stated above.

The CFR 30 Regulations by The Department of the Interior's (DOI), Bureau of Ocean EnergyManagement, Regulation and Enforcement (BOEMRE) (formally MMS) invoke the NEC codes for offshore platformsand mobile facilities. Major Oil Companies have been discussing the interpretation of 30CFR250.114 to include bothcertification to NEC and NFPA rules. The rules actually discuss API 14 and 14FZ which discusses generators forinstallation but not mobile equipment and directly references the NEC. In relation to this NFPA is used to define dieselunit installations. In discussions with a NFPA help line engineer on NFPA 37, it was stated that NFPA 37 is notapplicable for portable offshore equipment.

A Major Oil company's interpretations is that NFPA 37 does apply and offshore mobile temporary diesel drivenequipment for pumping or other specialize oil service equipment must comply with both NEC 500/505 and NFPA 37.This equipment is sent offshore to platforms for specialized work. The equipment may be on location for 2 days toseveral months then removed to another platform or returned to an onshore base to await the next callout. Typically thisis on an open deck outside but it may be included in a hazardous area because of proximity to vents or the wellhead.The temporary engine is only for Class I Div 2 or Zone 2. Only well monitoring electrical equipment would ever belocated in Class I Div I or Zone 1 and this is clearly defined in NEC 500;505.

NFPA 37 does not clearly define how temporary equipment which by their nature or location could discharge exhaustgases or have hot surfaces can be placed in these areas. European rules such as ATEX provide a clearer discussion ofthe subject using exhaust gas cooling systems that cool the exhaust gases below the T-rating as well as the need forspark arresting devices on the exhaust and flame screens on combustion air inlets, engine ventilation points andexhaust gas outlet. Some systems have shut downs on the engine in the event of gas above a Lower Explosive Limit isdetected at the combustion air inlet that allow running so that flame arresting screens can be installed if it is needed tocontinue to run.

This temporary equipment may at times be required to pump hazardous material to treat a well as well as beingtemporary located in a well site hazardous area. The NFPA 37 document prohibits this without enclosing the engine inseparate building that removes any external hazards or unless it is outside. It also requires the ducting of the exhaust tosafe areas. This may not be practical in some cases.

My proposal is to ask for revisions that more clearly defines temporary mobile diesel equipment other than generatorsfor use on offshore platforms, onshore drilling locations, inland waterway drilling barges and other equipment in NFPA37 or a new standard. There are gaps in the current standard that does not appear to recognize the utilization of exhaustgas cooling, hazardous LEL concentration detector shutdown systems and exhaust gas flame trap technologies definedin foreign rules and currently commercially available that could provide for safe use in the US both offshore andonshore.

1Printed on 5/16/2012


_______________________________________________________________________________________________John Whitney, Clarke Fire Protection Products, Inc. & Clarke Power Generation, Inc.

Revise text to read as follows:In determining the suitability of the equipment or component for use, the authority having jurisdiction shall

consider but not be limited to the following:The current language, although providing good guidance, possibly excludes critical considerations

present in unique installation.



_______________________________________________________________________________________________John F. Bender, Underwriters Laboratories Inc.

Revise text to read as follows:Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096. ANSI/UL 900,

, 2004 edition, with revisions through November 2007 2009.Add ANSI approval designation to ANSI/UL 900 and update referenced standard to most recent

edition.




Revise text to read as follows:A tank that has an inner and outer wall with an interstitial space (annulus)

between the walls and that has a means for monitoring the interstitial space for a leak. [ , 2008]Editorial.




Revise text to read as follows:A valve used to allow venting of air or gas from the system to the atmosphere. [85, 2007]

Editorial.




Revise text to read as follows:For reciprocating engines fueled with a Class I liquid or with a flammable gas, combustion air filters shall be

listed as Class 1 when tested in accordance with ANSI/UL900, . For all other applications, airfilters for engine combustion shall be listed as Class 1 or Class 2 when tested in accordance with UL 900.

Performance requirements of ANSI/UL 900 have been revised and no longer differentiates the classesof filter because it was found that once the filters were in service, there was not enough difference to justify thedistinction between Class 1 and Class 2. This is consistent with recent action to update NFPA 75. Add ANSI approvaldesignation to ANSI/UL 900.



_______________________________________________________________________________________________Marcelo M. Hirschler, GBH International

Revise text to read as follows:Engines, and their weatherproof housings if provided, that are installed outdoors

shall be located at least 1.5 m (5 ft) from openings in walls and at least 1.5 m (5 ft) from structures having combustiblewalls. A minimum separation shall not be required where either of the following conditions exist the conditions of either(1) or (2) apply:

(1) All walls of the structure that are closer than 1.5 m (5 ft) from the engine enclosure have a The adjacent wall of thestructure has a fire resistance rating of at least 1 hour.

(2)*The weatherproof enclosure is constructed of noncombustible materials and it has been demonstrated Full scalefire tests, in accordance with (3), have been conducted with the engine and its enclosure and have demonstrated that afire within the enclosure will not ignite combustible materials outside the enclosure.

(3) The full scale fire tests shall be conducted as follows: (a) in the vicinity of a wall composed of combustible materialssimilar to those expected to be present where the engine and its enclosure are to be located, (b) result in completeconsumption of all combustible materials contained within the engine and its enclosure, (c) represent fire scenarioswhere the engine is operating and where it is not operating and (d) offer a margin of safety between the distance used inthe fire tests and the distance at which the engine and its enclosure is to be placed with respect to the combustible wall.

Means of demonstrating compliance are by means of full-scale fire tests or by calculation Calculationprocedures, such as those given in NFPA 555, , areuseful tools to assess the probability of safe engine placement.

1. Fires with engines can be very severe and therefore full scale fire tests are essential andcalculations should be used only as guidance and predictive tools.

2. Fire tests have demonstrated that there is no need for engines to be constructed with noncombustible materialenclosures if the engine and its enclosure are appropriately designed so that they cannot cause ignition of combustiblewalls nearby.

3. Fire tests have demonstrated that there are various fire scenarios that must be taken into account, principally interms of whether the engine is operating or whether it is not. In fact it has been shown for at least two engine designsthat the fire scenario when the engine is not operating represents a more severe fire scenario because the fans usuallypresent in such enclosures tend to extinguish small fires when the engine is operating. Since there is no assurance thatevery generator will operate with an adequate fan, the fire tests need to be conducted with both the engine operatingand the engine off.

4. The fire tests must be conducted in such a way that there is complete consumption of the combustible materials inthe engine/enclosure, to ensure that the fire tests actually address the fire hazard.

5. There are different types of combustible enclosures and the fire tests should be conducted using the scenario to beused in the actual installation or the most severe type of combustible wall, typically polypropylene siding.

6. There must be a margin of safety so that if the tests are conducted at a distance of, for example 2 ft., the engineenclosure should not be permitted to be placed closer than 3 ft. (50% margin).

7. It is very likely (in view of the typical 5 ft. separation for residential construction) that an engine installed outdoors willnot just be close to a wall of the structure of the person installing an engine outdoors but also to a wall of a neighbor. It isimportant to ensure that, if a generator is installed outdoors, the requirement for fire resistance rating applies to all wallsin the vicinity.



_______________________________________________________________________________________________Lawrence M. Danner, General Electric, Energy

Revise text to read as follows:5.2.1(5)* A low-pressure switch sensor for engines with a 732 kW (2 .5 million Btu/hr) full- load input or greater(6)* A high-pressure switch sensor (manual reset) for engines with a 732 kW (2.5 million Btu/hr) full- load input or

greaterA.5.2.1(5) The sensor required by this paragraph may take the form of a dedicated switch or a device that converts

pressure into an analog or digital signal for action by a Programmable Logic Controller (PLC) or active control system.A.5.2.1 (6) The sensor required by this paragraph may take the form of a dedicated switch or a device that converts

pressure into an analog or digital signal for action by a PLC or active control system.Today's designs for combustion turbines and larger internal combustion engines have moved away

from relay based "ladder logic" controllers to full electronic control systems that allow increased fuel flexibility andoperating efficiency through improved control of the fuel and air delivery functions. These systems use high accuracymeasuring devices to monitor pressures, temperatures and other operating conditions. The "safety" controller is typicallya parallel, nearly duplicate version of the main controller that is dedicated to a safe shutdown of the system in the eventof a parameter that exceeds the programmed limit. To optimize the systems, manufacturers are using identical devicesfor both control and safety functions, just connected to a different controller. This change recognizes the evolution ofcontrol systems from discreet switch based detection to full active sensing of parameters for action by the controlsystem.




Add new text as follows:6.3.2.5 Where conflicts exist between standards, fuel tanks within structures installed to provide fuel to fire pumps

engines shall be installed and piped in accordance with NFPA 20.To provide guidance within the standard for clarity between NFPA 37 and NFPA 20 to resolve

confusions in the field present today.




Add new text as follows:6.8.5 Where conflicts exist between standards, piping between fuel tanks and fire pumps engines shall be installed and

piped in accordance with NFPA 20.To provide guidance within the standard for clarity between NFPA 37 and NFPA 20 to resolve





Add new text as follows:6.9.2 Fuel tanks mounted for fire pumps engines shall provide for gravity feed to the engine in accordance with NFPA

20.To provide guidance within the standard for clarity between NFPA 37 and NFPA 20 to resolve





Add new text as follows:8.2.6 Where conflicts exist between standards, exhaust pipes for fire pumps engines shall be installed and piped in

accordance with NFPA 20.To provide guidance within the standard for clarity between NFPA 37 and NFPA 20 to resolve





Add new text as follows:9.2.1.4 Where conflicts exist between standards, controls for fire pumps engines shall be installed and function in

accordance with NFPA 20.To provide guidance within the standard for clarity between NFPA 37 and NFPA 20 to resolve





Add new text as follows:10.2.4 Instructions for fire pumps engines shall be provided in accordance with NFPA 20.

To provide guidance within the standard for clarity between NFPA 37 and NFPA 20 to resolveconfusions in the field present today.



_______________________________________________________________________________________________Randy J. Kleen, GE Energy

Revise text to read as follows: Total flooding gaseous suppression systems shall be designed to maintain the design concentration

within the enclosure for a minimum of 20 minutes, or until it can be demonstrated that the engine has cooled to belowthe autoignition temperature of combustible material present, whichever is greater. For Aero gas turbines that havethin-wall engine casings and can demonstrate that the engine has cooled much faster than 20 minutes, CO2 designconcentration minimum of 6 minutes shall be maintained or until when the engine has cooled below the autoignitiontemperature of combustible material present, whichever is greater.

NFPA 37 11.4.4.1.1 seems to point to large frame gas turbines that have solid forgings and thick-wallengine casings, which can retain heat after shutdown for extended period of time. Aero gas turbines have ,high-strength alloy material engine casings and thus the outer case cools down very fast following a high powershutdown from result of fire system trip and is well below AIT of the combustible material present in less than 90seconds. Designing fire system concentration hold time much longer than what is necessary is over-kill, increases CO2gas storage size, increases CO2 rack/bottle footprint and the extra costs associated to maintain can be exuberant. PerNFPA 12 and NFPA 850, CO2 concentration needs to provide hold time to cover the hazard present and when theprotected compartment is below the AIT of the combustible material present. Reference NFPA 850 8.5.4.3.3 where italso calls out that the “…manufacture of the gas turbine would provide the cool down time of their units and design theCO2 concentration hold time, as such…”

See a separate attached file of Aero gas turbine event, which shows typical fast stop shutdown event from result of firetrip while at full power. Considering AIT of the combustible materials present: Methane gas 750 deg F, turbine syntheticlube oil 760 deg F, diesel fuel oil 500 deg F. The Aero gas turbine engine casing and hot section is over 100 deg Fbelow AIT of the fuel and oils present within 22 seconds. For good design margin and accounting for variability, roundup to 90 seconds. Accommodating additional margin for CO2 concentration hold time, use 4X factor, so 90 seconds * 4= 6 minutes.

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



_______________________________________________________________________________________________

Clifford C. Roberts, Chartis Global Marine & EnergyRevise Paragraphs 11.4.4.1.1 and 11.4.4.2 to read as follows:

Gaseous suppression systems shall be designed to maintain the design concentration within the enclosurefor a minimum of 20 minutes, or until it can be demonstrated that the engine has cooled to below the autoignitiontemperature of combustible material present, whichever is greater.

Local application gaseous agent suppression systems shall be designed to operate for a minimum of 20minutes, or until it can be demonstrated that the engine has cooled to below the autoignition temperature of combustiblematerial present, whichever is greater.

The purpose of this Tentative Interim Amendment (TIA) is to clearly state the intent of the tworequirements in question. As currently worded, neither Paragraph is clear as to which of the alternate durations takesprecedence over the other. The revisions are intended to eliminate any confusion by specifically stating that the designconcentration must be maintained for whatever period of time is necessary for the engine to cool to a safe temperature,but never less than 20 minutes. This was the intent of the Technical Committee on Internal Combustion Engines whenthe Chapter on Fire Protection Features was expanded by means of a major rewrite in the 1998 edition of NFPA 37.

In the 1997 Fall (ROP), the Technical Committee on Internal CombustionEngines presented its report for the 1998 edition of NFPA 37,

. Proposal 37-104 (Log #CP23) effected a major revision and significantexpansion of (then) Chapter 10, Fire Protection Features. As part of the revision of Chapter 10, the requirementsreflected in 11.4.4.1.1 and 11.4.4.2 were added to the standard. The Substantiation statement for the proposalspecifically states that the “20 minute minimum flooding time in 10-4.2.2 is based on recommendations in NFPA 850.”While it is recognized that the substantiation only mentions the paragraph that is now numbered 11.4.4.2, the tworequirements in question are parallel and it was intended that the minimum 20 minute duration was to be applied in bothcases.

This issue is of an emergency nature that meets the criteria of Section 5.2 of the. First, the TIA corrects an omission in that the current wording of both paragraphs does

not concisely express the intent of NFPA 37 as was intended in the 1997 Fall ROP. The TIA corrects this omission.Second, the TIA intends to lessen a recognized hazard by ensuring that gaseous fire suppression systems can maintainthe required design concentration for the time needed for the engine or turbine to reach a safe condition. This isimportant because of the application of NFPA 37 to many gas turbine power plants that are quite large. Some of thesegas turbines require cool down times that exceed the 20 minute minimum specified in 11.4.4.1.1 and 11.4.4.2. With thecurrent wording, one can design to the 20 minute minimum, even if a longer duration is called for. The installation wouldbe considered in compliance with NFPA 37, yet it could present an unsafe situation in an emergency.



_______________________________________________________________________________________________Scott J. Harrison, Marioff Inc.

Revise text to read as follows: Water mist suppression systems shall be designed and installed in

accordance with NFPA 750 their listing for the specific hazards andprotection objectives specified in the listing.

The reference to water mist suppression methods should be clarified by referencing the appropriateNFPA Standard (NFPA 750). This clearly directs the consultant, engineer or AHJ to the published NFPA guidelines.



_______________________________________________________________________________________________Scott J. Harrison, Marioff Inc.

Revise text to read as follows:A.11.4.7 Water mist fire suppression systems need to be designed specifically for use with the size and configuration

of the specific engine installation or enclosure being protected. Currently there is no generic design method recognizedfor water mist systems. System features, such as nozzle spacing, flow rate, drop size distribution, cone angle, and othercharacteristics need to be determined for each manufacturer's system through full-scale fire testing to obtain a listing foreach specific application. and designed, installed and tested per NFPA 750 Standard on Water Mist Fire ProtectionSystems.

The reference to water mist suppression methods should be clarified by referencing the appropriateNFPA Standard (NFPA 750). This clearly directs the consultant, engineer or AHJ to the published NFPA guidelines.




Revise text to read as follows:Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096. UL 2080,

, 2000. UL 2085,, 1999 1997, Revised 2010.

Update referenced standard to most current edition.


NFPA Document Proposal Form

NOTE: All Proposals must be received by 5:00 pm EST/EDST on the published Proposal Closing Date.

For further information on the standards-making process, please contact the Codes and Standards Administration at 617-984-7249 or visit www.nfpa.org/codes.

For technical assistance, please call NFPA at 1-800-344-3555.

FOR OFFICE USE ONLY

Log #:

Date Rec’d:

Please indicate in which format you wish to receive your ROP/ROC electronic paper download (Note: If choosing the download option, you must view the ROP/ROC from our website; no copy will be sent to you.)

Date 5-2-2012 Name Kevin Carlisle Tel. No. 763-582-1700

Company Karl Dungs, Inc Email [email protected]

Street Address 3890 Pheasant Ridge Dr. NE. City Blaine State MN Zip 55449

***If you wish to receive a hard copy, a street address MUST be provided. Deliveries cannot be made to PO boxes.

Please indicate organization represented (if any)

1. (a) NFPA Document Title Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines

NFPA No. & Year NFPA 37-2010

(b) Section/Paragraph 5.1.1 Fuel gas types

2. Proposal Recommends (check one): new text revised text deleted text

3. Proposal (include proposed new or revised wording, or identification of wording to be deleted): [Note: Proposed text should be in legislative format; i.e., use underscore to denote wording to be inserted (inserted wording) and strike-through to denote wording to be deleted (deleted wording).]

5.5.1* This section shall apply to utilization of fuel gases, including the following: (a) Natural gas (b) Mixed gas (c) Manufactured gas (d) Liquefied petroleum gas (LP-Gas) in the vapor phase (e) LP-Gas/air systems (d) Biogas

4. Statement of Problem and Substantiation for Proposal: (Note: State the problem that would be resolved by your recommendation; give the specific reason for your Proposal, including copies of tests, research papers, fire experience, etc. If more than 200 words, it may be abstracted for publication.)

Clarifies the types of fuel cases covered under this section.

5. Copyright Assignment

(a) I am the author of the text or other material (such as illustrations, graphs) proposed in the Proposal.

(b) Some or all of the text or other material proposed in this Proposal was not authored by me. Its source is as follows: (please identify which material and provide complete information on its source)

I hereby grant and assign to the NFPA all and full rights in copyright in this Proposal and understand that I acquire no rights in any publication of NFPA in which this Proposal in this or another similar or analogous form is used. Except to the extent that I do not have authority to make an assignment in materials that I have identified in (b) above, I hereby warrant that I am the author of this Proposal and that I have full power and authority to enter into this assignment.

Signature (Required)

PLEASE USE SEPARATE FORM FOR EACH PROPOSAL

Mail to: Secretary, Standards Council · National Fire Protection Association 1 Batterymarch Park · Quincy, MA 02169-7471 OR

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Date Rec’d:


Date 4-23-2012 Name 4-23-2012 Tel. No. 763-582-1700







(b) Section/Paragraph 5.2.1



5.2* Gas Trains. 5.2.1 Gas trains, as defined in 3.3.5, shall contain at least the following safety components: (1) An equipment isolation valve (2) A gas pressure regulator, if the prime mover does not operate at the gas supply pressure (3) Two ASSVs (4) A manual leak test valve for each ASSV or an alternative means of proving the full closure of the ASSV (5) A low-pressure switch for engines with a 732 kW (2.5 million Btu/hr) full-load input or greater (6) A high-pressure switch (manual reset) for engines with a 732 kW (2.5 million Btu/hr) full-load input or greater (7) Any other components or equipment that the manufacturer requires for safe operation (8) A vent valve or a VPS for inlet gas pressures more than 2PSI. (9) Flame arrestor when biogases are used and there is risk of having O2 in the gas. (10) Gas filter or strainer.


Clarifies the type of regulator required and adds the requirement for a vent valve, as already specified in 5.2.2. The addition of the flame arrestor is a needed safety device when the biogas could contain air as a result of generation of the fuel. Adds the requirement for gas filter or gas strainer. Debris in the gas has adverse affects many of the safety controls from performing correctly. Adding the requirement for filters or strainers will reduce the risk of debris in the downstream components.








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5.3.1 A gas pressure regulator not complying with 5.3.1.1 shall vent to atmosphere outside the structure at a point at least 1.5 m (5 ft) away from any structure opening.


Proposal clarifies which types of regulators required a vent to atmosphere outside.








Fax to: (617) 770-3500 OR Email to: [email protected]





FOR OFFICE USE ONLY

Log #:

Date Rec’d:


Date 4-23-2012 Name 4-23-2012 Tel. No. 763-582-1700







(b) Section/Paragraph 5.3.1.1



5.3.1.1* The following devices shall not be required to be vented to the outside when installed in accordance with their listing: (1) Any regulator or zero governor that does not use atmospheric pressure to operate.s with gas pressure on both sides of the diaphragm (2) A full lock-up regulator (3) A listed regulator incorporating with a listed a vent-limiting device. (4) A regulator incorporating a dual diaphragm, leak limiting system orificed for 2.5 ft3/h (based on natural gas) or less.


5.3.1.1 (1) . Some regulators manufacturers use more than one diaphragm for proper operation or for safety purposes, and this sentence does not specify which diaphragm the gas pressure must be applied to. The new language is to eliminate the overly broad language and clarify that it only applies to a diaphragm not using atmospheric pressure as a reference. 5.3.1.1 (3). Technically, there is no such thing as a “listed vent limiting device” for a gas regulator. A regulator may be listed, and the listing may also include the vent limiting device as complying with an applicable standard (e.g. ANSI Z21.18 and permits maximum 2.5 ft3/hr of gas leakage out the vent limiting device); the vent limiting device does not have its own listing. 5.3.1.1 (4). In addition, there is another technology that limits the escape of gas into the ambient space if the atmospheric ruptures. The technology has been used in the USA since the early 1990’s, and it uses a double diaphragm, leak limiting system located under the regulator dome. The extra diaphragm, so called a safety diaphragm, is only called upon to operate in the rare case that the atmospheric diaphragm fails. If that occurs, the ‘safety diaphragm’ forms perfectly to and seals to the upper dome of the regulator, forcing gas to escape out an internal vent limiting device to a leakage that is significantly less than 2.5 ft3/hr. Another safety feature of this design is that is can prevent significant, high gas conditions from occurring downstream, because the safety diaphragm can take over and prevent some high gas conditions if the atmospheric diaphragm fails. This leak limiting system has also been accepted by many authorities within the US and Canada (e.g. CSA B149.1 and the State Board of MA).





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5.3.4 When the inlet pressure of the regulator is higher than the maximum pressure rating of any of the main components downstream, an over protection device (OPD) shall be used. The OPD has to be rated to the maximum inlet pressure of the gas train and set lower than or equal to the maximum rating of the lowest rated downstream equipment.


An overpressure protection device is a needed safety device on the fuel train when the supply pressures exceed the ratings of the components on the fuel train.












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5.4.3.1* It shall be permissible to replace one of the ASSVs required by Section 5.2 with one of the following devices, provided no vent valve is required and the device will automatically shut off the flow of fuel within 1 second if the engine stops from any cause: (1) Carburetion valve (2) Zero governor–type regulating valve (3) Auxiliary valve


Replacing 1 ASSV with any one of these three devices creates issues related to safety when a vent valve is installed. The safety feature of a vent valve relies on the closure of a downstream safety valve. A downstream carburetion valve, zero governor–type regulating valve, or an auxiliary valve does not provide the same level of valve seal closure and reliability as a safety valve does.











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5.2.2.1 A vent valve, when installed to comply with 5.2.2 shall have a position indication switch and shall signal an alarm if the vent valve is not indicating closed during operation.


The added requirement for a position indicator switch for the vent valve is so that the failure of the vent valve is detected. The failure of a vent valve could introduce an explosion hazard if the failure remains undetected.









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5.2.2 For engines operating at more than a gauge pressure of 14 kPa (2 psi) inlet gas pressure to the equipment isolation valve, either a vent valve shall be provided between the two ASSVs or a listed valve proving system shall be installed to prove the two ASSV’s upon each startup or after each shutdown. This vent valve shall fail open without an externally supplied source of power and shall discharge outdoors.


Another technology to replace a vent valve is a valve proving system (VPS). The VPS has been used in the USA on gas fired equipment since the early 1990’s on many gas fired industrial applications, automotive applications, and larger boilers, and the VPS is referenced in other codes and standards such as NFPA 85, NFPA 86, and CSA B149.3. A VPS essentially performs a valve seat integrity test on each ASSV rather. As a result, there is no risk of venting gas into the atmosphere if the upstream ASSV either fails to close or leaks, and the integrity of both ASSV’s are checked during each valve proving sequence. Proposal also clarifies the correct pressure reference for the vent valve requirement.










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(b) Section/Paragraph A5.1.1



A5.1.1 Reference CSA B149.6 for the proper handling and generation of biogases.


CSA B149.6 Code for digester gas and landfill gas installations is a good reference standard for those parts of the gas piping for the handling and generation of biogases that are then ultimately used for the utilization of the gas in a stationary engine.









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From: Bob BenedettiTo: [email protected]: NFPA Technical Question Response [ ref:_00D5077Vx._50050F3Jd5:ref ]Date: Friday, February 24, 2012 9:30:42 AM

Good Morning, Mr. Schirra: Paragraph 8.2.3.1 of NFPA 37, Standard for the Installation and Use ofStationary Combustion Engines and Gas Turbines, states: “Exhaust systemsshall terminate outside the structure at a point where hot gases, sparks, orproducts of combustion will discharge to a safe location.” In my opinion, the weather enclosure constitutes a structure, even though itcannot be entered by personnel. Therefore, it is my opinion that the exhaustpipe or stack must terminate outside the enclosure. Frankly, I would think terminating the exhaust system of the engine within theenclosure would, over time, prove harmful to the installation. Please understand that this response is a personal opinion and does notconstitute a Formal Interpretation of the NFPA, as noted below and asdescribed in Section 6 of NFPA’s Regulations Governing Committee Projects. It is not to be relied upon to definitively determine compliance with any laws,ordinances, rules, or regulations. To determine legal compliance, you shouldrefer to the appropriate authority having jurisdiction or seek legal advice. It isnot intended, nor should it be relied upon, to provide professional consultationor services. To determine the adequacy or safety of any device or installation,you should consult with an appropriate professional. I hope this response is helpful. I hope this response is helpful. If you have afollow-up question related to this inquiry, please reply to this email. If youhave another question on a separate topic or a different document, pleasereturn to the document information pages and submit your new question(s) byclicking on the “Technical Questions” tab. R. P. Benedetti cc 37/IFI INT/NM-------------------------------------------------------------------------------------------------------------------------Robert P. Benedetti, CSP, PEPrincipal Flammable Liquids EngineerNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169-7471617-984-7433617-984-7110 (FAX)617-571-8494 (CELL)

mailto:[email protected]


bbenedetti@nfpa.org---------------------------------------------------------------------------------------------------Create Date: 2/16/2012Contact: JOHN SCHIRRA

Subject: Emergency Venting for a Outdoor Diesel Generator with SubbaseTank

Question for NFPA: For a diesel generator with a 660 gallon subbase(under generator) tank, can the emergency vent be allowed to vent withinthe weather enclosure of the generator or does the vent need to beextended to the outside of the weather enclosure? Note that the weatherenclosure cannot be entered and as such does not meet the defintion ofstorage tank building of 3.3.6.2, and the weather enclosure cannot containliquid since the primary tank has a secondary containment which is alsovented as required.


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From: Robert Benazzi [mailto:[email protected]] Sent: Friday, October 07, 2011 1:23 PM To: Benedetti, Bob Subject: RE: Inquiry: NFPA 37, 4.1.2.2 File: INT/NM Bob Thanks for getting back to me. Further to our discussion of yesterday, I am attaching a copy of the Solar Turbine cut sheet describing the standards to which the turbine skid and enclosure are designed, built and tested for your information. As I said, the skid for this particular project is built to the same requirements as the Code would mandate for engine rooms. Let me know if you have any questions. Robert V. Benazzi, PE Partner Emeritus

80 Pine Street - 12th Floor New York, NY 10005 T 212-530-9303 F 212-269-5894 www.jbb.com

----------------------------------------------------------------------------------------------------------------------- From: Benedetti, Bob [mailto:[email protected]] Sent: Tuesday, October 04, 2011 3:17 PM To: Robert Benazzi Cc: Mucci, Patti; Sances, Carol Subject: Inquiry: NFPA 37, 4.1.2.2 File: INT/NM Good afternoon, Mr. Benazzi: My apologies for the delay in getting back to you; I’ve been involved in a special project that has taken much of my time. After reviewing Section 4.1.2.2 of NFPA 37, Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines, and after searching some archive editions of the standard, my opinion is that these “dedicated detached structures” are meant to be be separated from any other building and not located within a building. I base this opinion on the following: Paragraph 4.1.2.2.2 specifies how far such an enclosure must be from structures that have combustible walls and from openings in walls. Presumably, this is to prevent a fire involving the enclosure from exposing the outside walls and interior of an adjacent building. The annex statement to 4.1.2.2.1 reads: “For information regarding noncombustible and fire resistive building construction, refer to NFPA 220, Standard on Types of Building Construction. The question of whether a factory-built generator enclosure is treated as a building, with respect to additional separation and protection requirements, depends on local zoning and building code requirements.” The inference is that these structures, although not intended to be considered buildings within the context of NFPA 37, could be and sometimes are so considered by the authority having jurisdiction. In fact, that is why the second sentence was added to A.4.1.2.2.1. But, there is no mention of these enclosures being used as a substitute for a room within a building. I must also point out that Section 4.1.2.2 does not specifically prohibit such enclosures from being used within a building. However, they would have to comply with all of the requirements of Subsection 4.1.2.1 for engine rooms. If these enclosures are being accepted as a substitute for a room, then they are being accepted on a case-by-case basis and after a determination of equivalency by the authority having jurisdiction. This issue will be added to the next agenda for the Technical Committee on Internal Combustion Engines.

bbenedetti

Text Box

ATTACHMENT No. A14

Please understand that this response is a personal opinion and does not constitute a Formal Interpretation of the NFPA, as noted below and as described in Section 6 of NFPA’s Regulations Governing Committee Projects. It is not to be relied upon to definitively determine compliance with any laws, ordinances, rules, or regulations. To determine legal compliance, you should refer to the appropriate authority having jurisdiction or seek legal advice. It is not intended, nor should it be relied upon, to provide professional consultation or services. To determine the adequacy or safety of any device or installation, you should consult with an appropriate professional. I hope this response is helpful. If you have any other questions, please call or write. I will be happy to assist. R. P. Benedetti cc 37/IFI INT/NM ************************************************************* From: Robert Benazzi [mailto:[email protected]] Sent: Wednesday, September 07, 2011 3:01 PM To: Benedetti, Bob Subject: Gas turbine enclosures Bob: Per our telephone conversation, I understand that Solar turbines can be installed within buildings in non combustible enclosures provided with automatic fire protection systems. I am assuming that this is in accordance with 4.1.2.2.2 of NFPA 37. Am I correct that if this paragraph is followed that engines located in “dedicated detached structures” which are non combustible and are provided with automatic fire protection systems can be located within buildings? I would appreciate you contacting other members of the committee to find the intent of the language. As I mentioned to you we are being told these installations are being accepted around the nation with the turbines located within their enclosure and the enclosure located within a building mechanical equipment room with no other separating walls. Thanks so much for your help and your time. Bob

Robert V. Benazzi, PE Partner Emeritus

80 Pine Street - 12th Floor New York, NY 10005 T 212-530-9303 F 212-269-5894 www.jbb.com

See JB&B’s Confidentiality Policy

NYU Langone Medical Center

Taurus 70 Generator Set

Inquiry No. NY08-02069 June 27,2011 9

GAS TURBINE PACKAGE: CODES, STANDARDS, and CERTIFICATIONS The gas turbine generator set package systems are designed in accordance with, and are tested to the applicable requirements for the following industry codes and standards: AGMA 2001-C95: Fundamental Rating Factors and Calculation Methods for Involute Spur and

Helical Gear Teeth AGMA 6001-C88: Design and Selection of Components for Enclosed Gear Drives AGMA 6011-G92: Specification for High Speed Helical Gear Units AGMA 6025-C90: Sound for Enclosed Helical, Herringbone and Spiral Bevel Gear Drives ANSI Z223.1: National Fuel Gas Code ASME B31.3: Process Piping

Applicability: • All piping with a diameter of up to 4” NPS are made of stainless steel. Package piping is

designed and fabricated to ANSI B31.3. • Piping with a nominal diameter of greater than 4 inches NPS may be carbon steel. • All tubing is stainless steel; tube fittings are stainless steel with Swagelok compression

fittings. ASME Code Section VIII: Pressure Vessel Design AWS D1.1: Structural Welding Code – Steel

Applicability: • Structural Welding

Factory Mutual (FM) Applicability:

• Fuel safety shutoff system. IEEE 115: Guide for Test Procedures for Synchronous Machines

Applicability: • Required by suppliers of generators to Solar for integration with the gas turbine generator

set package. NEMA MG1: Motors and Generators

Applicability: • Generator construction • Generator ratings

NFPA 12: Standard on Carbon Dioxide Extinguishing Systems Applicability:

• Fire suppression system NFPA 37: Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines NFPA 68: Guide for Venting of Deflagrations NFPA 70: U.S. National Electrical Code (NEC)

Applicability: • Electrical equipment contained within the gas turbine generator set package. • Area classification:

The onskid electrical equipment is designed for installation in a Class I, Div 2, Group D hazardous location.

NFPA 72: National Fire Alarm and Signaling Code Office of Technical Certification and Research (OTCR): New York only

Formerly MEA OSHA: Occupational Safety and Health Administration

Scope Clarification: The Buyer is responsible for working with the local authority to establish the proper area classification and for notifying Solar of the classification.

NYU Langone Medical Center

Taurus 70 Generator Set

Inquiry No. NY08-02069 June 27,2011 40

GENERATOR SET PACKAGE ENCLOSURE Basic Construction. An all-steel enclosure is provided for the turbine “driver” area only. The enclosure is self-contained, weatherproof, insulated, sound-attenuated, and assembled on the turbine package skid base. The enclosure is constructed with a solid roof, and doors that open to provide access and clearance for engine and gearbox removal. Enclosure doors are placed in key locations for access of major components requiring inspection and maintenance, and removal by forklift or overhead crane. Internal maintenance trolley rails are located above the turbine and the gearbox. The enclosure walls and roof are treated with fiberglass material for noise attenuation and thermal insulation. The enclosure is constructed to support a roof load of 50 pounds per square foot and to withstand a wind load of 120 miles per hour. The package control panel is installed in the exterior wall of the enclosure. Sound Attenuation. The sound-attenuated enclosure is intended for use with suitable turbine air inlet and exhaust silencing systems in environments where lower noise levels are required. Ventilation openings are equipped with suitable silencers for additional sound attenuation. For additional sound data, reference the "Noise Prediction, Guidelines for Industrial Gas Turbines” (Solar publication SPNP/898/4M). Exterior Connections. Connections for the oil tank vent line, ventilation fan wiring, fire suppression systems, and the turbine air inlet and exhaust are terminated outside of the enclosure.

Enclosure Lights. Incandescent lights are provided inside the enclosure with an on/off switch located near the enclosure door. Ventilation System. Enclosure ventilation is achieved by AC motor driven fans. The fans supply the airflow required to provide cooling and ensures that the air temperature inside the enclosure remains within acceptable limits. Suitable openings are provided so that an adequate, free flow of ventilation air is available through the enclosure. Standard elbow type enclosure inlet and exhaust ventilation is included as part of the enclosure scope. Dust Protection System. The enclosure inlet vent is equipped with filter units consisting of disposable, barrier type panel filters to remove dust and sand. The exhaust vent also contains back draft dampers to prevent dust ingress when unit is not running. Barrier-Type Filter. The enclosure ventilation inlet is equipped with a single-stage, disposable, barrier-type filter unit equipped with a delta-P alarm switch. The ventilation exhaust opening is equipped with back-draft dampers to prevent ingress of dust when the unit is not running. Door Open Alarm. The enclosure doors are equipped with door position switches to initiate an alarm whenever any of the enclosure doors are not securely closed.

Scope Clarification: Connections for oil tank vent line, ventilation fan wiring, CO2 fire suppression systems, and turbine air inlet and exhaust are terminated outside of the enclosure. All electrical wiring and mechanical piping external to the generator set package to these connections must be supplied by the Customer..

KSantella

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