National Fire Protection Association

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1 National Fire Protection Association 1 Batterymarch Park, Quincy, MA Phone: Fax: M E M O R A N D U M TO: FROM: NFPA Technical Committee on Liquefied Petroleum Gas Kimberly Shea DATE: February 8, 2012 SUBJECT: NFPA 58 ROP TC FINAL Ballot Results (A2013) The Final Results of the NFPA 58 ROP Letter Ballot are as follows: 30 Members Eligible to Vote 2 (S. Kastanas, D. Meyer) 14 Affirmative on All 14 s (D. Barber, R. Fredenburg, G. Hess, J. King, G. Mahnken, B. Mahre, S. McTier, S. McTier, G. Misel, J. Osterhaus, B. Swiecicki, T. Wilson, L. Woodward, W. Young) (on one or more proposals as noted in the attached report) 0 Abstentions (include names, if any) (on one or more proposals as noted in the attached report) There are two criteria necessary for each proposal to pass ballot: (1) simple majority and (2) affirmative 2/3 vote. The mock examples below show how the calculations are determined. (1) Simple Majority: Assuming there are 20 vote eligible committee members, 11 affirmative votes are required to pass ballot. (20 members eligible to vote 2 = = 11) (2) Affirmative 2/3: Assuming there are 20 vote eligible committee members, 1 ballot not returned and 2 abstentions, the number of affirmative votes required would be 12. (20 members eligible to vote 1 not returned 2 abstentions = 17 x 0.66 = = 12) Reasons for negative votes, etc. from alternate members are not included unless the ballot from the principal member was not received. According to the final ballot results, all ballot items received the necessary 2 / 3 required affirmative votes to pass ballot. ROP TC Final Ballot Results Cover Memo December 14, 2010

2 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 Entire Document (Log # CP10 ) 58-2 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (3) (Log # 67 ) 58-3 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (4) (Log # 68 ) 58-4 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 145 ) 58-5 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 32 ) 58-6 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 33 )

3 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : Various Definitions (Log # 40 ) 58-8 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : Bulk Plant (Log # 6 ) 58-9 Eligible To Vote:30 Affirmative: 25 : 3 Abstain: 0 : Bulk Plant (Log # 164 ) Fredenburg, R. There are many farms with industrial plants that are not open to the public but that are accessible by the public. As many of these farms have dispensers for fork lift cylinder filling and some have facilities for loading bobtails, security for the liquid product control system is needed. King, J. There are farms with large propane containers that are not open to the public but are located where they are accessible to the public. Fencing may be needed at some of these facilities to help control a potential for tampering that could result in a release of product. The Code should not prohibit requiring operators of such facilities to install security fencing where it is clearly in the interest of public safety. Mahnken, G. I disagree with the revision to LPG bulk plants at farms "not open to the public" are still susceptible to tampering and should be secured Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : Commercial Bulk Plant (New) (Log # 7 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : Industrial Bulk Plant (New) (Log # 8 )

4 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : Agricultural Bulk Plant (New) (Log # 9 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : Concrete Pad (New) (Log # 146 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : Direct Gas-Fired Tank Heater, and Tank Heater (Indirect and Direct Types) (New) (Log # 61 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : Lead Charge (New), Pressure Test (New) (Log # CP26 ) McTier, S. Change title to "Leak Check" instead of "Lead Charge." Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : Liquefied Petroleum Gas (LP-Gas) and A (New) (Log # 133 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : Low Emission Transfer and A (Log # 39 )

5 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : Second Stage Regulator (Log # CP28 ) McTier, S In the second line insert "inlet" between "appliance" and "pressure" Eligible To Vote:30 Affirmative: 25 : 3 Abstain: 0 : Positive Shutoff Valve (Log # CP1 ) Misel, Jr., G. The definition is vague and does not appear to truly identify what a positive shutoff valve is. Aren't all valves supposed to prevent flow of product when closed? Swiecicki, B. The definition is vague and does not appear to truly identify what a positive shutoff valve is. Aren't all valves supposed to prevent flow of product when closed? Woodward, L. This definition is vague as all valves prevent product flow when they are closed. McTier, S Add "and have a resilient seat disc that can be tightened to avoid incipient small leakage Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : Positive Shutoff Valve (Log # 134 ) Eligible To Vote:30 Affirmative: 25 : 3 Abstain: 0 : Vehicular Barrier Protection (VBP) and A (New) (Log # 49 ) Hess, G. This definition and supporting appendix is too vague. At the minimum it needs to include some language about "good engineering practice". I have seen several incidences where the protect provided could be interpreted to meet the proposed language but in reality was grossly inadequate. King, J. See my comment on

6 5 Wilson, T. In the list that is given in A3.3.77, Too many variables are in the list of accepted item. Parking curbs do not stop vehicles. They create a ramps that cars hat propel cars that then go up into structures or if L.P. tanks or of the L.P. Cabinet storage type could go into them. Fences. What type of fences,plastic, wood, chain link? What type of structural material in a fence will resist the impact of a vehicle.? Ditches, What constitutes a ditch 6" 12', 3' indention in the earth? I am voting no due to many open varibles in the proposed statement Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 69 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 14 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 5 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 70 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 71 ) Eligible To Vote:30 Affirmative: 26 : 2 Abstain: 0 : and A.4.7 (New) (Log # 152 )

7 6 Fredenburg, R. The committee's statement that it is the AHJ responsibility to inspect is made in a vacuum in places where the AHJ does not inspect. Sites in these areas get a free ride when no independent inspection is made. Hess, G. I agree with the proposer that a periodic, systematic inspection/audit should be preformed. This is more than just the responsibility of the AHJ. Some propane facilities presently are required under EPA regulations to preform these, and it is apparent it is having a positive outcome. Facilities are more closely keeping current with code changes like this one. The logic that if the AHJ does not find an issue so it is OK is not good policy. King, J. I am not convinced at this time that third party inspections of bulk plants are necessary to assure safety. Personal experience does, however, confirm preventative maintenance practices at some facilities could definitely stand improvement. In reviewing Chapter 14, I do not see an explicit requirement that bulk plant operators periodically perform documented self-audits to identify equipment in need of repair or replacement and to verify all emergency shut-down controls are working properly. This would be desirable because it would be a cost-effective means of helping to reduce the potential for unanticipated, uncontrolled releases of product during liquid transfer operations. The Committee should also keep in mind that preventing this type of release is (or should be) an especially high priority given that transport unloading at many bulk plants is performed using the pump on the cargo tank trailer, which necessitates having the engine on the truck-tractor running. If an uncontrolled release of liquid occurs under such circumstances the potential for ignition of the resulting vapor cloud appears to be substantially increased Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : , 6.6.6, A.6.6.6, and (Log # 1 ) Hess, G. This is a long time coming necessary good step. It however ignores those systems that are presently in the ground, many of which were not designed to be protected and will fail at some point in the future if some preventative maintenance or inspection is not done to determine if it is safe for continued service. The committee needs to address this issue as well in this cycle.. King, J. The Committee needs to also address the issue of existing underground tank installations, preferably in this cycle. I recognize this would entail considerable effort for some marketers, but it is justifiable given the nature of the hazard. The committee allowed ten years for the phase-in of the internal valve requirement. This might be a reasonable time to allow for inspecting existing installations provided the highest priority is given to evaluating the oldest containers. McTier, S (K)(1) In the first line change "climactic" to "climatic" (K)(2) Insert "testing shall be performed in" after "system," (K)(4) Change "climactic" to "climatic" Delete this paragraph and refer to Log # Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 72 )

8 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 Table (Log # 17 ) Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : (Log # 153 ) Young, W. I believe that there are numerous applications of containers on vehicles where the volume is great enough that normal anticipated temperatures will not cause excessive pressures. When such vessels are located in free air, they are safe, and need not have a higher work pressure Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # CP2 ) McTier, S In the second line change "occupancies" to "plants." Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 65 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : , , and (Log # 4 ) McTier, S Change " " to "(A)" and change " " to "(A)". Our present style in NFPA 58 is to use use parenthetical capital letters for subparagraphs.

9 Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : (Log # 154 ) Fredenburg, R. I agree that this not all-inclusive table is valuable, but should not be code. It should be annex material Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 12 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and (Log # 135 ) Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : (Log # 55 ) McTier, S. We plan to use Log #CP13 as the final version of Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : (Log # 56 ) McTier, S. We plan to use Log #CP13 as the final version of Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : (Log # 155 )

10 9 McTier, S. We plan to use Log #CP13 as the final version of Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # CP13 ) McTier, S. This is the recommended final version of with the following corrections: (C) In the first line change "2001" to "1001" and change "7.6 m3" to "3.8 m3" and change "bulk plant and industrial plant service" to "vehicle fuel dispenser and dispensing station service". 5,7,4,1(D)(11) In the second line after "shall", insert "require full internal pressure relief valves and shall have the springs and guiding mechanisms on the container pressure side of the seats so that the springs and guiding mechanisms shall not be exposed to the atmosphere." (D)(12)(1) In the first line insert "full internal" in front of "pressure relief valve". In the second line insert "full internal" in front of "pressure relief valve" and change " (J)" to " (D)(11)" as (D)(11) describes a full internal pressure relief valve (D)(12)(2) In the first line insert "full internal" in front of "pressure relief valve" Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 Table (Log # 57 ) Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : 2 Table (Log # 136 ) McTier, S. The full internal pressure relief valve is now defined in (D)(11). Change (J) in cell D3 to (D)(11) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 156 )

11 Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : 2 Table (Log # 73 ) McTier, S. Change the title of Table as follows: "Table Connection and Appurtenance Requirements for New and Existing Container Installations and Bulk Plants, Industrial Plants, Vehicle Fuel Dispensers, and Dispensing Stations". Change the title in the first line of the second vertical column from "2001 through 4000 gal W.C." to "1001 through 4000 gal W.C." In the second line change "(7.6 m3 through 15.1 m3) to "(3.8 m3 to 15.1 m3)". Change the "Options" in the first four categories in the second vertical column as follows: "Vapor inlet Option A or Option B" "Vapor outlet Option B" "Liquid inlet Option A or Option B" "Liquid outlet Option E or Option F (See ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and (Log # 58 ) McTier, S. Delete as it should duplicate new (C) and would be redundant Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and (Log # 16 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (B) (Log # 74 )

12 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 75 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # CP3 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # CP4 ) Eligible To Vote:30 Affirmative: 24 : 4 Abstain: 0 : and (H) (Log # 44 ) McTier, S. Various flexible or solid regulator relief valve vents are available to protect against higher water levels if needed. Misel, Jr., G. The committee did not address the reasons for rejecting the other aspects of the proposal. In addition, there does not appear to be a code requirement that the top of the dome must be installed at the same elevation as the ground level. Swiecicki, B. The committee did not address the reasons for rejecting the other aspects of the proposal. In addition, there does not appear to be a code requirement that the top of the dome must be installed at the same elevation as the ground level. Woodward, L. Other changes in the proposal were improvements to the existing code, but there is no comment in the substantiation as to why the committee objected to them Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : , (Log # CP5 )

13 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # CP29 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 34 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (4) (New) (Log # 60 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # CP17 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # CP18 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (c) (New) (Log # 137 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : , , , Table , and (Log # 76 )

14 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 77 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 13 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 78 ) Eligible To Vote:30 Affirmative: 26 : 2 Abstain: 0 : (4) (New) (Log # 24 ) Fredenburg, R. Remote shutoff and automatic shutoff are not the same. North Carolina has had a requirement for years that a pullaway automatically shuts off ESVs and bulkheads are designed to accomplish this before the hose breaks. Mahnken, G. I agree with the submitter's substantiation. Committee substantiation does not address the concern. Osterhaus, J. Installing an ESV at a bulkhead so that it will be immediately activated in the event of a pull away is not a difficult or costly safety enhancement. I agree with the submitter. However, it may be more appropriate to place the requirement in section 6.12 as it is more applicable to the installation than the design of the ESV Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 79 )

15 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 Table (Log # 138 ) Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : (Log # 157 ) Fredenburg, R. The text is harder to understand and there is no reason to repeat what is in the table. Also, this adds the extra burden of having to make sure that, if one is revised, the other receives the same revision Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : , , , and (New) (Log # 139 ) McTier, S Bypass Valves Insert after title and insert first paragraph text after Replace new paragraph number with This allows the subsection title to stand alone and allows for at least two paragraphs as required by the NFPA Manual of Style Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 63 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and (Log # 80 )

16 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : , , and (New) (Log # 140 ) McTier, S. Insert after title and insert first paragraph text after Replace with and replace with This meets the NFPA Manual of Style Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : through (Log # 81 ) Eligible To Vote:30 Affirmative: 25 : 3 Abstain: 0 : (New) (Log # 22 ) Fredenburg, R. The committee action does not accomplish the intent of the proposal, so accepting in principle is not correct. Proponent wanted no relief valve discharge under buildings. The committee action does not accomplish that. King, J. ASME containers should not be installed beneath buildings regardless of their capacity given the lower set-to-discharge pressure of the relief device (i.e., 250 psig for most ASME containers in service) compared to that of relief devices on DOT cylinders (i.e., 375 psig). Under fire conditions the lower set-to-discharge pressure could significantly increase the difficulty of bringing a fire under control once gas begins to discharge, or make it impossible to control a fire involving the structure. Mahnken, G. I disagree with allowing ASME LPG containers to be located under buildings. I agree with ballot statement by J. King Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 20 ) Eligible To Vote:30 Affirmative: 26 : 2 Abstain: 0 : (Log # 21 )

17 16 Fredenburg, R. By removing this subsection, a large container may be placed under an overhang. If the relief valve opens and is ignited, the torch will easily ignite the structure. Also, we have bulk tanks that are acceptably located at warehouse locations with large overhangs with this provision. If it is removed, we will have to make special documentation to allow these containers to stay. Mahnken, G. Current limitations on over-hangs in are better than none Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 82 ) Eligible To Vote:30 Affirmative: 23 : 5 Abstain: 0 : And A (New) (Log # 46 ) Fredenburg, R. "Stored" is an intentional act. What about piled combustible material that was not intentionally placed near a container? I can appreciate moving the rest of the text to the annex. Hess, G. The last sentence of the appendix language needs modification and should include "live". Dead vegetation like brush, trees at neglected locations can be an issue. This also conflicts with OSHA that specifically states " readily ignitable material including weeds and long grass, shall be removed within 10 feet of containers". King, J. Fires involving weeds and/or long dry grass can damage hoses at installations such as bulk plants or cylinder fills where liquid is transferred, and increase the potential for failure in service. Fires involving weeds and/or long dry grass may also spread and ignite other combustible materials and/or structures. Mr. Mahnken makes a very good point with regard to storage of easily-ignited material such as idle pallets, which are quite susceptible to ignition by material such as tall dry grass or weeds. The change would also create, as Mr. Hess has indicated, a conflict with 29 CFR (b)(6)(vi). Mahnken, G. The 10 ft separation may not be sufficient for LPG containers exposed to fire involving some combustible materials, say idle pallet storage. There is no one-size-fits-all safe separation distance. The appropriate separation distance should be determined in the fire safety analysis. Wilson, T. Weeds and grass need to be kept cut. We have a lot of grass fires and keeping the grass cut keeps down the tanks to fire exposure Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : through , , and (Log # 19 )

18 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and Table (Log # CP9 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 83 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 Table 6.5.3, Note b (Log # 41 ) Eligible To Vote:30 Affirmative: 26 : 2 Abstain: 0 : , (B), and (C) (Log # 50 ) King, J. The current provision in the Code addressing protection of containers has been in place for many years, and has generally worked well. The proposed change adds unnecessary complexity. It also does not address whether protection is necessary for propane containers installed within 10 feet of thoroughfares on farms and other types of remote sites that are used by tractors or other farm implements, construction machinery, or other mobile equipment, and the roadway or path of travel or operating area is not a "public thoroughfare." (By the way, what is a "public thoroughfare?" No definition is provided.) Also, Table in the Code provides guidance on "Separation Distances Between Containers, Important Buildings, and Line of Adjoining Property That Can Be Built Upon." With regard to "Line of Adjoining Property That Can Be Built Upon" Formal Interpretation LPG-5 as reproduced in the 2004 edition of the LP-Gas Code Handbook, which is still valid, it appears it would be possible to install a very large propane container, or multiple containers without providing any protection eleven feet from a public thoroughfare (in situations where the nearest property line that can be built upon is on the other side of the highway or street). This, needless to say, while "legal" if this proposal is adopted, might not be a safe condition. The action of the Committee should be reversed. Mahnken, G. As has been revised, Vehicle Barrier Protection would no longer be required for LPG containers exposed "only" to on-site traffic. The impact hazard is not limited to public vehicular thoroughfares Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 84 )

19 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (G) (Log # 15 ) Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : (H) (New) (Log # 147 ) Fredenburg, R. The committee statement that this is already addressed is incorrect. The example tank was on concrete blocks, but weathering caused the soil under the blocks to erode. The blocks were no longer on a firm foundation, as is required for cylinders. There is no requirement for tanks to be on a firm foundation Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and (Log # 85 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (B) and (C) (New) (Log # 148 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 42 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (A) (Log # CP15 )

20 19 Misel, Jr., G. It is essential that the committee be provided with reports on the full details of the incidents that are alleged in this proposal before any changes to the code are made. Swiecicki, B. It is essential that the committee be provided with reports on the full details of the incidents that are alleged in this proposal before any changes to the code are made Eligible To Vote:30 Affirmative: 25 : 3 Abstain: 0 : (L), , A (L), and A (New) (Log # 64 ) McTier, S. Add the following text to A : "Not all ANSI/UL 569 connectors are electrically isolating; therefore, a manufacturer must identify that their flexible hose connection provides electrical isolation for cathodic protection and is approved for underground service. Misel, Jr., G. The committee indicates that the reason for rejection is due to their belief that flexible hose connectors have not been used in underground container application, but it fails to recognize that the reason for that is because of the prohibition on using them in this application until now. With the requirement for underground containers to be protected by cathodic protection systems, there is now a need to provide electrical isolation for the container from the piping system. There appears to be no substantive technical reason for not allowing a product that complies with a product standard and is recommended by the manufacturer for that application. Swiecicki, B. The committee indicates that the reason for rejection is due to their belief that flexible hose connectors have not been used in underground container application, but it fails to recognize that the reason for that is because of the prohibition on using them in this application until now. With the requirement for underground containers to be protected by cathodic protection systems, there is now a need to provide electrical isolation for the container from the piping system. There appears to be no substantive technical reason for not allowing a product that complies with a product standard and is recommended by the manufacturer for that application Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and (Log # 86 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 87 ) Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : 2 6.7, , , and (Log # 88 )

21 20 Hess, G. The 7 foot requirement for underground tanks conflicts with OSHA regulations that requires 10 feet in some cases Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 89 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : , , and through (Log # 66 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : through (Log # 132 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 90 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 91 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 92 )

22 Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : (5) (Log # 131 ) McTier, S. Since line pressure regulators are often used with CSST installations and line pressure regulators are not equipped with integral regulator relief valves, we originally limited these CSST vapor systems to a maximum 5 psig limit. We also developed the 2 psi regulator second stage regulator that is UL listed for this service. If the line pressure regulator fails we could potentially have a first stage regulator outlet pressure of 10 psig on our appliance controls that could be dangerous. Because of all of this, we re-designed all of our UL listed second stage regulators so that the outlet pressure would not go above two psig outlet pressure even if the regulator seat disc was removed to indicate serious failure. We did not want to see pressures above 2 psig to our appliance controls Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 30 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and (Log # 93 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 94 ) Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : , 6.15 (New), Annex M (New) (Log # CP27 )

23 22 Mahnken, G. I disagree with revision to allowing large piping systems to be pressure tested using LP-Gas. Not a reason for negative vote, but I would like to see the leak check also specifically required for vaporizer systems being restored after an interruption of service, including the supply side McTier, S. M.1.2(1) In the fourth and sixth lines delete "gauge reading." Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : (Log # 43 ) Hess, G. I disagree with the logic of the committee statement. This issue has been raised in the previous cycle and it appears we are just kicking the can down the road. If local building codes acknowledge the existence of a hazard that has a nexus to our code we should address. I recommend that this be accepted in principal. McTier, S. See affirmative comment on Proposal Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : (Log # 163 ) Hess, G. I disagree with the logic of the committee statement. If local building codes acknowledge the existence of a hazard that has a nexus to our code we should address. I recommend that this be accepted in principal. McTier, S. Suggest that we transfer present 6.15 covering installation in areas of heavy snowfall to 6.27 to avoid changing all of the numbering after adding 6.15 covering leak check for vapor systems. Both and will probably be rejected by the letter ballot Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 25 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 95 )

24 23 McTier, S Insert "Plant" after "Industrial". Delete the first line of the substantiation Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 26 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # CP8 ) Eligible To Vote:30 Affirmative: 24 : 4 Abstain: 0 : (3) (New) (Log # 23 ) King, J. The premise behind the substantiation is partially incorrect. Also, the committee statement indicating the proposal "would not affect existing facilities until the facility hose is replaced" could encourage some operators, in a misguided attempt to control expenses, to keep hoses in service longer than their condition indicates it is safe to do so. Misel, Jr., G. The proposal might result in a violation of the federal preemtion laws that restrict any state or jurisdiction from enacting laws that are not substantively the same as those in the Hazardous Materials Transportation requirements. Preemption requirements can be found in Title 49 of the Code of Federal Regulations, Part There are other concerns as well, including the fact that "passive shutoff device" is not defined in NFPA 58. Swiecicki, B. The proposal might result in a violation of the federal preemtion laws that restrict any state or jurisdiction from enacting laws that are not substantively the same as those in the Hazardous Materials Transportation requirements. Preemption requirements can be found in Title 49 of the Code of Federal Regulations, Part There are other concerns as well, including the fact that "passive shutoff device" is not defined in NFPA 58. Woodward, L. required. These requirements could violate federal pre-emption laws. Also a definition as to what a passive shutoff device is would be McTier, S. Rewrite (3) and A (3) as follows: A facility transfer hose at a bulk plant or industrial plant that is designed to connect with cargo tank vehicles greater than 3500 gal (18.2 m3) water capacity shall be equipped with a passive shutdown system that is designed to automatically shutdown the flow of an unintentional release of LP- Gas caused by the complete separation of the facility transfer hose within 20 seconds without the need of human intervention. A (3) The passive shutdown system shall be mechanical, pneumatic, electronic, or any combination thereof.

25 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (D) (New) (Log # 28 ) Mahre, B. This proposal will not affect the transfer of liquid through hose used for refilling bulk truck vehicles which are in metered service. The proposal is intended for new construction only, using a facility hose or when major modifications to the bulk plant or industrial plants occur Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 96 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # CP11 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 97 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 158 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : , , and (Log # 98 )

26 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # CP6 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and A (New) (Log # 62 ) Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : (Log # 31 ) Hess, G. Propane has the highest flammability rating under NFPA. Some industry groups have recognized the benefits of using non-sparking tools around potential flammable atmospheres. The committee statement sounds like we are ignoring a potential hazard. The proposal has some merit. King, J. Perhaps there is a need for research to determine if the conclusions in API Recommended Practice 2214, "Spark Ignition Properties of Hand Tools," also apply to typical activities of propane marketers. "This publication emphasizes that the use of nonferrous hand tools, sometimes referred to as nonsparking tools, is not warranted as a prevention measure in petroleum operations." Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : (Log # 159 ) Young, W. I believe that there are numerous applications of containers on vehicles where the volume is great enough that normal anticipated temperatures will not cause excessive pressures. When such tanks are located in free air, they are safe, and need not have a higher work pressure (c) is restrictive Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (New) (Log # 11 )

27 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 99 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 100 ) Fredenburg, R. Not having been involved in the discussion on this proposal, I am concerned that a dispenser under a simple shelter may not be allowed as the shelter does not comply with Chapter 10. A quick review of Chapter 10 does not relieve this concern. I welcome comments about this concern Eligible To Vote:30 Affirmative: 26 : 2 Abstain: 0 : and (New) (Log # 51 ) Fredenburg, R. The proposal fails to require steel pipe of sufficient wall thickness to provide protection for the concrete that fills it. A shaft of non-re-enforced concrete has little resistance to this type of impact. The proposal should require steel pipe of at least schedule 40 thickness. Thin-wall conduit would be allowed by this proposal. King, J. See my comment on My objection is not to protecting containers and dispensing equipment from collision damage from vehicles, which is already provided for by the Code, but to the "Vehicular Barrier Protection" methodology espoused by the submitter. Also, as written, this change would not be retroactive to existing installations, which would create an enforcement nightmare. McTier, S. This needs more review as the numbers are confusing. Osterhaus, J. Propane dispensers dispense liquid not vapor, so "liquid" doesn't seem necessary to describe dispensers. Propane is often dispensed at industrial and commercial installations in areas that are not accessible to the public. Dispensers at these facilities also require protection if they are subject to damage from vehicular traffic. Removing the word "public" before thoroughfare and parking location would be more inclusive and eliminate confusion and conflict as to the meaning of "public" Eligible To Vote:30 Affirmative: 19 : 9 Abstain: 0 : through (Log # 101 )

28 27 Barber, D. I vote negatively to eliminate conflict with action taken on Proposal Mahnken, G. I vote negative to avoid conflict with action taken on Proposal Mahre, B. To correct conflict with action taken on Proposal McTier, S. I vote negatively to avoid conflict with action taken on Proposal Misel, Jr., G. The action taken by the committee on Section would conflict with the previous action taken on Osterhaus, J. I vote negatively to avoid conflict with action taken on Proposal Swiecicki, B. I vote negatively to avoid conflict with action taken on Proposal Woodward, L. I vote negatively to avoid conflict with action taken on Proposal Young, W. Covered by Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 3 ) Fredenburg, R. Considering that some of the switches required by this section are difficult to access (inside and behind piled stock), should this be made retroactive? As it currently stands, these difficult to access switches would not have to be made accessible in existing installations. McTier, S. This needs more review as the numbers are confusing Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and (Log # 102 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 35 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # CP12 )

29 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and (Log # 103 ) McTier, S In the first line replace "occupancies" with "plants" In the first line replace "occupancy" with "plant" Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and (Log # 104 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 105 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (A) (Log # 10 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (9) (New) (Log # 149 )

30 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 Table (Log # 106 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 Chapter 8 (Log # 144 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # CP7 ) Eligible To Vote:30 Affirmative: 25 : 3 Abstain: 0 : and A (New) (Log # 52 ) Hess, G. The original wording gets the point across much better than the proposed language. The new wording appears to be vague and unenforceable. This appears to be supported by the appendix language that starts out with "Only minimal"... "may be needed". King, J. See my comment on The reference to "bollards" may also cause some confusion given its maritime connotation (i.e., a bollard is a post on a pier used to hold fast a ship's mooring line). Wilson, T. See my explanation of negative vote on Proposal Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 45 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and (Log # 18 ) 29

31 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and (Log # 107 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (New) (Log # 47 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and (Log # 108 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 109 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and (Log # 110 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 112 )

32 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and (Log # 111 ) Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : (Log # 160 ) Young, W. I believe that there are numerous applications of containers on vehicles where the volume is great enough that normal anticipated temperatures will not cause excessive pressures. When such vessels are located in free air, they are safe, and need not have a higher work pressure Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 141 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and (Log # 113 ) McTier, S In the first line replace "water-" with "water-resistant" Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : and (Log # 142 )

33 32 McTier, S. Delete new and replace with the following: (New) Cylinders in engine fuel service shall be equipped with full internal or flush-type full internal pressure relief valves In the first line insert "full internal pressure" in front of "relief valves", insert (D)(11) after "with", and delete " or as applicable" In the third line replace " (J)' with " (D)(11)" Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 114 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 161 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 115 ) McTier, S. Flexible hose connectors are presently found in or Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (J) (Log # 116 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 117 )

34 Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : (New) (Log # 143 ) McTier, S. Reject this change as it is not needed Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : , , , and (Log # 118 ) McTier, S Insert "full internal" in front of "pressure relief valve". Replace " (L)" with " (D)(11) This is also shown Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 119 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 29 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : , , and (Log # 120 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and (Log # 121 )

35 34 McTier, S. Replace "Electric Equipment" in "13.2.2". Remove text from subsection title and show it as Remove bold "Electrical Power" title and start paragraph with "Electric power-operated valves Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : (Log # 27 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : and A (New) (Log # 59 ) McTier, S * in the first line insert "plants" after "bulk" Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : , , A , and A (New) (Log # 53 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : , , and (Log # 122 ) Eligible To Vote:30 Affirmative: 24 : 4 Abstain: 0 : (New) (Log # 150 )

36 35 Fredenburg, R. Failure of the person who performs maintenance to be identified makes it impossible for an inspector to verify that person is qualified to perform that maintenance. We have evidence that maintenance checklists were performed in the office by non-qualified office staff. A proper paper trail must be made. King, J. Refer to the comment by Mr. Wilson. Mahnken, G. Identity of persons conducting inspections should be clearly indicated on reports for auditing purposes. Wilson, T. When I make a inspection I have to sign the inspection form. This is for keeping track of who does it and for legal issues Eligible To Vote:30 Affirmative: 25 : 3 Abstain: 0 : (New) (Log # 151 ) Fredenburg, R. Failure of the person who performs maintenance to be identified makes it impossible for an inspector to verify that person is qualified to perform that maintenance. We have evidence that maintenance checklists were performed in the office by non-qualified office staff. A proper paper trail must be made. King, J. Refer to the comment by Mr. Wilson. Wilson, T. When I make a inspection I have to sign the inspection form. This is for keeping track of who does it and for legal issues Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 A (Log # 123 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 A , A.5.9.5(D), A , A , A.6.4.6, A.6.4.7, A.6.5.1, A (4), and A (Log # 124 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 A (Log # 36 )

37 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 A and A (Log # 125 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 A (Log # CP20 ) McTier, S. Change the title of from "A.6.3.1" to "A " as shown in Also change paragraph "A.6.3.1" to "A " and in the first line change "Table 6.3.1" to "Table ". Four lines later change "tank" to "container" and change "Figure A.6.3.1" to "Figure A " Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 A (Log # CP21 ) McTier, S. "A.6.3.8" should be changed to "A " in the title and in the paragraph for the Annex. The new A should be added to the Annex Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 A.6.8.2(H) (Log # 126 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 A.6.8.2(H) (Log # CP14 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 A.6.15 (Log # 2 )

38 37 McTier, S. Change to A.6.27 as 6.15 will now be covering "Leak Check for Vapor Systems" Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 A (Log # CP23 ) Eligible To Vote:30 Affirmative: 27 : 1 Abstain: 0 : 2 A (Log # CP22 ) Hess, G. The proposed language is contrary to regulatory language and will only cause further confusion by the regulated community. For example in EPA's EPCRA regulations routinely use the word aggregate in guidance, court decisions and in the regulation. The Extremely Hazardous Substance inventory requirements under EPCRA 302 specifically include aggregate in 40 CFR and specifically indicates the total at a facility. The proposed wording would also be confusing as it relates to OSHA 29 CFR ( storage and handling of liquefied petroleum gas) when it refers to total water capacity. The proposed definition as being less than the minimum separation required between containers is outside the common meaning of the word. McTier, S. In the third line change "Table 6.3.1" to "Table ". In the fourth line change "Table 6.3.1" to "Table " Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 A (Log # CP24 ) McTier, S. Show an asterisk with Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 A (New) (Log # 48 )

39 Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 A (Log # CP25 ) McTier, S. Show an asterisk with Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 A (Log # 127 ) McTier, S. Show an asterisk for new Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 A (Log # CP19 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 Table D Note c (Log # 162 ) Eligible To Vote:30 Affirmative: 25 : 3 Abstain: 0 : 2 Figure I.1(a) (Log # 54 ) Misel, Jr., G. Swiecicki, B. The proposal is needed to clarify some of the installation requirements that are not currently depicted in the diagram. The proposal is needed to clarify some of the installation requirements that are not currently depicted in the diagram.

40 39 Woodward, L. The actual recommended changes to the diagram were useful. The committee just needs a professionally drawn illustration in order to view them clearly Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 Figure I.1(a) (Log # 128 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 Figure I.1(b) and Figure I.1(c) (Log # 129 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 K.3.1 (Log # 130 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 New Annex L (Log # CP16 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 L (Log # 37 ) Eligible To Vote:30 Affirmative: 28 : 0 Abstain: 0 : 2 L (Log # 38 )