nfpa technical committee on gas process safety (gps-aaa) … · 2019. 3. 19. · saudi aramco...

NFPA Technical Committee on Gas Process Safety (GPS-AAA) NFPA 56, Standard for Fire and Explosion Prevention during Cleaning and

Purging of Flammable Gas Piping Systems SECOND DRAFT MEETING AGENDA (F2019 cycle)

In Person Meeting with Web/Teleconference Option

Wednesday, April 10, 2019 from 8:00 AM to 5:00 PM (EDT) at

Sheraton Charlotte Airport Hotel 3315 Scott Futrell Drive, Charlotte, North Carolina 28208

Tel: 704-392-1200

Note: The hotel is located 1.5 miles from the airport (CLT) and provides complimentary 24-hour airport shuttle service. Estimated taxi fare is $25 USD.

To Join the Meeting Remotely: https://nfpa.adobeconnect.com/nfpa56-sdmeeting/

Teleconference Number: 1-855-747-8824

Participant Passcode: 377593

1. Call to Order. Call meeting to order by Chairman Franklin R. Switzer, Jr. at 8:00 a.m. Eastern Daylight Time on Wednesday, April 10, 2019.

2. Chairman’s Remarks. Franklin R. Switzer, Jr.

3. Self-Introduction of Committee Members and Guests, See page 3. Attachment A:

• Current Committee Roster – Technical Committee on Gas Process Safety.

4. Approval of F-2019 First Draft Meeting Minutes, See page 5. Review and approve the First Draft Meeting Minutes, held 31 May 2018. Attachment B:

• Meeting Minutes from NFPA 56 First Draft Meeting held on 05/31/18.

5. Staff Liaison discussion of Second Draft Meeting Procedures, See page 8. Attachment C:

• NFPA 56 Second Draft Meeting Power Point

NFPA Technical Committee on Gas Process Safety (GPS-AAA) - NFPA 56 SECOND DRAFT MEETING AGENDA

https://nfpa.adobeconnect.com/nfpa56-sdmeeting/

6. NFPA 56 Public Comments (23 Items), See page 22.

Chapter 1, Administration (9 Public Comments). Chapter 3, Definitions, (1 Public Comment). – See Attachment E for PC-24 Chapter 4, General Requirements, (1 Public Comment). Chapter 7, Purging into Service, (7 Public Comments). Chapter 8, Purging out of Service, (2 Public Comments). Annex A, Explanatory Material, (3 Public Comments). – Note: These are for Annex A notes for Chapter 1 material and should be considered by the Committee in conjunction with the Chapter 1 Public Comments. Attachment D:

• NFPA 56 Public Comments Attachment E:

• NFPA 56 F-19 PC-24 Definitions

7. NFPA 56 Committee Input (1 Item), See page 49. Committee Input 15 (CI-15), Revisions to Annex B and C – Note: there is no material in

the F-19 First Draft Record for changes to Annex C. Attachment F:

• NFPA 56 CI-15 Annex B Attachment G:

• NFPA 56 Annex B Edition 4 2.5 and 2.6 Text Rev.

8. Second Draft (SD) Balloting Information, See page 57. Attachment H:

• NFPA 56 SD Balloting Information Power Point 9. Other Business or Future Meetings. For this revision cycle (F-2019), if necessary, 24

April 2019 is being held to conclude any business for this revision of NFPA 56 by teleconference/web-meeting. Determination if this is necessary will be made before the conclusion of this April 10, 2019 Second Draft Meeting.

10. Adjournment. Anticipated adjournment is 5:00 PM or earlier if the Committee

concludes its business sooner on April 10, 2019.

NOTE: † A separate email will be sent with the Adobe Connect link and instructions & teleconference dial-in numbers for members who cannot participate in this meeting in person.

Address List No PhoneGas Process Safety GPS-AAA

Lawrence Russell03/19/2019

GPS-AAAFranklin R. Switzer, Jr.ChairS-afe, Inc.85 Denison Parkway E #201Corning, NY 14830-2726

SE 8/9/2011GPS-AAA

Hocine Ait MohamedPrincipalSaudi AramcoR-210, Floor 2, C Wing, Star Building (Bldg. 3150)Dhahran, 31311 Saudi Arabia

U 08/17/2015

GPS-AAADenise BeachPrincipalFM Global1151 Boston-Providence TurnpikePO Box 9102Norwood, MA 02062-9102

I 08/17/2015GPS-AAA

Michael W. BethanyPrincipalGas Piping Safety Services (GPSS)1088 Brookpoint DriveMedina, OH 44256

SE 12/07/2018

GPS-AAAChristopher S. BuehlerPrincipalExponent, Inc.420 Lexington Avenue, Suite 1740New York, NY 10170Alternate: Ali Reza

SE 3/1/2011GPS-AAA

Paul W. CabotPrincipalAmerican Gas Association400 North Capitol Street, NWWashington, DC 20001

IM 3/1/2011

GPS-AAAPat ConveryPrincipalCornerstone Energy Services172 Shrewsbury StreetWorcester, MA 01604

SE 10/29/2012GPS-AAA

Larry M. DannerPrincipalGE Power & Water300 Garlington Road GTTC Room 200DGreenville, SC 29615-0648Alternate: Gordon R. Smith

M 3/1/2011

GPS-AAALouis A. Donsbach, Jr.PrincipalUS Steel CorporationOne North Broadway, 91E2/TS 526Gary, IN 46402-3101

U 03/05/2012GPS-AAA

John P. DoucettePrincipalState of CT Department of Administrative ServicesOffice of State Fire Marshal 450 Columbus Boulevard, Suite 1304Hartford, CT 06103

E 03/03/2014

GPS-AAARob EarlyPrincipalCompressed Gas Association2540 Bowen RoadElma, NY 14059Alternate: Richard A. Craig

M 08/09/2012GPS-AAA

Bridget HamiltonPrincipalPraxairUSIG Operations175 East Park DriveTonawanda, NY 14072Alternate: Kristie R. Baron

M 04/11/2018

GPS-AAAChad KingPrincipalSENSIT Technologies851 Transport DriveValparaiso, IN 46383Alternate: Nicholas J. Boekeloo

M 12/07/2018GPS-AAA

Kreg J. LevengoodPrincipalKiewit Power Engineers9401 Renner BoulevardLenexa, KS 66219

SE 3/1/2011

1

Address List No PhoneGas Process Safety GPS-AAA

Lawrence Russell03/19/2019

GPS-AAARobert C. NaperPrincipalEnergy Experts International2 Anthony WayCanton, MA 02021-3559ANSI Gas Piping Technology Committee

SE 3/1/2011GPS-AAA

John R. PuskarPrincipalPrescient Technical Services LLC2078 Ridge RoadHinckley, OH 44233

SE 3/1/2011

GPS-AAAHossam ShalabiPrincipalCanadian Nuclear Safety Commission280 Slater StreetOttawa, ON K1P 5S9 Canada

E 08/17/2018GPS-AAA

Bruce J. SwiecickiPrincipalNational Propane Gas Association19530 Southfield LaneTinley Park, IL 60487

IM 3/1/2011

GPS-AAABrett A. WheelockPrincipalOGE/EnogexOne Leadership Square, Suite 950211 North RobinsonOklahoma City , OK 73105Alternate: Scott Neil

M 03/07/2013GPS-AAA

Peter J. WillsePrincipalAXA XL/Global Asset Protection Services, LLC100 Constitution Plaza, 12th FloorHartford, CT 06103

I 3/1/2011

GPS-AAASam PagadalaVoting AlternateAmerican International Group, Inc. (AIG)500 West Madison StreetChicago, IL 60661

I 10/29/2012GPS-AAA

Kristie R. BaronAlternatePraxair Inc175 East Park Drive, Building 60 / 225Tonawanda, NY 14150Principal: Bridget Hamilton

M 04/11/2018

GPS-AAANicholas J. BoekelooAlternateSENSIT Technologies851 Transport DriveValparaiso, IN 46383Principal: Chad King

M 12/07/2018GPS-AAA

Richard A. CraigAlternateCompressed Gas Association14501 George Carter Way, Suite 103Chantilly, VA 20151Compressed Gas AssociationPrincipal: Rob Early

M 10/18/2011

GPS-AAAScott NeilAlternateDCP Midstream LLC370 17th Street, Suite 2500Denver, CO 80202Principal: Brett A. Wheelock

M 07/29/2013GPS-AAA

Ali RezaAlternateExponent, Inc.5401 McConnell AvenueLos Angeles, CA 90066-7027Principal: Christopher S. Buehler

SE 8/9/2011

GPS-AAAGordon R. SmithAlternateGeneral Electric Company1 River RoadBuilding 40-271Schenectady, NY 12305-2551Principal: Larry M. Danner

M 08/17/2015GPS-AAA

Lawrence RussellStaff LiaisonNational Fire Protection AssociationOne Batterymarch ParkQuincy, MA 02169-7471

2

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© National Fire Protection Association. All rights reserved.

NFPA 56 Second Draft MeetingWednesday, April 10, 2019 from 8:00 AM to 5:00 PM (EDT)

Sheraton Charlotte Airport Hotel3315 Scott Futrell Drive, Charlotte, North Carolina 28208

Technical Committee on Gas Process Safety (GPS-AAA)

Second Draft Meeting Procedures Presentation

nfpa.org | © National Fire Protection Association. All rights reserved.

NFPA 56 Second Draft Meeting

• Members, please verify/update your contact information. (See the roster provided with your agenda.)

• Use of recording devices or other means capable of reproducing verbatim transcriptions of this or any NFPA meeting is not permitted

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• Guests All guests are required to sign in and identify their affiliations.

Any guests on the teleconference need to identify themselves. Participation is limited to TC members or those individuals who

have previously requested time to address the committee. Other participation is granted at the discretion of the Chair.

Guest chairs are located around the room as a courtesy.

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Members categorized in ANY interest category who have been retained to represent the interests of ANOTHER interest category (with respect to a specific issue or issues that are to be addressed by a TC/CC) shall declare those interests to the committee and refrain from voting on any Public Input, Comment, or other matter relating to those issues throughout the process.

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• General Procedures

Follow Robert’s Rules of Order.

Discussion requires a motion.

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NFPA 56 Second Draft Meeting• Motions for Ending Debate Previous Question or “Call

the Question” Not in order when another has the floor

Requires a second

This motion is not debatable and DOES NOT automatically stop debate

A 2/3 affirmative vote will immediately close debate and return to the original motion on the floor. Less then 2/3 will allow debate to continue.

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• Committee member actions:

Member addresses the chair.

Receives recognition from the chair.

Introduces the motion.

Another member seconds the motion.

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NFPA 56 Second Draft Meeting• Committee chair actions:

States the motion.

Calls for discussion.

Ensures all issues have been heard.

Calls for a vote.

Announces the result of the vote.

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NFPA F-2019 Revision Cycle - Second Draft

• Comment Stage (Second Draft): Public Comment Closing Date: COMPLETED Second Draft Meeting Period: Closes on 05/16/19 Posting of Second Draft & Balloting Date: 06/27/19 Second Draft Ballot-Return Deadline: 07/18/19 Posting of Second Draft Report: 08/01/19

• Tech Session Preparation: NITMAM Closing Date: 08/29/19 CAM & Consent Standard Notice: 10/10/19

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NFPA F-2019 Revision Cycle - Second Draft

• Tech Session Preparation (continued): Consent Standard Appeals Closing Date: 10/25/19 Consent Standard Issuance Date: : 11/04/19 NFPA Meeting Tech Session for Docs w/CAMs: 06/17/20

• Appeals & Issuance: Appeal Closing Date for Standards w/CAMs: 07/08/20 Issuance of Standards w/CAMs: 08/14/20

The Full F-2019 is provided on the Document Information page for NFPA 56

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• The Purpose of this meeting:Review & Act on Public Comments (23 PCs)

Address Committee Input (1 CI)

Address any Task Group Work (?)

Address Editorial Staff Comments (none as of 3/6/19)

Create Second Revisions

Note: All Committee Action requires a Committee Statement


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Action Options for the Committee at the Second Draft Meeting

• The following is taken from the Regulations Governing Committee Projects (§4.4.8.1).

• Action Options are:– Accept the Comment

– Reject the Comment but See Related 2nd Revision

– Reject the Comment

– Reject but Hold the Comment

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Accept the Comment• Action: The Technical

Committee takes this Action when it decides to accept the text proposed in the Public Comment exactly as it is submitted.

• Result: The Public Comment is marked as “Accept,” and the proposed text is incorporated into one or more Second Revisions.

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Reject the Comment, but See Related Second Revision.

• Action: The Technical Committee takes this Action when it agrees with the concept of the Public Comment in whole or in part but has developed related text in one or more Second Revisions that is different from the text in the Public Comment.

• Result: The Public Comment is marked as “Reject But See” and, a reference is provided to the related Second Revision(s).

Original comment is revised with additions and/or deletions.

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Reject the Comment. • Action: The Technical

Committee takes this Action when it disagrees with the proposed changes in the Public Comment.

• Result: The Public Comment is marked as “Reject,” and no Second Revision is developed. A Committee Statement about why the comment was rejected is required.

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Reject But Hold the Comment. • Action: The Technical Committee

takes this Action when it decides to reject the Public Comment, but hold it for processing as a Public Input for the next Revision Cycle in accordance with §4.4.8.3.

• Result: The Comment is marked as “Reject But Hold,” and no Second Revision is developed. A Committee Statement for this action is required.

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Criteria for Hold (§4.4.8.3.1)

• The Comment introduces a concept that has not had public review by being included in a related Input or First Revision as shown in the First Draft.

• The Comment changes the text from the First Draft to the point that the Technical Committee would have to restudy the text of the First Draft.

• The Comment proposes something that could not be properly handled within the timeframe for processing the Second Draft.

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Basis for Reject But Hold (§4.4.8.3.2)

• The Committee may consider any relevant factors including but not limited to:– the extent to which the Public Comment proposes a change that

is new or substantial,

– the complexity of the issues raised, and

– whether sufficient debate and public review has taken place.

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Committee Statements on Comments (§4.4.8.2)

• A Statement is required for all Actions on Comments.

• Statements supporting Committee Actions shall be technical in nature and shall be sufficiently detailed so as to convey the Committee’s rationale for its Action.

• Statements may consist, in whole or in part, of a cross-reference to Statements on other Comments and Second Revisions.

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• Creating a Second Revision (SR) Committee wants to make a change (to add, delete or modify) the

First Draft.

Committee develops a Committee Statement (CS) substantiating the change.

Each Second Revision gets balloted


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• No “new material” after the Public Input Stage since it hasn’t had the benefit of public review.

• What constitutes new material is decided by the TC or Correlating Committee.

• Adding “new material” at this Comment Stage could successfully be challenged through an appeal to the NFPA Standards Council.


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• Formal voting Voting during this meeting is used to establish a sense

of agreement (simple majority).

Secured by letter ballot (which needs 2/3 agreement).

Only the results of the formal ballot determine the official position of the committee on the Second Draft.

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Legal Stuff

Antitrust: the single most important provision- Federal law prohibits contracts, combinations, or conspiracies which unreasonably restrain trade or commerce. (Section 1 of the Sherman Act)

Patent: Disclosures of essential patent claims should be made by the patent holder, but others may also notify NFPA if they believe that a proposed or existing NFPA standard includes an essential patent claim.

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Legal Stuff

• Activities Disapproved by the Courts Packing meetings

Hiding commercial interest throwing the committees out of balance

No final decision-making authority to unbalanced Task Groups; include all interested parties.

Hiding scientific or technical information from committees

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Doc Info Page for NFPA 56

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https://www.nfpa.org/codes-and-standards/all-codes-and-standards/list-of-codes-and-standards/detail?code=56


Doc Info Pages

Document Information

• Document scope• Current/Previous

Edition information• Issued TIAs, FIs and

Errata• Archived revision

information• Standard Council

Decisions• Articles and Reports• Read only document

Next Edition

• Submit Public Input/Comments via Electronic Submission System.

• Meetings and Ballots• First Draft Report and

Second Draft Report• NITMAM and Standard

Council Decisions• Private TC info

• Ballot circulations, informational ballots and other committee info

Technical Committee

• Committee name, responsibility and scope

• Staff liaison• Committee list

• Private committee contact information

• Current committee documents in PDF format

• Committees seeking members and committee online application

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NFPA Second Draft Meeting

Any questions?

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Thank You!NFPA thanks you for all of your hard work and dedication to this project as Committee Members.

Public Comment No. 5-NFPA 56-2018 [ Section No. 1.1 ]

1.1 Scope.

1.1.1* Applicability.

This standard shall apply to fire and explosion prevention during cleaning and purging activities for newand existing flammable gas piping found in electric-generating plants and in industrial, institutional, andcommercial applications. It shall not apply to exploration and development well pads operations postcompletion to custody transfer, gas distribution facilities

1.1.1.1*

Coverage of fuel gas piping systems shall extend from the point of delivery or source valve to the gas-consuming equipment isolation valve.

1.1.1.1.1

For other than undiluted liquefied petroleum gas (LP-Gas) systems, the point of delivery shall be the outletof the service meter assembly or the outlet of the service regulator or service shutoff valve where no meteris provided. [54:1.1.1.1(A)]

1.1.1.1.2

For undiluted LP-Gas systems, the point of delivery shall be considered to be the outlet of the final pressureregulator, exclusive of line gas regulators where no meter is installed. Where a meter is installed, the pointof delivery shall be the outlet of the meter. [54:1.1.1.1(A)]

1.1.1.1.3

For facilities that produce flammable gas for consumption on site, the point of delivery or source valve shallbe the discharge isolation valve for the gas-producing equipment.

1.1.1.2*

Coverage of flammable gas piping systems other than fuel gas piping systems shall extend from the sourcevalve serving the gas supply system to the gas-consuming equipment isolation valve.

1.1.2 Nonapplication of Standard.

This standard shall not apply to the following items:

(1)

(2)

(3) Fuel-dispensing facilities covered by NFPA 52

(4)

(5)

(6)

(7)

(8)

(9)

(10) Commissioning and maintenance of gas-consuming equipment

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

(12)

(13)

Statement of Problem and Substantiation for Public Comment

This makes it very clear that exploration and production and transportation of gas is not covered by NFPA 56

* Piping systems covered by NFPA 2





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

* LNG facilities covered by NFPA 59A

* Vehicle fuel dispensers

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

* Gathering lines from well pads to gas processing facilities

National Fire Protection Association Report https://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPar...

1 of 25 3/5/2019, 9:51 AM

In fact Appendix C only has information relating to electric generation plants as was the original intent and scope of NFPA 56 when first promulgated. The expertise for LPG and LNG is found in NFPA 58, 59, 59A Committees.

Related Item

• PI 7

Submitter Information Verification

Submitter Full Name: Richard Kraus

Organization: API/Petroleum Safety Consultan

Affiliation: API

Street Address:

City:

State:

Zip:

Submittal Date: Sun Sep 30 13:13:54 EDT 2018

Committee: GPS-AAA


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Public Comment No. 13-NFPA 56-2018 [ Section No. 1.1.1 [Excluding any Sub-Sections]

]

This standard shall apply to fire and explosion prevention during cleaning and purging activities for new andexisting flammable gas piping that fuel electric-generating equipment found in electric-generating plantsand in industrial, institutional, and commercial applications.


The American Petroleum Institute (API) Safety and Fire Protection Group (SFPG) has come to learn that the Gas Process Safety Technical Committee, which has jurisdiction over NFPA 56 (Standard for Fire and Explosion Prevention During Cleaning and Purging of Flammable Gas Piping Systems), is considering a change of scope. We request that the scope remain as is. We also suggest adding this further clarification to ensure that the intent of the document is maintained.

Related Item

• Expansion of Scope


Submitter Full Name: Stuart Saulters

Organization: API

Affiliation: Safety and Fire Protection Group (SFPG)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Oct 31 16:23:44 EDT 2018

Committee: GPS-AAA


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Public Comment No. 14-NFPA 56-2018 [ Section No. 1.1.1 [Excluding any Sub-Sections]

]

This standard shall apply to fire and explosion prevention during cleaning and purging activities for new andexisting flammable fuel gas piping which contains flammable gases found in electric-generating plantsfacilities and in industrial, institutional, and commercial applications.


NFPA 56 appropriately addresses fuel gas piping which carries flammable gasses. The later addition of "...industrial, institutional and commercial applications" is ambiguous and has been interpreted by some to expand the applicability beyond that of fuel gas lines, and by others, like myself, be expanded beyond electric generating planets to include other applications but only if they are still fuel gas lines. This has lead some to attempt to expand this standard to include well pad operations and gathering lines. In the former case this is a technical impossibility because the equipment required does not exist. In the latter case, it can lead to extremely dangerous situations. This is an attempt to bring this standard back to the discussions under which it was developed. Those discussions did not include anything beyond fuel gas piping.

Related Item

• Public Input No.7-NFPA 56-2018 (Section No. 1.1.1 Excluding any Sub-Sections)


Submitter Full Name: Robert Naper

Organization: Energy Experts International

Affiliation: Liaison from the Gas Piping Technology Committee

Street Address:

City:

State:

Zip:

Submittal Date: Mon Nov 12 12:35:50 EST 2018

Committee: GPS-AAA


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Public Comment No. 2-NFPA 56-2018 [ Section No. 1.1.1.1 ]

1.1.1.1*

Coverage of fuel gas piping systems shall extend from the point of delivery or source valve to the gas-consuming equipment isolation valve. The point of delivery or source valve shall be that which is nearestto the entry of the gas piping system onto the consumer's property. (see annex 1.1.1.1.1)

1.1.1.1.1

For other than undiluted liquefied petroleum gas (LP-Gas) systems, the point of delivery shall be the outletof the service meter assembly or the outlet of the service regulator or service shutoff valve where no meteris provided. [54:1.1.1.1(A)]

1.1.1.1.2

For undiluted LP-Gas systems, the point of delivery shall be considered to be the outlet of the final pressureregulator, exclusive of line gas regulators where no meter is installed. Where a meter is installed, the pointof delivery shall be the outlet of the meter. [54:1.1.1.1(A)]

1.1.1.1.3

For facilities that produce flammable gas for consumption on site, the point of delivery or source valve shallbe the discharge isolation valve for the gas-producing equipment.


this provides clarification that the gas piping system does not include piping that is located at or extends from the production facility to the distribution facility, Such piping is covered by the scope of NFPA 59

Related Item

• FR29




Affiliation: api

Street Address:

City:

State:

Zip:


Committee: GPS-AAA


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1.1.1.2*

Coverage of flammable gas piping systems other than fuel gas piping systems shall extend from the sourcevalve serving the gas supply system to the gas-consuming equipment isolation valve but not including theprocessing isolation valve or other associated gas extraction and processing equipment or piping .


To specifically exempt gas extraction, processing and main line pipeline delivery systems fromj the requirements of NFPA 56. Any needed requirements for this activity should be in NFPA 59.

Related Item

• PI9




Affiliation: api

Street Address:

City:

State:

Zip:


Committee: GPS-AAA


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Public Comment No. 15-NFPA 56-2018 [ Section No. 1.1.2 ]



(1)

(2)


(4)

(5)

(6)

(7)

(8)

(9)



(12)

(13) Exploration and development sites (wellpads), gathering lines, transmission lines and distrtibution lines. These include, within each type, bothmains and services.

(14) Converted lines

(15) Lines which have ever carried, or do carry gasses which are beyond the scope of "flammable" asdefined within this standard. For the alkane series, for example, lines which ever carried methane,ethane, propane and butane, would be controlled by this standard. However, if they ever carried, inwhole or in part, pentane, hexane, heptane, octane, etc. this standard would not apply. Attempting toapply this standard to pipes which have carried these gasses could be dangerous.


This wording further clarifies what NFPA 56 was specifically written to address by excluding those facilities which had no part of the discussion when this was written.

Related Item






Street Address:

City:

State:

Zip:


Committee: GPS-AAA












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(1)

(2)


(4)

(5)

(6)

(7)

(8)

(9)



(12)

(13)

(14)


these operations are in the scope of NFPA 59/59A and should not be included in this document. NFPA 56 scope is for users of gas and not intended for producers of gas.

Related Item

• PI 1




Affiliation: API

Street Address:

City:

State:

Zip:


Committee: GPS-AAA












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Public Comment No. 16-NFPA 56-2018 [ Section No. 1.2 [Excluding any Sub-Sections] ]

This standard provides minimum safety requirements for the cleaning and purging of flammable fuel gaspiping systems which transport flammable gases , including cleaning new or existing piping systems, andpurging piping systems into or out of service.


These changes are intended to make this portion of the standard consistent with being limited to fuel gas piping.

Related Item

• FR-4




Street Address:

City:

State:

Zip:


Committee: GPS-AAA


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1.5.1

Technical documentation shall be submitted to the authority having jurisdiction to demonstrate equivalency.However, it need not be submitted if the existing standard is well documented, and has been found to besafe and effective a long period of time. In addition, as in the case of gathering lines, many operators ownboth jurisdictional and non jurisdictional pipelines. Jurisdictional pipelines come under the jurisdiction of theUS Department of Transportation, which defines what is, and is not, jurisdictional. Those gathering lineswhich are jurisdictional have a higher risk than those which are not jurisdictional. It is not necessary for anoperator to demonstrate equivalence if they are using procedures for higher risk pipelines, which areacceptable to the US DOT for non-jurisdictional pipelines, which have less risk. One set of standards issufficient without a demonstration of equivalency.


The standard, in its present form, does not appropriately take into account other standards which have been found to be acceptable to other governing bodies or which have been used successfully for decades and which, in fact, may have a longer period of success than this standard. It can be argued that a standard which has proven itself to be safe and effective over decades is a wiser choice than one which is new and has yet to be proven over time.

Related Item

• Public Input No. 13-NFPA 56-2018 (Section No. 1.4.2)





Street Address:

City:

State:

Zip:


Committee: GPS-AAA


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Public Comment No. 24-NFPA 56-2018 [ Section No. 3.2 ]

3.2 NFPA Official Definitions.

3.2.1* Approved.

Acceptable to the authority having jurisdiction.

3.2.2* Authority Having Jurisdiction (AHJ).

An organization, office, or individual responsible for enforcing the requirements of a code or standard, orfor approving equipment, materials, an installation, or a procedure.

3.2.3 Labeled.

Equipment or materials to which has been attached a label, symbol, or other identifying mark of anorganization that is acceptable to the authority having jurisdiction and concerned with product evaluation,that maintains periodic inspection of production of labeled equipment or materials, and by whose labelingthe manufacturer indicates compliance with appropriate standards or performance in a specified manner.

3.2.4* Listed.

Equipment, materials, or services included in a list published by an organization that is acceptable to theauthority having jurisdiction and concerned with evaluation of products or services, that maintains periodicinspection of production of listed equipment or materials or periodic evaluation of services, and whoselisting states that either the equipment, material, or service meets appropriate designated standards or hasbeen tested and found suitable for a specified purpose.

3.2.5 Shall.

Indicates a mandatory requirement.

3.2.6 Should.

Indicates a recommendation or that which is advised but not required.

3.2.7 Standard.

An NFPA Standard, the main text of which contains only mandatory provisions using the word “shall” toindicate requirements and that is in a form generally suitable for mandatory reference by another standardor code or for adoption into law. Nonmandatory provisions are not to be considered a part of therequirements of a standard and shall be located in an appendix, annex, footnote, informational note, orother means as permitted in the NFPA Manuals of Style. When used in a generic sense, such as in thephrase “standards development process” or “standards development activities,” the term “standards”includes all NFPA Standards, including Codes, Standards, Recommended Practices, and Guides.

Additional Proposed Changes

File Name Description Approved

NFPA_56_New_Definitions_due_November_15.docxNew definitions for the expanded discussions within NFPA 56


The expansion of the discussions regarding the scope of NFPA 56 require us to be specific about that which we are referring to. These definitions would have us all speaking the same language and eliminate much of the confusion which the 2017 Edition currently has.

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Submittal Date: Wed Nov 14 16:34:41 EST 2018

Committee: GPS-AAA


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4.1.2* Pressure Testing and Inspection.

Prior to cleaning, pressure testing or purging a new system that has not been in service, piping systemsshall be inspected and pressure tested to determine that the materials, design, fabrication, and installationpractices comply with the requirements of this standard and the intended application. Before any pipe ispressure tested, it should be cleaned.

4.1.2.1*

Pressure testing and inspection procedures shall be documented.

4.1.2.2

Where piping is designed and installed in accordance with NFPA 54, pressure testing and inspection shallbe in accordance with NFPA 54, Chapter 8.

4.1.2.3

Where piping is designed and installed in accordance with ASME B31.1, Power Piping, pressure testingand inspection shall be in accordance with Chapter VI of ASME B31.1.

4.1.2.4*

Where piping is designed and constructed in accordance with ASME B31.3, Process Piping, leak testingand inspection shall be in accordance with Chapter VI of ASME B31.3.

4.1.2.5*

Where pneumatic testing is conducted in accordance with ASME B31.1, Power Piping, paragraph 137.5.2,or with ASME B31.3, Process Piping, paragraph 345.5.3, the test medium shall be air or an inert gas.Oxygen shall never be used.


Piping should, in general, be cleaned before being pressure tested. If a pipe is not cleaned first there is a significant increased risk of damage in the area the medium is being vented to, as well as a significant increased risk of static discharge leading to possible ignition or explosion. These, of course, could lead to injury or death.

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• Public Input No.7-NFPA 56-2018 (Section No. 4.1.2 Excluding any Sub-Sections





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Submittal Date: Tue Nov 13 15:02:27 EST 2018

Committee: GPS-AAA


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Public Comment No. 6-NFPA 56-2018 [ Section No. 7.1.2 [Excluding any Sub-Sections] ]

If an electric generating plant is operated by the serving natural gas supplier, natural gas piping betweenthe point of delivery or source valve and the plant shall be permitted to be purged into service inaccordance with the serving natural gas supplier’s written procedures.


Do not delete this section as it provides information for this type of distribution and consumer

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• FR13 PI24




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7.1.2.1

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


do not delete provides important requirements

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• FR13 PI 25




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7.1.2.1




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• PI 25




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7.1.2.2

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



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• PI 25




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7.3.1*

Sense of smell shall not be used to detect the presence of flammable gas. However, if the sense of smelldoes suddenly detect the presence of flammable gas and the instrument does not, the operation shouldimmediately be shut down until the detection equipment is checked for proper operation.


This addition takes into account the fact that sometimes, a CGI will not work properly. The normal sense of smell can, and has been, a life-saver under these circumstances.

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• Annex




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7.3.2*

Detection equipment shall be listed or approved for the gas being monitored and the environment where itis used and shall be calibrated in accordance with the manufacturer’s instructions. Before use, it should beturned on and zeroed in in clean air, following manufacturer's instructions at all times.


If a CGI is not turned on and calibrated in clean air, it may easily give inaccurate readings in an unsafe direction. For example, lets assume that the atmosphere within the room the gas is being purged into has a concentration of 2.0% gas in air. If the instrument is turned on and zeroed in in that atmosphere, it will be reading 2.0% lower than the actual concentration. So, if it reads the atmosphere to be 4%, ( less than the LFL), the concentration would actually be 6%, and within the combustible range, and immediately hazardous to life.

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• Annex




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7.3.4*

Lower flammability limit (LFL) monitors shall numerically display the gas concentration as a percentage ofthe LFL from 0 percent to 100 percent in measurement increments determined by the procedure. However,in the case of dual scale instruments calibrated to detect natural gas in air, they often have one scalemeasuring the LFL and another measuring 100 % gas. Under these circumstances the LFL scale is moreoften expressed as 0 percent to 5.00 percent, the latter being the LFL of natural gas. This is acceptable.Also the term LFL is equivalent to LEL, the lower explosive limit.


The additional wording brings this standard up-to-date with how modern CGIs are usually configured.

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• Annex




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8.2.1*

If an electric generating plant is operated by the serving natural gas supplier, natural gas piping betweenthe point of delivery or source valve and the plant shall be permitted to be purged out of service inaccordance with the serving natural gas supplier’s written procedures.

8.2.1.1


8.2.1.2

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



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• PI26




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8.4.1*

Sense of smell shall not be used to detect the presence of flammable gas. However, it may be noted that,when purging a pipeline of natural gas, the pipeline which is being purged may be "pickled" with odorant.After all natural gas has been purged, the air going through the pipeline may still pick up significant odorantfrom the pipe walls and the odor of gas may still be present. This is very common and should not be acause for alarm.


This addition is to alleviate any concerns a technician may have when the odor of gas is detected after the pipe has been purged of natural gas. This phenomenon is common with many gasses and liquids.

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• Annex




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Public Comment No. 1-NFPA 56-2018 [ Section No. A.1.1.1 ]

A.1.1.1

Industrial applications encompass a wide variety of manufacturing and other operations such as, but notlimited to, petroleum refining and petrochemical and chemical applications where fuel gas is consumed butnot where it is produced or transported by gas pipelines to the place where it is consumed .

A.1.1.1.3 delete proposed


The annex is intended to provide the user with clarification as to the exact piping systems covered by NFPA 56. NFPA 56 was never intended to cover gas extraction and production and mainline pipeline transport of LPG or LNG. These products are regulated by NFPA 58 and NFPA 59/59A as that is where the expertise is that is needed to provide safe handling procedures for these operations. We support the committee action. to not approve this change

We also support the rejection of CI2 (new section A 1.1.1.3) for the above reasons

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• CI 28 and CI 2




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Public Comment No. 12-NFPA 56-2018 [ Section No. A.1.1.1 ]

A.1.1.1

Industrial applications encompass a wide variety of manufacturing and other operations such as, but notlimited to, petroleum refining and petrochemical and chemical applications .


The American Petroleum Institute (API) Safety and Fire Protection Group (SFPG) has come to learn that the Gas Process Safety Technical Committee, which has jurisdiction over NFPA 56 (Standard for Fire and Explosion Prevention During Cleaning and Purging of Flammable Gas Piping Systems), is considering a change of scope. We request that the scope remain as is. We also suggest adding further clarification to ensure that the intent of the document is maintained. Deleting these portions of the appendix scope statement will assist in that explaining.

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• Expansion of Scope


Submitter Full Name: Stuart Saulters

Organization: API

Affiliation: Safety and Fire Protection Group (SFPG)

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Submittal Date: Wed Oct 31 16:19:02 EDT 2018

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Public Comment No. 11-NFPA 56-2018 [ Section No. A.1.1.1.1 ]

A.1.1.1.1

The piping system includes segments located between pieces of equipment, such as gas conditioning orcompressing equipment. This document does not cover the commissioning or maintaining of suchequipment. However, the standard can be applied to the commissioning or maintaining of those pipingsegments and equipment as a system where the complete system is purged into or out of service as a unit.The equipment manufacturer's written instructions should be included as part of the written purgeprocedure. The equipment isolation valve is intended to be the final isolation valve prior to themanufacturer’s or supplier’s equipment gas train. For some common pieces of equipment in NFPAstandards, the isolation valve is identified and referenced as follows:

(1) NFPA 37 uses the term equipment isolation valve in 5.2.1.

(2) NFPA 85 uses the term manual shutoff valve in Figure A.5.3.2.3 for single burner boilers; in FigureA.6.6.5.1.5.4(a) and Figure A.6.6.5.1.5.4(b) for multiple burner boilers; and in Figure A.8.8.5.8(a)through Figure A.8.8.5.8(c) for heat recovery steam generators.

(3) NFPA 86 uses the term equipment isolation valve in 6.2.4.1.

(4) NFPA 87 uses the term equipment isolation valve in 6.2.4.3.

(new)"

“delete *****This standard is intended to include oil and gas production facilities in as much as no existingstandards provide worker protection during maintenance activities”*** delete


WELL I do not know how one deletes something that is not in the report but was approvedThis new section which states “This standard is intended to include oil and gas production facilities in as much as no existing standards provide worker protection during maintenance activities” needs to be deleted in accordance with other proposed comments regarding scope of document. This should be in the scope of NFPA 59/59AI cannot believe the committee rejected others and not this annex item

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• PI 6




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NFPA 56 New definitions (Attachment to PC‐24)

Comments due November 15, 2018

DRAFT November 14, 2018 4:50 PM EST

Note: The source of each definition is shown, after the definition, within parentheses.

Converted pipeline is a pipeline previously used in service not subject to 49 CFR Part 192. The following

are some of the types of steel pipelines that might be converted to gas service under this part.

(a) Gas pipelines abandoned prior to effective date of Part 192.

(b) Liquid petroleum pipelines, such as oil or gasoline.

(c) LPG pipeline systems.

(d) Non jurisdictional pipelines.

(e) Pipelines carrying chemical or industrial products, such as carbon dioxide, nitrogen, air or liquid

chemicals.

(f) Slurry pipelines.

(Taken, pending approval, from the ANSI/GPTC Z380.1, Guide for Gas Transmission, Distribution, and

Gathering Piping Systems, 2018 Edition.)

Distribution line means a pipeline other than a gathering or transmission line. (49 CFR 192.3)

Fuel gas line, within NFPA 56, means a pipeline which is downstream of a service line and is owned by

the customer. It transports gas from the outlet of the customer meter or at the connection to a

customer's piping, whichever is further downstream, or at the connection to customer piping if there is

no meter. (New definition, only for this standard)

Gathering line means a pipeline that transports gas from a current production facility to a transmission

line or main. (49 CFR 192.3)

Main means a distribution line that serves as a common source of supply for more than one service line.

(49 CFR 192.3)

Pipe means any pipe or tubing used in the transportation of gas, including pipe‐type holders. (49 CFR

192.3)

Pipeline means all parts of those physical facilities through which gas moves in transportation, including

pipe, valves, and other appurtenance attached to pipe, compressor units, metering stations, regulator

stations, delivery stations, holders, and fabricated assemblies. (49 CFR 192.3)

Pipeline facility means new and existing pipelines, rights‐of‐way, and any equipment, facility, or building

used in the transportation of gas or in the treatment of gas during the course of transportation. (49 CFR

192.3)

Service line means a distribution line that transports gas from a common source of supply to an

individual customer, to two adjacent or adjoining residential or small commercial customers, or to

multiple residential or small commercial customers served through a meter header or manifold. A

service line ends at the outlet of the customer meter or at the connection to a customer's piping,

whichever is further downstream, or at the connection to customer piping if there is no meter. (49 CFR

192.3)

Transmission line means a pipeline, other than a gathering line, that:

(1) Transports gas from a gathering line or storage facility to a distribution center, storage facility, or

large volume customer that is not down‐stream from a distribution center;

(2) operates at a hoop stress of 20 percent or more of SMYS; or

(3) transports gas within a storage field. Note: A large volume customer may receive similar volumes of

gas as a distribution center, and includes factories, power plants, and institutional users of gas. (49 CFR

192.3)

Transportation of gas means the gathering, transmission, or distribution of gas by pipeline or the

storage of gas, in or affecting interstate or foreign commerce. (49 CFR 192.3)

NFPA Staff Notes:

Yellow highlighted text is the new term to be added to NFPA 56 if approved by the TC.

As noted above the red font in parentheses is the source for the definition.

Committee Input No. 15-NFPA 56-2018 [ Chapter B ]

Note: The committee is planning on updating the Annex B & C Text, Figures and Tables per the draft AGAPurging Manual, 4th Edition, 2018. At this time, please refer to the exisiting Annex materials as there appear tobe no changes between the 3rd and 4th editions except to the text in Annex B Sections 2.5 & 2.6. Please findattached the revised text edits for Annex B Sections 2.5 & 2.6 with the changes highlighted in yellow. The AGAextracted material for Annex B & C will be discussed at the second draft meeting.

Annex B Purge End Points for Common Flammable Gases

This annex is not a part of the requirements of this NFPA document but is included for informational purposesonly.

National Fire Protection Association Report https://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/...

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B.1


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The material in this annex is extracted in part from AGA XK0101, Purging Principles and Practices, Manual ,Fourth Edition, 2018, and is reprinted here with permission.


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Supplemental Information

File Name Description Approved

NFPA_56_Annex_B_Edition_4_2.5_and_2.6_Text_Rev.docx Annex B Sections 2.5 & 2.6 text edits ✓


Submitter Full Name: Lisa Hartman

Committee:


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Submittal Date: Thu May 31 16:41:25 EDT 2018

Committee Statement and Meeting Notes

Committee Statement: The material will updated to the current edition of the AGA Purging Manual, 4th edition, 2018.

Response Message: CI-15-NFPA 56-2018

Ballot Results

This item has not been balloted


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2.5 Purging Facilities into Service

A safe purging operation of air from piping or vessels subsequently filled with natural gas is generally represented in Figure 2-2. As an inert gas is added, the air concentration drops along ordinate VX to any point G below F. Subsequent addition of natural gas causes the mixture composition to change along line GH, which crosses no part of the flammable zone ABC. In the example shown in Figure 2-2, inert gas should be added until the purged atmosphere contains at least 42 percent inert gas, thereby reducing the air content in the purged atmosphere to 58 percent, or an oxygen concentration of about 12 percent.

To render a given flammable-air mixture nonflammable it is desirable to know what percentage of inert gases is required. Table 2-3 gives the values for a number of flammables investigated by the U.S. Bureau of Mines. To ensure safety, purging shall be continued to a point at least 20 percent beyond the flammable limit. These purging end-points are given on the right side of Table 2-3.

Sometimes it is more convenient to control the purging by determining the oxygen content of the purged gases. In purging into service, inert gas is added to the container until the oxygen concentration of the mixture is decreased to the point where no mixture of this with the flammable gas would be flammable. This data, also presented by the U.S. Bureau of Mines, is given in Table 2-4. Suggested purging end-point data with a 20 percent safety factor are given on the right half of Table 2-4 in terms of percent of oxygen for the purging of containers in preparation to receive the various flammables shown.

Note: NFPA 69 requires that oxygen end-points be calculated at 60% of the limiting oxidant concentration. The reader is urged to review both NFPA and US Bureau of Mines safety factors appropriate for their specific purge application.

2.6 Purging Facilities Out of Service

The operation of purging natural gas from piping or vessels to be filled subsequently with air may also be illustrated using Figure 2-2. As inert gas is added, the methane concentration decreases from point H (at the right) along abscissa HX to a point J beyond D. Subsequent addition of air results in a change in the mixture composition along line JV, which crosses no part of flammable zone ABC. In the example shown in Figure 2-2, at least 88 percent of methane should be replaced by nitrogen when the container is purged out of service.

To render a given flammable mixture nonflammable if air be added to it in any amount, it is desirable to know what percentages of inert gases are required. Table 2-5 gives the data for a number of flammables investigated by the U.S. Bureau of Mines. To ensure safety, purging shall be continued to a point at least 20 percent beyond the flammable limit. These purging end-points are given on the right side of Table 2-5. Again, the requirements of NFPA 69 implies that U.S. Bureau of Mines oxygen end-points listed in these tables do not meet the safety margins of a 60% limiting oxidant concentration.

NOTE: The reader should be aware and verify the appropriate limiting oxidant concentration for their specific application.

It is sometimes more convenient to control the purging by determining the flammable content of the purged gases. In purging out of service, inert gas is added to the container until the flammable gas concentration of the mixture is decreased to the point where no mixture of this with any amount of air would be flammable. These data are given on Table 2-6. Suggested purging end-point data with a 20 percent safety factor are given on the right side of Table 2-6 in terms of the percent of flammable in a mixture which will

remain nonflammable regardless of any amount of air which may be added to it.

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© National Fire Protection Association. All rights reserved.

NFPA 56 Second Draft MeetingWednesday, April 10, 2019 from 8:00 AM to 5:00 PM (EDT)

Sheraton Charlotte Airport Hotel3315 Scott Futrell Drive, Charlotte, North Carolina 28208

Technical Committee on Gas Process Safety (GPS-AAA)

Second Draft Balloting Procedures Presentation


NFPA Second Draft Meeting Balloting Information

• Ballots are on the Second Revisions (SR) ONLY Public Comments and Committee Statements not balloted Reference materials are available on the Doc Info page

Second Revisions Report, Public Comments Report, etc.• Ballot form allows you to vote:

Affirmative on all SR Affirmative on all SR with exceptions specifically noted

• Ballot form provides a column for affirmative with comment Note: This box only needs to be checked if there is an accompanying

comment.• Reject or abstain requires a reason.

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NFPA Second Draft Meeting Balloting Information

• Initial ballot

• Circulation of negatives and comments

• Members may change votes during circulation

• Second Revision that fails letter ballot shall be designatedas a Committee Comment (in the 2nd Draft Report),marked as “Reject” and deleted from the Second Draft.

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Electronic Balloting

• Ballots will be an online format (same as First Draft)

• Alternates are strongly encouraged to return ballots

• Ballot session will time out after 90 minutes

• Use “submit” to save your work

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Electronic Balloting • Click the link on the ballot email you will receive from

Jenny Depew.

• Sign in with your NFPA.org Committee Login and Password.

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• Select either Affirmative on All; or Affirmative withException(s)

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• Use “See SR - #” link to review all Second Revisions

• Use “Edit election” to change individual votes or to modify voteafter submitting ballot.

Choosing AFFIRMATIVE ON ALL

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• Make selection: Affirmative with Comment, Negative, or Abstain• No selection made-defaults to affirmative• Must include comment on each vote.

Choosing AFFIRMATIVE WITH EXCEPTION(S)

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• To complete ballot click Participant Consent andSubmit

• Return and edit any votes before ballot due date.

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nfpa technical committee on gas process safety (gps-aaa) … · 2019. 3. 19. · saudi aramco...

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