statement of problem and substantiation for public input€¦ · a13.1, scheme for identification...

Public Input No. 23-NFPA 853-2012 [ Section No. 2.3.1 ]

2.3.1 ANSI Publications.

American National Standards Institute, Inc., 25 West 43rd Street, 4th Floor, New York, NY 10036.

ANSI

A13.1, Scheme for Identification of Piping Systems , 1996.ANSI CSA FC.1, American National Standard for Fuel Cell Power Systems , 2004 2012 .

Statement of Problem and Substantiation for Public Input

The latest version of ANSI CSA FC.1 is dated 2012.

Submitter Information Verification

Submitter Full Name: Robert Wichert

Organization: Robert P. Wichert Professional Engineering, Inc.

Submittal Date: Tue Dec 18 14:54:30 EST 2012

Committee Statement

Resolution: FR-5-NFPA 853-2013

Statement: The latest version of ANSI CSA FC.1 is dated 2012.

Copyright Assignment

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

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

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2.3.2 ASME Publications.

American Society of Mechanical Engineers, Three Park Avenue, New York, NY 10016-5990.

ASME/ANSI B31.3, Process Piping , 1996.

B31.12, Hydrogen Piping and Pipelines, 2011.


The latest reference for hydrogen piping design is now ASME B31.12.





Committee Statement

Resolution: B31.12 is not applicable for fuel cell applications at this time as currently written. It is currently written to address large piping used in industrial applications. The next addition will address commercial and residential applications.


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





2.3.4 UL Publications.

Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096.

UL 790, Standard Test Methods for Fire Tests of Roof Coverings, 2004, Revised 2008 .


Update referenced standard to most recent revision.


Submitter Full Name: John Bender

Organization: Underwriters Laboratories Inc.


Committee Statement


Statement: Update referenced standard to most recent edition as indicated. Added reference to ASTM E 119 as it replaced the reference to NFPA 251 in section5.3.1.


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

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




2.3.4 UL Publications.

Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096.

ANSI/ UL 790, Standard Test Methods for Fire Tests of Roof Coverings, 2004, revised 2008 .


Update referenced standard to most recent edition as indicated.


Submitter Full Name: John Bender

Organization: UL LLC

Submittal Date: Fri Dec 28 09:08:21 EST 2012

Committee Statement


Statement: Update referenced standard to most recent edition as indicated. Added reference to ASTM E 119 as it replaced the reference to NFPA 251 in section5.3.1.


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

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



Public Input No. 15-NFPA 853-2012 [ Section No. 3.3.1.1 ]

3.3.1.1 Exhaust Air.

Air removed from a space or power system and not reused.


UTC Power's recent experience with siting in-door power plants has shown that the initial definitions have created confusion with the AHJs. The lack of definitions has not stopped a project but has added delays and cost.


Submitter Full Name: William Collins

Organization: UTC Power

Submittal Date: Thu Nov 08 10:51:15 EST 2012

Committee Statement

Resolution: The language was unchanged from the original text.


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

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




3.3.1.2 Ventilation Air.

The portion of supply air whose source is the outside/outdoors plus any recirculated air that has been treated and is acceptable for use by the power system ventilation system. This air may be used for circulation, dilution and/or primary air applications.

3.3.1.2.1 Circulation Air . The portion of supply air whose source is the outside/outdoors plus any recirculated air that has been treated and is acceptable for use by the power system ventilation system that is used to cool equipment located in areas unclassified per NFPA 70 Article 500-516.

3.3.1.2.2 Dilution Air . The portion of supply air whose source is the outside/outdoors plus any recirculated air that has been treated and is acceptable for use by the power system ventilation system that is used to cool equipment or dilute normal and abnormal releases to below a flammable level located in areas classified per NFPA 70 Article 500-516.

3.3.1.2.3 Primary Air . The portion of supply air whose source is the outside/outdoors plus any recirculated air that has been treated and is acceptable for use by the power system for the purpose of conversion of fuel and air to power and heat.







Committee Statement


Statement: UTC Power's recent experience with siting in-door power plants has shown that the initial definitions have created confusion with the AHJs. The lack of definitions has not stopped a project but has added delays and cost.


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




5.2.3

The exhaust outlet(s) from process areas or areas that contain fuel-bearing components of a fuel cell power system shall be located at least 4.6 m (15 ft) from heating, ventilating, and air-conditioning (HVAC) air intakes, windows, doors, and other openings into buildings unless the manufacturer’s instructions and the product listing allows closer spacing .

5.2.3.1

The exhaust outlet(s) shall not be directed onto walkways or other paths of travel for pedestrians.5.2.3.2

The area classification around outlets from processes or compartments that contain fuel-bearing components shall be in accordance with Article 500 or Article 505 of NFPA 70, National Electrical Code.


The current language requires a fifteen foot separation between building intakes and the fuel cell power system exhaust. If the manufacturer and the listing and the listing agency agree that closer spacing provides an equivalent level of safety, it should be allowed.





Committee Statement

Resolution: The added text is not necessary and is covered by section 1.5 equivalency.






Public Input No. 20-NFPA 853-2012 [ Section No. 5.2.3 [Excluding

any Sub-Sections] ]

5.2.3 The exhaust outlet(s) from process areas or areas that contain fuel-bearing components of a fuel cell power system shall be located at least 4.6 m (15 ft) from heating, ventilating, and air-conditioning (HVAC) air intakes, operable windows, operable doors, and other openings into buildings that could allow gas to enter the building .


The current language might be confused to mean separation from inoperable windows or other building features which would not be affected by the fuel cell power system exhaust. The revised wording makes it clear that the fuel cell power system exhaust only needs to be separated from other building features that might allow gas to enter the building.





Committee Statement

Resolution: The proposed text does not added any benefit to the requirement as currently written.







5.3.1

The room shall be separated from the remainder of the building by floor, wall, and ceiling construction that has at least a fire barrier walls and horizontal assemblies with a minimum of a 1-hour fire resistance rating in accordance with NFPA 251, Standard Methods of Tests of Fire Resistance of Building Construction and Materials 5000, Building and Construction Safety Code .


Note: This proposal was developed by the proponent as a member of the Building Code Development Committee (BCDC) with the committee's endorsement.The hazards associated with fuel cell systems are similar to other hazardous materials. In

both NFPA 5000 and the International Building Code, areas inside of buildings containing these and other hazardous materials are traditionally required to be segregated from the remainder of the building with Fire Barriers (that being that the supporting construction has an equivalent level of fire resistive protection) As currently written, the required fire resistive containment barriers could be something less than fire barriers such as fire partitions and even smoke barriers. This change will ensure consistency with both 5000 and other building codes which both currently require the supporting structure to be protected with an equivalent fire resistive rating. The following is an excerpt from NFPA 500034.2.4.1 Construction Requirements for Control Areas. 34.2.4.1.1 Control areas shall be separated from each other by fire barriers in

accordance with Table 34.2.4.1.1.


Submitter Full Name: Salvatore DiCristina

Organization: Rutgers, The State University of New Jersey


Committee Statement


Statement: The hazards associated with fuel cell systems are similar to other hazardous materials. In both NFPA 5000 and the International Building Code, areas inside of buildings containing these and other hazardous materials are traditionally required to be segregated from the remainder of the building with Fire Barriers (that being that the supporting construction has an equivalent level of fire resistive protection) As currently written, the required fire resistive containment barriers could be something less than fire barriers such as fire partitions and even smoke barriers. This change will ensure consistency with both 5000 and other building codes which both currently require the supporting structure to be protected with an equivalent fire resistive rating. The following is an excerpt from NFPA 5000 34.2.4.1 Construction Requirements for Control Areas. 34.2.4.1.1 Control areas shall be separated from each other by fire barriers in accordance with Table 34.2.4.1.1.




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

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




5.3.5

Fire dampers shall be installed in accordance with NFPA 90A 80 , Standardfor the Installation of Air-Conditioning and Ventilating Systems Fire Doors and Other Opening Protectives .


NFPA 853 should reference NFPA 80 for the installation requirements of fire dampers. The requirements for installation, testing, and maintenance of fire dampers were removed from NFPA 90A and placed in NFPA 80 for the 2007 edition. A new Chapter 19 in the document now contains the requirements that were previously found in NFPA 90A with regards to installation, testing and maintenance. For the 2009 edition of 90A, the requirements were replaced with a reference to NFPA 80, where such requirements now reside.


Submitter Full Name: Bruce Campbell

Organization: Hughes Associates, Inc.


Committee Statement


Statement: NFPA 853 should reference NFPA 80 for the installation requirements of fire dampers. The requirements for installation, testing, and maintenance of fire dampers were removed from NFPA 90A and placed in NFPA 80 for the 2007 edition. A new Chapter 19 in the document now contains the requirements that were previously found in NFPA 90A with regards to installation, testing and maintenance. For the 2009 edition of 90A, the requirements were replaced with a reference to NFPA 80, where such requirements now reside.


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

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



Public Input No. 22-NFPA 853-2012 [ Section No. 6.4.3 [Excluding

any Sub-Sections] ]

Hydrogen piping, valves, and fittings from the hydrogen storage system to the fuel cell power system shall conform to ASME/ANSI B31.3, Process PipingB31.12 , Hydrogen Piping and Pipelines and 6.4.3.1 through 6.4.3.7 .

6.8 For systems not adequately covered by sections 6.2, 6.2.2, 6.3, 6.4.3, 6.5 and 6.6, the applicable portions of the ASME Code for Pressure Piping, B31 shall be used.


Natural gas fuel is covered by Section 6.2; NFPA 54. Compressed natural gas is covered by Section 6.2.2; NFPA 52. Liquefied petroleum gas is covered by Section 6.3; NFPA 58. Biogas is covered by Section 6.5; NFPA 54. Liquid fuels are covered by Section 6.6: NFPA 30. Solid fuels are covered by Section 6.7. The most current reference for hydrogen piping design is now ASME B31.12. For other systems or outside the scope of these standards, other portions of ASME B31 might be preferable.





Committee Statement

Resolution: B31.12 is not applicable for fuel cell applications at this time as currently written. It is currently written to address large piping used in industrial applications. The next addition will address commercial and residential applications.







7.1.1

All fuel cell power systems shall be provided with a source of ventilation, exhaust, and makeup air in accordance with this chapter, with the exception of the following:

(1) Fuel cell power systems installed outdoors

(2) Listed prepackaged or pre-engineered and matched modular fuel cell power systems that have a sealed, direct ventilation and exhaust system that is installed in accordance with the terms of the listing and manufacturer's installation instructions

Additional Proposed Changes

File Name Description Approved853_PI_1Figure_7.1.1_Rec.docx 853 PI #1 Rec







Committee Statement





NFPA 853 (F14 ROP) PI #1


7.1.2*

The building ventilation system and fuel cell power system and exhaust system shall be designed to provide a negative or neutral pressure in the room, with respect to the building.







Committee Statement

Resolution: The current requirement provides greater flexibility for fuel cells that use different ventilation arrangements as indicated in the annex to this section.




Page 16 of 30National Fire Protection Association Report



7.1.3

The ventilation air intake , and exhaust air system(s) shall meet the requirements specified in Sections 5.1, 7.2, and 7.3.







Committee Statement









7.2.1

A separate mechanical building ventilation system shall be provided for the area where a fuel cell power system is located. This system is to remove exhaust air. This system may also be the source of supply for fuel cell power system ventilation air (primary, circulation, and dilution system(s)).







Committee Statement


Statement: An annex note has been added to clarify the purpose of the ventilationsystem.







7.2.2

If it can be verified, natural ventilation shall be permitted to provide all required ventilation and makeup exhaust air.







Committee Statement


Statement: The term exhaust air was not accepted and was removed as the requirement falls under section 7.2, which specifically addresses "Ventilation Air".







7.2.3

The inlet air vent inlets for all primary, ventilation, and exhaust air system(s) shall be designed to prevent foreign matter from entering and/oraccumulating .







Committee Statement









7.3.2

The fuel cell power system exhaust system shall be designed such that all harmful emissions are exhausted to a safe location.







Committee Statement









7.3.3

The building ventilation exhaust rate from the room shall not be less than 0.3 m3/min·m2 (1 cfm/ft2) of floor area and not less than 45 m3/min (150 cfm).







Committee Statement


Statement: UTC Power's recent experience with siting in-door power plants has shown that the initial definitions have created confusion with the AHJs. The lack of definitions has not stopped a project but has added delays and cost. The 45 m3/min.m2 was a typo and has been modified to 4.25 m3/min.m2.







7.3.4

If mechanical exhaust for either the fuel cell power system or building is required, a control interlock shall be provided to shut down the fuel cell power system the unit upon loss of exhaust.


UTC Power's recent experience with siting in-door power plants has shown that the initial definitions have created confuston with the AHJs. The lack of definitions has not stopped a project but has added delays and cost.





Committee Statement


Statement: UTC Power's recent experience with siting in-door power plants has shown that the initial definitions have created confuston with the AHJs. The lack of definitions has not stopped a project but has added delays and cost.







7.3.5

The exhaust outlet(s) shall be located as specified in 5.2.3.

7.3.6 The exits for exhaust from the fuel cell power system and/or building air system(s) shall be designed to prevent foreign matter from entering and/oraccumulating.







Committee Statement









8.1.5.4 4*

Combustible gas detector(s) shall be installed in the fuel cell power system enclosure, the exhaust system, or the room that encloses the fuel cell power system installation per the manufacturer's instructions and local regulation .







Committee Statement









8.1.5.5

A combustible gas detector that meets the requirements of 8.1.5.4 shall be provided for all indoor or separately enclosed fuel gas compressors (fuel gas boosters) . Fuel gas coosters within the fuel cell enclosure containing fuel containing members are addressed in ANSI FC1 as part of the leak detection and mitigation strategy.







Committee Statement


Statement: An annex has been added to clarify compressor requirements.






Public Input No. 26-NFPA 853-2012 [ New Section after A.5.1.2 ]

TITLE OF NEW CONTENT

A.5.2.3 If the manufacturer’s instructions and the product listing allows closer spacing based on the potential amount of the release and the mixing models used, closer spacing is allowed.


The current language requires a fifteen foot separation between building intakes and the fuel cell power system exhaust. If the manufacturer and the listing and the listing agency agree that closer spacing provides an equivalent level of safety, it should be allowed.





Committee Statement

Resolution: The added text is not necessary and is covered by section 1.5 equivalency.






Public Input No. 25-NFPA 853-2012 [ New Section after A.6.4 ]

TITLE OF NEW CONTENT

A.6.4.3 Some hydrogen generators, e.g., reformers or gasifiers used with fuel cells, may produce a gas mixture that is less than 95% hydrogen or above the temperature limits of ASME B31.12, Hydrogen Piping and Pipelines. In these cases another section of ASME B31 may be more appropriate.


Natural gas fuel is covered by Section 6.2; NFPA 54. Compressed natural gas is covered by Section 6.2.2; NFPA 52. Liquefied petroleum gas is covered by Section 6.3; NFPA 58. Biogas is covered by Section 6.5; NFPA 54. Liquid fuels are covered by Section 6.6: NFPA 30. Solid fuels are covered by Section 6.7. The most current reference for hydrogen piping design is now ASME B31.12. For other systems or outside the scope of these standards, other portions of ASME B31 might be preferable.





Committee Statement

Resolution: B31.12 is not applicable for fuel cell applications at this time as currently written. It is currently written to address large piping used in industrial applications. The next addition will address commercial and residentialapplications.






Public Input No. 11-NFPA 853-2012 [ Section No. A.7.1.2 ]

A.7.1.2

The building ventilation and fuel cell power system and exhaust system design should consider the manufacturer's air requirements for the fuel cell power system(s) and any additional equipment that is located within thespace.







Committee Statement








Public Input No. 5-NFPA 853-2012 [ New Section after A.8.1.5.2 ]

A.8.1.5.4 Combustible gas detector(s) shall be installed in the fuel cell power system enclosure, the exhaust system, and/or the room that encloses the fuel cell power system installation. Location and quantity shall be per the manufacturer's instructions and local regulation. In many cases, a fuel cell power system that includes an internal combutible gas detector would meet this requirement.







Committee Statement


Statement: Clarification has been added regarding internal combustible gas detectors.






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