Statement of Problem and Substantiation for Public Input ... Input No. 4-NFPA 37-2015 [ Global Input ] Throughout standard remove references to the following and replace with the following:

Public Input No. 4-NFPA 37-2015 [ Global Input ]

Throughout standard remove references to the following and replace with thefollowing:

(1) ANSI/UL and replace with UL.

(2) ANSI/ASME B31.3 and replace with ASME B31.3.

(3) API # and so on and replace API STD # or API RP #.

Statement of Problem and Substantiation for Public Input

Corresponds with PI-5 and PI-6.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 5-NFPA 37-2015 [SectionNo. 2.3]

Referenced current SDO names, addresses, standardnames, and years,

Public Input No. 6-NFPA 37-2015 [SectionNo. B.1.2]

Referenced current SDO names, addresses, standardnames, and years,

Submitter Information Verification

Submitter Full Name: Aaron Adamczyk

Organization: [ Not Specified ]

Street Address:

City:

State:

Zip:

Submittal Date: Sat Feb 07 01:55:00 EST 2015

Committee Statement

Resolution: A document search may not recognize abbreviations. If, for example, a standard has beenrecognized by ANSI, the group who has created the standard generally wants the documentrecognized as such and would include ANSI in the designation. The reference should be the full title,not an abbreviation. The Manual of Style should be referenced to ensure compliance with theformatting for references.

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

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Public Input No. 5-NFPA 37-2015 [ Section No. 2.3 ]

2.3 Other Publications.

2.3.1 API Publications.

American Petroleum Institute, 1220 L Street, NW, Washington, DC 20005-4070.

API STD 620, Design and Construction of Large Welded Low-pressure Storage Tanks, 11th 12thedition, February 2008 2013, Amendment 1, 2014 .

API STD 650, Welded Tanks for Oil Storage, 11th 12th edition, June 2007 2013, Errata, 2014 .

2.3.2 ASME Publications.

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

ANSI/ ASME Boiler and Pressure Vessel Code, 2007 2015 .

ANSI/ ASME B31.3, Process Piping, 2002 2014 .

2.3.3 MSS Publications.

Manufacturers Standardization Society of the Valve and Fittings Industry Inc. , 127 Park Street NE, Vienna,VA 22180-4602 .

MSS SP -69 58 , Pipe Hangers and Supports — Selection and Application, 2003. And Supports -Materials, Design, And Manufacture, Selection, Application, And Installation, 2009 . (SupersedesMSS SP-69)

2.3.4 UL Publications.

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

ANSI/ UL 900, Standard for Air Filter Units, 2004, with revisions through November Revised 2012.

2.3.5 Other Publications.

Merriam-Webster’s Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, 2003.


Referenced current SDO names, standard numbers, names, and years



Public Input No. 4-NFPA 37-2015 [Global Input]

Public Input No. 6-NFPA 37-2015 [Section No. B.1.2]




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Committee Statement

Resolution: FR-13-NFPA 37-2015

Statement: Updated information for reference documents.


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Public Input No. 18-NFPA 37-2015 [ New Section after 3.3.8 ]

3.3.x Protected Pressure. A pressure that equals the setting of the nearest, upstream overpressureprotection device or is the inlet pressure to the service regulator, whichever is lower.

Additional Proposed Changes

File Name Description Approved

3.xx_definition_of_protected_pressure.pdf original


This would be a useful term to introduce in 5.9 to remove ambiguity with OPD regulators.


Submitter Full Name: KEVIN CARLISLE

Organization: KARL DUNGS INC

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Submittal Date: Thu Jul 02 14:02:26 EDT 2015

Committee Statement


Statement: The committee added these definitions to address the terms introduced in the new section 5.6(FR-11).


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3.3.x Proof-of-Closure Switch. A switch installed in a safety shutoff valve that activates only after the valve isfully closed.



3.x.x_POC_definition.pdf original


Suggest that this term be defined, and that the definition be the same as in NFPA 86.




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3.3.x.x Overpressure cutoff device. an overpressure protection device. such as such as a slam-shut valve ora high-pressure switch in combination with an adequately rated shutoff valve. functions by completelyshutting off the flow of gas into the downstream system.

3.3.x.x pressure relief valve : an overpressure protection device which vents gas from the downstreamsystem to a safe location.

3.3.x.x Monitoring Regulator. an overpressure protection device that acts as backup pressure regulator.which is set in a non-regulated state and in series with another main pressure regulator. for the purpose oftaking over and providing a regulated pressure should the main pressure regulator fail.

3.3.x.x Series Regulator. one of two pressure regulators in series. both of which are in a regulated state.and one acts as an overpressure protection device for the purpose of continuously providing a regulatedpressure should the other regulator fail.



3.xx_defintion_of_OP.pdfOriginal


Overpressure Protection Devices are required, and section 5.9 discussed what they do. But a definition of what they are would be good to have in ' the code.




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3.3.x Service Regulator. A pressure regulator installed by the serving gas supplier to reduce and limit theservice line gas pressure (e.g. street pressure) to point of delivery pressure (delivery pressure).



3.3xx_defintion_of_service_regulator.pdf original


Definitoin of service regulator is needed in order to clarify the definition of protected pressure.




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TITLE OF NEW CONTENT

4.1.4.1 The engine shall be installed in a location such that the termination of the exhaust system is inaccordance with 8.2.3.


Currently, the Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines (“NFPA 37”) and the National Electrical Code (“NFPA 70 (NEC)”) do not address carbon monoxide (“CO”) poisoning hazards for stationary generators. A U.S. Consumer Product Safety Commission (“CPSC”) staff proposal to add generator installation requirements in the 2017 NEC to address carbon monoxide poisoning hazards resulted in the addition of an Informational Note in section 445.10 in the first draft of the NEC: “See NFPA 37, Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines for information on the location of generator exhaust.” Code-making Panel No. 13 believed that the CO hazard needed to be addressed during generator installation and stated: “Where the NEC addresses the permanent installation of combustible engine driven generators, it is prudent to reference NFPA 37. Prescriptive requirements for generator exhaust is under the purview of NFPA 37 and any proposed changes should be directed to that committee.”

The proposed additions to 4.1.4 and 8.2.3 are intended to prevent combustion gases exhausted from an engine generator from infiltrating a structure to reduce the risk of consumer CO poisoning injuries and deaths from stationary generators.

The CPSC’s databases include at least two incidents involving stationary generators installed outdoors that caused CO poisonings indoors. In a 2011 incident (documented in CPSC In-Depth Investigation report [“IDI”] 110912HNE1118), two victims died from CO poisoning from a 7 kilowatt (“kW”) propane engine-powered stationary generator installed in the immediate vicinity of a ground-level screened access vent/window for the crawlspace, which ran under the entire dwelling. In a 2005 incident (IDI 050830HNE2737), four victims suffered severe nonfatal CO poisoning from a propane engine-powered12 kW stationary generator. The stationary generator was installed on the side of the house, right under a large window, and next to the air conditioner ventilation system.

The U.S. Environmental Protection Agency’s Nonroad Small Spark-Ignition Engine Certification Data1 include data showing that the CO emission rates from propane and natural gas-fueled engines, such as those used in stationary generators, are often just as high as those from gasoline-fueled engines, such as those used in portable generators. For the 10-year period of 2004 through 20132, CPSC has reports of 15 non-work-related consumer CO deaths resulting from the exhaust of gasoline-fueled portable generators operating outdoors infiltrating the homes; there are other published sources that show CO deaths and injuries from outdoor operation of gasoline-fueled portable generators. A number of these sources document that the injured consumers generally used their portable generators, on average, only a few feet away from the nearest door or window.3,4 In 2013, the Centers for Disease Control and Prevention (“CDC”) began recommending that portable generators should never be placed less than 20 feet from an open window, door, or vent where exhaust can infiltrate into an enclosed area5; and CPSC is now making this recommendation as well.6 This recommendation is based, in part, on results of modeling studies performed by the National Institute of Standards and Technology (“NIST”) on the effects on indoor CO concentration profiles of operating an existing, gasoline-fueled carbureted generator outdoors.7,8

NFPA 37, NFPA 70, and UL 2200, Standard for Stationary Engine Generator Assemblies currently deal only with fire and shock hazards; they do not address the CO poisoning hazard related to exhaust emissions. The natural gas and propane engines used in stationary generators have CO emission rates comparable to gasoline-fueled portable generators,1 which have a long history of causing CO poisoning fatalities and injuries when placed outside the home, but close enough to the home to allow the exhaust to infiltrate indoors. NFPA 37 currently allows stationary generators to be located 5 ft. from openings in walls (e.g., windows, doors) and even closer placement, with NO minimum distance, if the adjacent structure wall is fire resistant or the generator enclosure will not ignite combustible materials outside the enclosure.

References:


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1. CO emission rates of natural gas and propane engines in the EPA’s exhaust emission database for small non-road spark-ignited engines have CO emission rates comparable to the gasoline-fueled engines: http://www.epa.gov/otaq/certdata.htm#smallsi.

2. Matthew V. Hnatov, U.S. Consumer Product Safety Commission, Incidents, Deaths, and In-Depth Investigations Associated with Non-Fire Carbon Monoxide from Engine-Driven Generators and Other Engine-Driven Tools, 2004-2013, http://www.cpsc.gov//Global/Research-and-Statistics/Technical-Reports/Home/Portable-Generators/GeneratorsandOEDTFatalities-2014-FINAL.pdf<, June 2014.

3. CDC, 2006. Carbon Monoxide Poisonings After Two Major Hurricanes - Alabama and Texas, August - October 2005, Morbidity and Mortality Weekly Report (“MMWR”), United States Centers for Disease Control and Prevention: 4. 4. CDC, Carbon Monoxide Poisoning from Hurricane-Associated Use of Portable Generators- Florida, 2004, MMWR 2005; 54:697-700. 5. Carbon Monoxide Poison Prevention, Centers for Disease Control and Prevention Web page, http://www.cdc.gov/features/copoisoning/.

6. U.S. Consumer Product Safety Commission Winter Weather Alert: Generators, CPSC website, http://www.cpsc.gov/onsafety/2014/01/winter-weather-alert-generators/.

7. Liangzhu (“Leon”) Wang, S. J. Emmerich, NIST Technical Note 1637, Modeling the Effects of Outdoor Gasoline Powered Generator Use on Indoor Carbon Monoxide Exposures, August 2009, http://fire.nist.gov/bfrlpubs/build09/art009.html. 8. Liangzhu (“Leon”) Wang, S. J. Emmerich, and R. Powell, NIST Technical Note 1666, Modeling the Effects of Outdoor Gasoline Powered Generator Use on Indoor Carbon Monoxide Exposures – Phase II, July 2010, http://www.cdc.gov/nceh/airpollution/pdfs/cdc_phaseii_tn1666.pdf.

**This proposal is that of the CPSC staff, has not been reviewed or approved by, and may not necessarily reflect the views of, the Commission.



Public Input No. 16-NFPA 37-2015 [Section No. 8.2.3.1] dependent


Submitter Full Name: DOUGLAS LEE

Organization: US CONSUMER PRODUCT SAFETY COM

Affilliation: US Consumer Product Safety Commission Staff

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Submittal Date: Wed Jul 01 16:20:00 EDT 2015

Committee Statement

Resolution: The committee decided that there is no need for this section, which simply references another sectionof the standard. The exhaust requirements of section 8.2 stand alone.


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Public Input No. 11-NFPA 37-2015 [ Section No. 4.1.4 ]

4.1.4 * Engines Located Outdoors.

Engines, and their weatherproof housings, if provided, that are installed outdoors shall be located at least1.5 m (5 ft) from openings in walls and at least 1.5 m (5 ft) from structures having combustible walls. A Theminimum separation distance shall not be required where either permitted to be decreased where anyone of the following conditions exist:

(1) All If all walls of the structure that are closer than 1.5 m (5 ft) from the engine enclosure have a fireresistance rating of at least 1 hour, no minimum separation distance shall be required .

(2) The weatherproof enclosure is constructed of noncombustible materials and it has beendemonstrated that a fire within the

the engine shall be permitted to be placed ata distance no lower than that used during the fire test from a combustible wall similar to the one usedin the test.

(3) * If calculations acceptable to the authority having jurisdiction have demonstrated that a fire within theengine enclosure will not ignite a combustible materials wall outside the enclosure at the distanceat which the engine is placed .

A.4.1.4 It has been demonstrated that, when engines fail, they can generate large fires and cause ignitionof nearby structures.

A.4.1.4 (2) Combustible materials exhibit different levels of combustibility or of ignitability. Examples ofcombustible exterior wall materials include various types of siding, such as vinyl, wood and polypropylene,as well as different exterior wall coverings (such as particleboard), exterior insulation and finish systemsand decorative laminates. It has been shown that these various combustible materials can have verydifferent levels of fire performance or of ignitability (see for example, NFPA 555, Guide on Methods forEvaluating Potential for Room Flashover). Therefore, the full scale fire tests should be conducted in thepresence of combustible materials that adequately represent the potential fire hazard to be expected at thelocation where the engine is to be placed. Moreover, it is advisable that engines located outdoors shouldbe placed at a separation distance from the nearest combustible wall that is greater than the distance atwhich the fire tests have been conducted, to provide a margin of safety. An example of the type of full scalefire tests that have been conducted, which will serve for guidance, can be found in a publication byHirschler (Marcelo Hirschler, “Testing of Residential Electrical Generators”, Fire and Materials Conf., SanFrancisco, CA, Jan. 31-Feb. 2, 2011, pp. 71-81, Interscience Communications, London, UK.)

A.4.1.4 (3) Calculation procedures, such as those given in NFPA 555, Guide on Methods for EvaluatingPotential for Room Flashover, are useful tools to assess the probability of safe engine placement.

The calculating procedure in Chapter 10 of NFPA 555 is similar to the Radiant Ignition of a Near Fuelalgorithm in NIST’s FPETOOL for calculation ignition from a nearby fire. It is a sound, engineering-basedmethod of predicting the risk of ignition from a fire.

The values in 4.1.4 and the reference to the NFPA 555 calculation method are the result of the calculationspresented to the committee in 1996. The calculations treated an engine fire as a vertical cylinder. The valuesin 4.1.4 changed somewhat in the 1998 edition of NFPA 37, based on those calculations. They arereasonably consistent with the requirements of the BOCA building code, which was in effect at the time. Thecommittee wanted to include a performance alternative in NFPA 37 . The reference in this annex section tothe NFPA 555 method provides guidance on how to evaluate proposed alternatives.

(Also add the proposed reference into an annex on informational references).


This section lacks the information an authority having jurisdiction needs to assess any reports provided by an engine manufacturer seeking to place engines close to combustible walls. There are no criteria for how to demonstrate that an engine fire will not ignite a combustible wall or for how close to the wall the engine can be

*If a full scale fire test involving an actual engine and a

combustible wall has demonstrated that the complete consumption of the combustibles within thetested engine will not cause ignition of the nearby wall,


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placed. The proposed language provides that information without being a detailed test protocol and without ruling out the use of calculations as a tool.1. In view of the close proximity between homes that often install engines or generators to ensure uninterrupted electrical supply, clear criteria for engine placement are essential to permit adequate enforcement. NFPA 37 does not contain enforceable criteria.2. This public input incorporates the wishes of the technical committee in the last cycle that NFPA 37 should not specify details of the full scale fire test procedure to be used for determining acceptable separation distances. This is reflected in the proposed wording.3. This comment also accepts the wishes of the technical committee that calculation methods be retained as an option. This is reflected in the proposed wording.4. This comment does not propose wording that would require specific test protocols but simply proposes wording that ensures a minimal level of safety, after the calculations or full scale fire tests have been conducted.5. This comment suggests the addition of the phrase “acceptable to the authority having jurisdiction” because that will ensure an “approved” level of safety.6. If an engine burns it can cause the ignition of nearby combustible walls. Whether ignition of combustible walls occurs will depend primarily on three factors: (a) the amount and fire performance of the combustible materials in the engine and the engineering design of the engine and its enclosure, (b) the materials contained in the combustible walls present and (c) the distance between the engine and the combustible walls.7. Fire tests have demonstrated that fire tests with some engines can be more severe when the generator/engine is not operating because the associated cooling fan in the generator/engine can result in the extinguishment of the fire when the generator/engine is operating but not when the generator/engine is idle. This has been shown for at least two engine designs. (a) Jason Huczek (Southwest Research Institute) [“Custom Fire Testing of Power Generators for NFPA 37 Compliance”, at the NFPA 2010 Annual Meeting, Session T68, June 9, 2010] and (b) Marcelo Hirschler [“Testing of Residential Electrical Generators”, Fire and Materials Conf., San Francisco, CA, Jan. 31-Feb. 2, 2011, pp. 71-81, Interscience Communications, London, UK]. A proposed reference to the latter work, which involved full scale fire tests, is proposed to be added to NFPA 37.8. There can be no assurance that every generator/engine will be provided with an adequate fan. Therefore, full scale fire tests or calculations should be conducted with both the engine operating and the engine idle. However, that requirement is not included here, to allow maximum flexibility for the fire test.9. The full scale fire tests or calculations leading to the determination of the safe location distance need to be conducted in such a way that there is complete consumption of the combustible materials in the engine/enclosure to ensure that the full scale fire tests or calculations actually address the fire hazard.10. If the full scale fire tests or calculations do not result in complete consumption of the combustible materials in the engine there can be no assurance that the results are fully representative of the actual fire hazard.11. There are different types of combustible wall materials that are in common use and the full scale fire tests need to be conducted using either the wall materials to be used in the actual installation or the combustible wall materials with the poorest fire performance. Fire tests have demonstrated that polypropylene siding is a more combustible wall material than either wood siding or vinyl (PVC) siding. Peak heat release rate data for polypropylene, wood and PVC siding materials are shown below.12. The distance between the engine and the combustible walls should provide be a reasonable margin of safety so that if the tests are conducted at a distance of, for example 1 ft., the engine enclosure should not be permitted to be placed closer than 1.5 ft. (i.e. a 50% margin of safety).13. This public input proposes the elimination of the requirement that the weatherproof enclosure be constructed of noncombustible materials because that is neither a needed requirement (if the engines have been properly designed) and has long been ignored by manufacturers. For the vast majority of engines the weatherproof enclosures contain some combustible components (such as knobs, for example) and their presence or absence is of no consequence if a fire that destroys all combustible materials does not cause wall ignition, and that is the key issue.

Heat release rate of siding materials (calorimeter testing)Vinyl (PVC) siding: 187 kW/m2Cedar siding: 309 kW/m2Polypropylene siding: 546 kW/m2

Note that existing annex text has been included in this public input as well as proposed revised annex text.



Public Input No. 12-NFPA 37-2015 [Section No. A.4.1.4(2)]

Public Input No. 29-NFPA 37-2015 [Section No. 4.1.4]


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Public Input No. 30-NFPA 37-2015 [Section No. B.2]


Submitter Full Name: MARCELO HIRSCHLER

Organization: GBH INTERNATIONAL

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Submittal Date: Mon Jun 29 12:59:28 EDT 2015

Committee Statement


Statement: The committee agrees that in certain cases it may be possible to locate engines closer than the 5 ftclearance specified previously. The committee has incorporated criteria for fire tests and calculationsthat will allow this clearance to be decreased. The committee chose not to include the referencedocument by the submitter, as it was not provided to the committee for review with the public input,and the committee was not able to find it in the public domain. The committee also deleted therequirement for noncombustible weather enclosures provided they can meet the fire test orcalculations which would substantiate their use.


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4.1.4 Engines Located Outdoors.

Engines, and their weatherproof housings, if provided, that are installed outdoors shall be located at least1.5 m (5 ft) from openings in walls and at least 1.5 m (5 ft) from structures having combustible walls. Aminimum separation shall not be required where either of the following conditions exist:

(1) All walls of the structure that are closer than 1.5 m (5 ft) from the engine enclosure have a fireresistance rating of at least 1 hour.

(2) The weatherproof enclosure is constructed of noncombustible materials and it has beendemonstrated

The full scale fire test shall involve a worst case scenario of a fullyinvolved engine.


This is a more generic approach to that PI 11 to include requirements for a full scale fire test. The same justification is valid and the same revisions would be necessary for the annex note (as shown in PI 12).

The substantiation for PI 11 is not being repeated here for the purposes of brevity.









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* When documentation regarding a full scale fire test of the engine acceptable to the

AHJ has been provided demonstrating that a fire within the enclosure will not ignite combustiblematerials outside the enclosure.


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5.1.1

Gas piping shall be installed in accordance with the following methods:

(1) All fuel gas systems at service pressures equal to or less than a gauge pressure of 860 kPa (gaugepressure of 125 psi) shall be installed in accordance with NFPA 54, National Fuel Gas Code.

(2) All fuel gas systems at service pressures in excess of a gauge pressure of 860 kPa (gauge pressureof 125 psi), other than LP-Gas systems, shall be installed in accordance with ANSI/ASME B31.3,Process Piping.

(3) LP-Gas systems, whether liquid or vapor phase, shall be installed in accordance with the provisionsof NFPA 58, Liquefied Petroleum Gas Code.

(4) Biogas piping systems shall be installed in accordance with the provisions of ANSI/GSA 8149.6.



5.1.1_ANSI_CSA_B149_6_ref.pdforiginal


ANSI/GSA 8149.6 is a code for digester gas, landfill gas, and biogas generation and utilization. This code covers the proper gas piping requirements when using such gases.




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Committee Statement

Resolution: CI-10-NFPA 37-2015

Statement: This CI was created to gauge need for providing an installation standard for biogas piping systems.The committee is soliciting public comments on this subject.


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5.1.3

Approved metallic flexible connectors shall be permitted for protection against damage caused bysettlement, vibration, expansion, contraction, or corrosion. All flexible connectors used for vibrationdampening shall be properly anchor and installed according to manufacturer's instructions.



5.1.3_flex_hose.pdf original


Too many installation use flexible connectors, and there is no proper anchoring of the flex hose. This whips the gas train, and increasing the risk of causing significant damage to devices and components upstream.




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Committee Statement


Statement: The committee agreed with the need to anchor connectors used for vibration dampening and hascreated a new section to address this.


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5.2.x. (6)*1f a high-pressure limit control trips. a manual reset shall be required to re-start the engine.


Manual reset is required so that the failed component can be identified and replaced before other components, such as diaphragms for sensing andcontrol, are damaged by a repeat high-pressure condition.




Public Input No. 27-NFPA 37-2015 [Section No. A.5.2]

Public Input No. 28-NFPA 37-2015 [New Section after A.5.1.2]




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Statement: The committee agreed that where a high-pressure limit control trip occurs, the cause should beinvestigated prior to a manual reset. This was moved to chapter 9 to address this as an operationalissue rather than a gas supply issue.


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5.2.1

Gas trains, as defined in 3.3.5, shall contain at least the following safety components:

(1) An equipment isolation valve

(2) A gas pressure regulator, if the prime mover does not operate at the gas supply pressure

(3) Two automatic safety shutoff valves (ASSVs)

(4) A manual leak test valve for each ASSV or an alternative means of proving the full closure of theASSV

(5)

(6)

(7) A vent valve or a valve proving system (VPS) for inlet gas pressures greater than a gauge pressure of14 kPa (gauge pressure of 2 psi)

(8) A flame arrester, where biogases are used and there is risk of having oxygen in the biogas

(9) A gas filter or strainer

(10)





Public Input No. 26-NFPA 37-2015 [New Section after 5.2.1]

Public Input No. 27-NFPA 37-2015 [Section No. A.5.2]




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Committee Statement


Statement: The committee determined that the requirement for manual reset is valid and has revised thedocument to clarify that the manual reset can be done at a control panel.

* A low-pressure limit control for engines with a 732 kW (2.5 million Btu/hr) full-load input or greater

* A high-pressure limit control (manual reset) for engines with a 732 kW (2.5 million Btu/hr) full-loadinput or greater

* Any other components or equipment that the manufacturer requires for safe operation


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The annex material in item (10) was moved to the main body of the text (new section 5.6, see FR 11)in order to provide minimum requirements for properly using and applying overpressure protectiondevices.


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Public Input No. 20-NFPA 37-2015 [ Section No. 5.3.2.1 ]

5.3.2.1 Such relief valves and any

If the protected pressure to the equipment isolation valve exceeds the pressure rating of any downstreamcomponent, an overpressure protection device shall be installed. either upstream or downstream of theequipment isolation valve.

5.3.2.2 The overpressure protection device. when required in 5.3.2.1. shall provide a protected pressure thatis equal to or lower than the lowest rated. downstream component or device on the gas train

5.3.2.3 The overpressure protection device shall be one of the following:

(I) A second regulator in series with the supply pressure regulator

(2) A monitoring regulator installed in series with an operating regulator

(3) A pressure relief valve

(4) An overpressure cutoff device. such as a slam-shut valve or a high-pressure switch in combination withan adequately rated shutoff valve

5.3.2.4 If a pressure relief valve is used to comply with 5.3.2.1. the pressure relief valve and all connectedpiping shall be sized to

ventfully relieve the required volume of gas resulting from the failure of the nearest, upstream pressure regulatorunder the following conditions:

1 . The pressure regulator has failed in the wide open position.

2. The pressure. at which the relief capacity to be sized. shall be based on the protected pressure to thepressure relief valve.

5.3.2.5 The overpressure protection device shall have a pressure rating that is equal to or greater than theprotected pressure to the overpressure protection device.

5.3.2.6 Each gas train. for which an overpressure protection device is required in 5.3.2. 1. shall be designedand installed so that an overpressure condition is detectable.



5.3.1.1_OPD_requirements_.pdf original


Moves the annex requirements in A.5.2.1 (1 0) and provides minimum requirements for properly using and apply overpressure protection devices




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Statement: The committee recognizes the need for overpressure protection requirements where not required byNFPA 54. This new section mostly models the requirements in NFPA 54 for low pressure gas pipingsystem, and the settings are taken from 49 CFR part 192 subpart D paragraph 192.201 “Design ofPipeline Components: Required capacity of pressure relieving and limiting stations”, which areconsidered good engineering practice.


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Public Input No. 1-NFPA 37-2014 [ Section No. 5.4.3 [Excluding any Sub-Sections] ]

The ASSVs shall stop the flow of fuel within 1 second within 2 seconds in the event the engine stops fromany cause. The ASSV shall fail closed without an externally applied source of power.


The change to 2 seconds is to match ANSI Z21.21


Submitter Full Name: Steve Oxtoby

Organization: Kohler Power Systems

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Submittal Date: Tue Oct 07 10:23:41 EDT 2014

Committee Statement


Statement: The change to 2 seconds is to match ANSI Z21.21 for commercial and industrial valves.


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5.4.3.1*

It For prime movers below 400,000 btu/hr and if operating at inlet pressures of 2PSI or less, it shall bepermissible to replace one of the ASSVs required by Section 5.2 with one of the following devices,provided the device will automatically shut off the flow of fuel within 1 second if the engine stops from anycause:

(1) Carburetion valve

(2) Zero governor–type regulating valve

(3) Auxiliary valve


For large engines, it is a very unsafe practice to use a zero governor type regulating valve as an alternative to an ASSV for the following reasons:1) It does not shut off the flow of gas to the engine. The engine must first stop, then the zero governor type regulating valve disc closes in response to the negative pressure signal from the gas engine. There is no "safety" shutoff function in a zero governor regulator, and this type of operation and level of safety is not what is intended in a safety shutoff valve.2) If the diaphragm ruptures, which is the failure mode of zero governor type regulating valves, the failure results in a complete bypass around the closing disc. Thus, they cannot be considered a close-off valves. 3) Moreover, NFPA 37-2010 requires a vent valve when the supply pressure is above 2 PSI. The vent valve acts as a safety device to eliminate the buildup of gas pressure on the downstream valve in the case that the upstream valve leaks. In order for this safety feature to work properly, the downstream shutoff valve must be closed and a tight shutoff-type valve, otherwise, gas flows into the gas engine if the upstream shutoff valve leaks. Relaying on a zero governor regulating valve as the downstream shutoff valve defeats the safety feature of the vent valveIt can be easily be field adjusted to remove open, even if the engine has stopped.4) It can be easily be field adjusted to remove open, even if the engine has stopped. 5) It can also have the atmospheric side backloaded, and this connection can be connected is such a way that when the engine cranks (air pressure in the turbo charger), the zero governor regulator opens because of the air pressure backloading the diaphragm. Such a function defeats safety intended with having two automatic valves closed between the gas engine and the fuel supply.




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Submittal Date: Tue Jul 07 10:06:08 EDT 2015

Committee Statement


Statement: When operating at pressure at 2PSI or less, the risk of damaging the zero governor regulator leadingto leakage downstream is not considered a credible failure mode. The change to 2 seconds wasmade to coordinate with FR #5.


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See Substantation

6.6.3

Piping for fuel tanks, other than engine-mounted tanks, shall be in accordance with the provisions of6.6.3.1 through 6.6.3.3, except as provided for in 6.6.3.4.

6.6.3.1

Piping for fuel tanks shall meet the applicable requirements of Chapters 21 and 27 of NFPA 30, Flammableand Combustible Liquids Code.

6.6.3.2

Tanks shall be filled by a closed piping system.

6.6.3.3

The fill pipe for each tank shall be provided on an exterior wall of the room or structure enclosing the tank ata point at least 600 mm (24 in.) from any building opening at the same or lower level.

6.6.3.4

A fill pipe terminating in accordance with 6.6.3.3 shall not be required for tanks that are filled manually atthe fill connection on the tank, provided that the tank and its fill connection are located within the spillcontainment required by 6.3.2.4, 6.3.5.3, or 6.3.6.3 and the filling operation is constantly attended.



TIA_37-15-1.pdf TIA 37-15-1


NOTE: This public input originates from Tentative Interim Amendment No. 37-15-1 (Log 1102) issued by the Standards Council on 8/14/14 and per the NFPA Regs., needs to be reconsidered by the Technical Committee for the next edition of the Document.

Substantiation and Emergency Nature provided by the TIA submitter:The purpose of this Tentative Interim Amendment (TIA) is to reinstate an important safety provision of earlier editions of NFPA 37 that was inadvertently deleted in the processing of the current 2010 edition. This requirement appears in the prior (2006) edition of NFPA 37 as Subsection 9.3.2..Technical Validity: Proposal 37-20 (Log #CP19) in the Fall 2009 Report on Proposals (ROP) proposed a rewrite of Chapter 9 of NFPA 37. Proposal 37-20 was accepted by the Technical Committee on InternalCombustion Engines and the text being proposed for reinstatement by this TIA appears in the proposal as Subsection 9.3.2. Comment 37-7 (Log #6) proposed amendments to the rewrite of Chapter 9 in the form of anew rewrite of the text beginning with Subsection 9.2.1 and extending to the end of the chapter. This comment also was accepted.Unfortunately, the text of Subsection 9.3.2 from the 2006 edition was not included in the text of the public comment and, therefore, does not appear in the text accepted therein. A poll of the Technical Committee members disclosed that it was never anyone’s intent to delete this provision and all agreed the text needs to be reinstated.This TIA reinstates the provision, numbered accordingly.

Emergency Nature: Failure to properly purge the exhaust system of a gas turbine can result in a significant quantity of fuel remaining in the system. History has shown that this residual fuel can igniteexplosively during turbine light off, resulting in significant damage to the system, including catastrophic rupture of the exhaust system with atten



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Submitter Full Name: TC on INT-AAA

Organization: Technical Committee on Internal Combustion Engines

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Submittal Date: Tue May 05 13:49:27 EDT 2015

Committee Statement


Statement: The committee reaffirms the action of the TIA.


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8.2.3.1 *

Exhaust systems shall terminate outside the structure at a point where hot gases , and sparks , orproducts of combustion will discharge to a safe location. Products of combustion shall discharge at least20 feet from any opening in a structure, such as a window, door, crawl space access at or below gradelevel, or ventilation opening. The distance shall be measured from the generator exhaust systemtermination to the closest point on the structure opening. Exhaust systems shall not terminate understructures (including loading platforms).






NFPA 37, NFPA 70, and UL 2200, Standard for Stationary Engine Generator Assemblies currently deal only with fire and shock hazards; they do not address the CO poisoning hazard related to exhaust emissions. The natural gas and propane engines used in stationary generators have CO emission rates comparable to gasoline-fueled portable generators,1 which have a long history of causing CO poisoning fatalities and injuries when placed outside the home, but close enough to the home to allow the exhaust to infiltrate indoors. NFPA 37 currently allows stationary generators to be located 5 ft. from openings in walls (e.g., windows, doors) and even closer placement, with NO minimum distance, if the adjacent structure wall is fire resistant or the generator enclosure will not ignite


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combustible materials outside the enclosure.

References:










Public Input No. 17-NFPA 37-2015 [Section No. A.8.2.3.1]





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Committee Statement


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Statement: The committee, although charged with the responsibility for the fire safety of the installation, operationand control of internal combustion engines, located in or immediately exposing structures, doesrecognize the concerns made by the submitter, but does not feel that sufficient information is providedwithin the public input to insert the 20 foot separation requirement from the exhaust termination, toopenings in structures, as sufficient support documentation was not provided to support the specifieddistance under all conditions, including wind speed and direction, barometric conditions or whetherthe separation applies to openings around corners of structures.

Furthermore, the committee believes that industry is progressing to towards othersolutions/technologies for reducing the life safety hazards presented by the engine exhaust.

Although the committee did not change the text of section 8.2.3.1, it did revise the wording of therelated appendix section to further highlight the concerns regarding carbon monoxide from the engineexhaust.

The committee welcomes additional information provided by the presenter or other interested partieson this topic.


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Public Input No. 12-NFPA 37-2015 [ Section No. A.4.1.4(2) ]

A.4.1.4(2)

Compliance can be demonstrated by full-scale fire tests or by calculationIt has been demonstrated that, when engines fail, they can generate large fires and cause ignition ofnearby structures.

A.4.1.4 (2) Combustible materials exhibit different levels of combustibility or of ignitability. Examples ofcombustible exterior wall materials include various types of siding, such as vinyl, wood and polypropylene,as well as different exterior wall coverings (such as particleboard), exterior insulation and finish systemsand decorative laminates. It has been shown that these various combustible materials can have verydifferent levels of fire performance or of ignitability (see for example, NFPA 555, Guide on Methods forEvaluating Potential for Room Flashover). Therefore, the full scale fire tests should be conducted in thepresence of combustible materials that adequately represent the potential fire hazard to be expected at thelocation where the engine is to be placed. Moreover, it is advisable that engines located outdoors shouldbe placed at a separation distance from the nearest combustible wall that is greater than the distance atwhich the fire tests have been conducted, to provide a margin of safety.An example of the type of full scalefire tests that have been conducted, which will serve for guidance, can be found in a publication byHirschler (Marcelo Hirschler, “Testing of Residential Electrical Generators”, Fire and Materials Conf., SanFrancisco, CA, Jan. 31-Feb. 2, 2011, pp. 71-81, Interscience Communications, London, UK.)

A.4.1.4 (3) Calculation procedures, such as those given in NFPA 555, Guide on Methods for EvaluatingPotential for Room Flashover , are useful tools to assess the probability of safe engine placement .

The calculating procedure in Chapter 10 of NFPA 555 is similar to the Radiant Ignition of a Near Fuelalgorithm in NIST’s FPETOOL for calculation ignition from a nearby fire. It is a sound, engineering-basedmethod of predicting the risk of ignition from a fire.

The values in 4.1.4and the reference to the NFPA 555 calculation method are the result of the calculationspresented to the committee in 1996. The calculations treated an engine fire as a vertical cylinder. Thevalues in 4.1.4 changed somewhat in the 1998 edition of NFPA 37, based on those calculations. They arereasonably consistent with the requirements of the BOCA building code, which was in effect at the time.The committee wanted to include a performance alternative in NFPA 37 . The reference in this annexsection to the NFPA 555 method provides guidance on how to evaluate proposed alternatives.

(Also add the proposed reference into an annex on informational references).


This is tied to the proposed change to 4.1.4, and further information for conduction of a full scale fire test are proposed to be shown in the body of the standard.









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Submittal Date: Mon Jun 29 13:36:16 EDT 2015

Committee Statement




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Public Input No. 28-NFPA 37-2015 [ New Section after A.5.1.2 ]

A.5.2.x. A Manual reset feature within the safety circuitry is required so that the all high gas conditions canbe identified before other components, such as diaphragms for sensing and control. are damaged byrepeated high-pressure conditions. The manual reset function can be integrated into the high gas switch orbe integrated within the engine controller.









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Committee Statement


Statement: The committee agreed that where a high-pressure limit control trip occurs, the cause should beinvestigated prior to a manual reset. This was moved to chapter 9 to address this as an operationalissue rather than a gas supply issue.


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Public Input No. 35-NFPA 37-2015 [ New Section after A.5.1.2 ]

A.5.1.3 Not installing flexible connectors properly, if used to dampen vibration, and according tomanufacturer's instructions, significant damage to the upstream devices and components can occur, one ofwhich is premature and

catastrophic failure of gas connections. Consider the following when using a flex connector for vibrationdampening.

1. Since most machinery vibrates in a radial direction from the main shaft, the flex hose should be installedparallel to the shaft (i.e. in line with the engine).

2. Install a flex hose in a pre-stress condition (e.g. minimum offset/displacement).

3. Do not install a flexible hose in the gas line and then attempt to pull, compress, or torque in order to alignflex hose into position

4. Piping and the flex hose should be lined up within a maximum of 1/8". If using a flex hose toaccommodate misalignments, an additional or a longer hose may be needed to dampen the vibration.

5. In order for a flex hose to absorb movement, it must be properly anchored. Installing an anchor near thehose at the opposite end of the source of motion is a fundament rule. A flex hose increases flexibility. Thisadded flexibility can result in extreme deflection being applied to both the pipe and the metal hose,potentially adding large forces similar to a "snap-the-whip" action.

6. Piping must be supported by hangers or anchors so that its weight is not carried by the flexible connector.Excessive weight can compress the hose and relax the braid tension.

7. A rigid anchor installed within 4 pipe diameters of the flex hose should be installed to prevent "snap-the-whip" of the upstream components.

8. For best results, add a second anchor within 10 pipe diameters upstream.


Recommend adding annex information to provide special consideration, which are often overlooked, when using flex connectors to dampen vibration.




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Committee Statement


Statement: The committee agreed with the need to anchor connectors used for vibration dampening and hascreated a new section to address this.


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Public Input No. 27-NFPA 37-2015 [ Section No. A.5.2 ]

A.5.2

The requirements in this section state the minimum requirements for compliance with this standard. Thesecontrols and valves are required as part of the prime mover installation and are to be dedicated solely to thesingle individual prime mover. These components of the gas train might or might not be supplied by themanufacturer of the prime mover. Authorities having jurisdiction and manufacturer’s data sheets for gastrain components might have additional requirements. Prior editions of this standard required an automaticcontrol valve, which is an operating component to control the engine under load and not a safety device.Therefore, the requirement for an automatic control valve is no longer within the scope of NFPA 37.

For calculations, the fuel input rating is to be based on the higher heating value (HHV), also called totalheating value, which is the number of British thermal units produced by the combustion, at constant

pressure, of 1 ft3 (0.028 m3) of gas when the products of combustion are cooled to the initial temperatureof the gas and air, when the water vapor formed during combustion is condensed, and when all necessarycorrections have been applied.

The following paragraphs describe the basis for the requirements in this standard that are applicable toeach component of the gas train:

(1) The equipment isolation valve is installed to allow the gas supply to a single prime mover to be shutoff without affecting other equipment. This valve could be used in an emergency, but the primaryapplication is the isolation of the prime mover for maintenance of the prime mover and/or the gas trainwithout a danger of a gas leak.

(2) The regulator provides steady gas pressure to the engine for stable operation. With its own regulator,the prime mover will be less affected by pressure spikes or dips caused by the operation of otherloads in the plant or on the same gas supply system.

(3) The automatic safety shutoff valves (ASSVs) ensure the automatic shutoff of the fuel supply to theprime mover in the event the prime mover stops for any reason or there is a serious fuel or controlproblem.

(4) The manual leak test valve is for periodic testing of the ASSV. An ASSV requires periodic testing(proofing) to verify complete blockage of the gas flow. The ASSV manual leak test valve must beinstalled downstream of but prior to any other device that can block the flow of gas. Somemanufacturers build in proofing provisions for this valve as part of the ASSV; it is permissible to usethis provision for the manual leak test valve if it is located on the downstream side of the ASSV. Amanual leak test valve can consist of a shutoff valve, suitable for the specific fuel, that is capped orplugged when not being used to conduct a leak test.

(5) The low-pressure switch shuts down the engine if the gas pressure to the engine falls below the levelwhere the engine can operate properly, thereby reducing the risk of unburned gas discharge throughthe exhaust. Either a manual or automatic resettable switch is acceptable.

(6) The high-pressure switch (with manual reset) protects against high pressure in the gas supply. Ahigh-pressure condition is usually caused by failure of a component, such as a regulator. Manualreset is required so that the failed component can be identified and replaced before othercomponents, such as diaphragms for sensing and control, are damaged by a repeat high-pressurecondition.

Figure A.5.2 illustrates the typical arrangement of components of a gas train.

Figure A.5.2 Typical Piping Arrangement of a Gas Train.


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Committee Statement


Statement: This revision was made to coordinate with FR 4.


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Public Input No. 32-NFPA 37-2015 [ Section No. A.5.2.1(10) ]

A.5.2.1(10)

An example of an additional component might be an overpressure protection device that protectsdownstream components if the supply pressure exceeds the pressure rating of any such downstreamcomponent. Examples of such overpressure protection devices would be any of the following:

(1) A second regulator in series with the supply pressure regulator

(2) A monitoring regulator installed in series with an operating regulator

(3) A full-capacity pressure relief valve

(4) An overpressure cutoff device, such as a slam-shut valve or a high-pressure switch in combinationwith an adequately rated shutoff valve


Delete annex since annex reuirements in A.5.2.1(10) and move to main body text.




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Committee Statement


Statement: The committee determined that the requirement for manual reset is valid and has revised thedocument to clarify that the manual reset can be done at a control panel.

The annex material in item (10) was moved to the main body of the text (new section 5.6, see FR 11)in order to provide minimum requirements for properly using and applying overpressure protectiondevices.


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Public Input No. 33-NFPA 37-2015 [ Section No. A.5.3.1.2 ]

A.5.3.1.2

A full Lock-up is a feature of some pressure regulators where under no-flow conditions there is a maximumpressure increase downstream of the regulator (aka "lock-up pressure"). This lockup pressure should besignificantly less than the inlet pressure to the regulator under. A lock-up regulator generally permits notmore than 150% of the outlet pressure setting or 5 in. W.C, whichever is a specially designed regulatorthat can shut off tight, thus stopping the flow of gas entirely if the load goes to zero and preventing thedownstream pressure from rising more than 51 mm (2 in.) Hg above the set point greater, however. this canvarv for a given regulator design and application. In addition, there are variables for each regulator designthat affect the lock-up pressure. (e.g. ambient temperature, condition of the regulator disc after some use,flow, inlet pressure, outlet pressure setting, the volume between the regulator and the first downstreamsafety shutoff : valve, the sizing of the regulator, and the length of the atmospheric vent connection, ifvented) .


Propose to add this annex information to aid the industry on what the characteristic of lockup type regulators are and what affects the lockup pressure for a given application.




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Committee Statement


Statement: This change is made to reflect the lock-up requirements in ANSI Z21.80 and the variables that affectlock-up in the given application.


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Public Input No. 17-NFPA 37-2015 [ Section No. A.8.2.3.1 ]

A.8.2.3.1

Exhaust systems should not terminate under structures (including loading platforms) or where exhaust gasentrainment into ventilation intakes might occur.






NFPA 37, NFPA 70, and UL 2200, Standard for Stationary Engine Generator Assemblies currently deal only with fire and shock hazards; they do not address the CO poisoning hazard related to exhaust emissions. The natural gas and propane engines used in stationary generators have CO emission rates comparable to gasoline-fueled portable generators,1 which have a long history of causing CO poisoning fatalities and injuries when placed outside the home, but close enough to the home to allow the exhaust to infiltrate indoors. NFPA 37 currently allows stationary generators to be located 5 ft. from openings in walls (e.g., windows, doors) and even closer placement, with NO minimum distance, if the adjacent structure wall is fire resistant or the generator enclosure will not ignite combustible materials outside the enclosure.

References:


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Public Input No. 16-NFPA 37-2015 [Section No. 8.2.3.1] dependent





Street Address:

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Committee Statement


Statement: The committee, although charged with the responsibility for the fire safety of the installation, operationand control of internal combustion engines, located in or immediately exposing structures, doesrecognize the concerns made by the submitter, but does not feel that sufficient information is providedwithin the public input to insert the 20 foot separation requirement from the exhaust termination, to


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openings in structures, as sufficient support documentation was not provided to support the specifieddistance under all conditions, including wind speed and direction, barometric conditions or whetherthe separation applies to openings around corners of structures.

Furthermore, the committee believes that industry is progressing to towards othersolutions/technologies for reducing the life safety hazards presented by the engine exhaust.

Although the committee did not change the text of section 8.2.3.1, it did revise the wording of therelated appendix section to further highlight the concerns regarding carbon monoxide from the engineexhaust.

The committee welcomes additional information provided by the presenter or other interested partieson this topic.


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Public Input No. 6-NFPA 37-2015 [ Section No. B.1.2 ]

B.1.2 Other Publications.

B.1.2.1 ANSI Publications.

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

ANSI B133.4, Gas Turbine Control and Protection Systems, 2007 (withdrawn 1997) .

ANSI B133.6, Procurement Standard for Gas Turbine Ratings and Performance, 1994 (Out of Print) .

ANSI Z21.21, Automatic Valves for Gas Appliances, 2005 4th edition, 2012 .

B.1.2.2 ASHRAE Publications.

ASHRAE, 1791 Tullie Circle, NE, Atlanta, GA 30329-2305.

ASHRAE, Handbook — Fundamentals, 1997 2013 .

ASHRAE and SFPE, Design Handbook of Smoke Management Systems Control Engineering , 19922012 .

B.1.2.3 ASTM Publications.

ASTM International, 100 Barr Harbor Drive, P.O. Box C700. West Conshohocken, PA 19428-2959.

ASTM SI 10 SI10 , Standard for the Use of the International System of Units (SI): The Modern MetricSystem, 1997 2010 .

B.1.2.4 CSA Publications.

Canadian Standards Association, 5060 Spectrum Way, Mississauga 178 Rexdale Blvd, Toronto , ON, L4W5N6, Canada Canada M9W 1R3 .

CSA B149.6, Code for Digester Gas and Landfill Gas Installations for Piping Materials and Practices, 2011.

B.1.2.5 SAE Publications.

Society of Automotive Engineers SAE International , 400 Commonwealth Drive, Warrendale, PA 15096.

SAE J1349, Engine Power Test Code, Spark Ignition and Compression Ignition, 1990 2011 .

B.1.2.6 UL Publications.

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

UL 2080, Fire Resistant Tanks for Flammable and Combustible Liquids, 2000.

UL 2085, Protected Aboveground Tanks for Flammable and Combustible Liquids, 1997, revised 2010.


Referenced current SDO names, standard names, and years.



Public Input No. 5-NFPA 37-2015 [SectionNo. 2.3]

Referenced current SDO names, addresses, standard names,and years.

Public Input No. 4-NFPA 37-2015 [GlobalInput]




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Committee Statement


Statement: Updated to current references.


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Public Input No. 30-NFPA 37-2015 [ Section No. B.2 ]

B.2 Informational References. (Reserved)

Marcelo Hirschler, “Testing of Residential Electrical Generators”, Fire and Materials Conf., San Francisco,CA, Jan. 31-Feb. 2, 2011, pp. 71-81, Interscience Communications, London, UK.


The reference proposed to be added by PI 12.









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Documents

Statement of Problem and Substantiation for Public Input ... Input No. 4-NFPA 37-2015 [ Global Input ] Throughout standard remove references to the following and replace with the following: