Technical Committee on Gas Process Safety Committee on Gas Process Safety Date: May 6, 2011 To: Technical Committee on Gas Process Safety From: Denise Beach, Staff Liaison/Senior Engineer

Technical Committee on Gas Process Safety

Date: May 6, 2011 To: Technical Committee on Gas Process Safety From: Denise Beach, Staff Liaison/Senior Engineer Re: Agenda Package – Document Development Meeting Part II Enclosed is the agenda package for the May 10-12, 2011 meeting. Please ensure that you have reviewed the attachments in advance as we intend to go through the draft document in detail. The agenda and attachments will be posted on the document information page, www.nfpa.org/56. If you have any questions or comments, please feel free to reach me at (617) 984-7501 or by e-mail at [email protected]. Members who cannot attend this meeting are encouraged to forward any concerns about the draft or the standard in general in the form of written comments to Denise Beach. Meeting notes and findings will be forwarded to all TC members promptly following completion of the meeting. Task Groups will be posted and open to those members who cannot attend.

http://www.nfpa.org/56�

Technical Committee on Gas Process Safety

AGENDA

NFPA Headquarters Quincy, MA

May 10-12, 2011 1. Chair’s welcome, call to order, and opening remarks at 9:00 a.m. EDT. 2. Roll call of Committee Members and Guests 3. Staff Liaison Report A. Committee membership (Attachment A) B. NFPA Policies and Regulations 4. Approval of the minutes of the April 5-7, 2011 meeting. 5. Review Committee and Document Scope – Following the last meeting, an internal

NFPA review of the draft committee and document scope resulted in recommendations for further modifications. (Attachment B)

6. U.S. Chemical Safety Board Q&A Regarding Use of Flammable Gas for PIG Cleaning Procedure

7. Review draft standard NFPA 56 (Attachment C) A. Purging Procedures Task Group Report B. Complete document review 8. Review of written comments – Due to time constraints, the committee did not

specifically review all of the written comments previously submitted (Attachment D). Following the last meeting, additional written comments were solicited from impacted NFPA committees (Attachment E). While these comments are not required to be formally addressed, the committee should review and provide an informal response to each submitter.

9. Document timeline/set up Task Groups/next steps. 10. Date/Location of Next Meeting. A follow-up meeting to continue review of the draft

has been tentatively scheduled for June 8-9, 2011. The Committee should identify a convenient location or solicit a host site.

11. Adjournment.

Attachment A: Committee Roster

Address List 5/6/2011

Gas Process Safety GPS-AAADenise Beach

Glenn Mahnken

GPS-AAAChairFM Global1151 Boston-Providence TurnpikeNorwood, MA 02062-9102Alternate: Michael C. Polagye

Phone/Cell: 781-255-4727Fax: 781-551-9775Email : [email protected]

I 3/1/2011 Bernhard G. Bischoff

GPS-AAAPrincipalUTC/Chemetron Fire Systems4801 Southwick Drive, 3rd FloorMatteson, IL 60443


M 3/1/2011

Leon A. Bowdoin, Jr.

GPS-AAAPrincipalHess LNG/Weaver’s Cove EnergyOne New StreetFall River, MA 02720

Phone/Cell: 777-488-3872 508-404-8535Fax: 508-675-9483Email : [email protected]

U 3/1/2011 Christopher S. Buehler

GPS-AAAPrincipalExponent, Inc.10850 Richmond Avenue, Suite 175Houston, TX 77007


SE 3/1/2011

Paul W. Cabot

GPS-AAAPrincipalAmerican Gas Association400 North Capitol Street, NWWashington, DC 20001


IM 3/1/2011 Lawrence M. Danner

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


M 3/1/2011

Dan Dorran

GPS-AAAPrincipalAtlas Copco Rental850 West Pine AvenueHermiston, OR 97838-2212


U 3/1/2011 Sean P. George

GPS-AAAPrincipalSteamfitters LU 449-Pittsburgh1459 Woodruff StreetPittsburgh, PA 15220


L 3/1/2011

Kevin W. Gordon

GPS-AAAPrincipalNextEra Energy/Florida Power & Light Company700 Universe Blvd., JSA/JBJuno Beach, FL 33408

Phone/Cell: 561-691-2851Fax:Email : [email protected]

U 3/1/2011 Kreg J. Levengood

GPS-AAAPrincipalBlack & Veatch Corporation1027 North Old Mill RoadIndependence, MO 64056


SE 3/1/2011

1

Address List 5/6/2011

Gas Process Safety GPS-AAADenise Beach

Daniel E. Michael

GPS-AAAPrincipalNucor Steel4537 South Nucor RoadCrawfordsville, IN 47933


U 3/1/2011 Robert C. Naper

GPS-AAAPrincipalEnergy Experts International2 Anthony WayCanton, MA 02021-3559ANSI Gas Piping Technology Committee


SE 3/1/2011

John R. Puskar

GPS-AAAPrincipalCEC Combustion Safety, Inc.11699 Brookpark RoadCleveland, OH 44130


SE 3/1/2011 Alan Rice

GPS-AAAPrincipalChartis Insurance, Global Marine & EnergyOne State Street, 8th FloorHartford, CT 06103


I 3/1/2011

Bruce J. Swiecicki

GPS-AAAPrincipalNational Propane Gas Association21200 South LaGrange Road, Suite 353Frankfort, IL 60423


IM 3/1/2011 Peter J. Willse

GPS-AAAPrincipalXL Global Asset Protection Services100 Constitution Plaza, 12th FloorHartford, CT 06103

Phone/Cell: 860-293-7900 860-460-1965Fax: 860-293-7907Email : [email protected]

I 3/1/2011

Robert G. Zalosh

GPS-AAAPrincipalFirexplo20 Rockland StreetWellesley, MA 02481


SE 3/1/2011 Michael C. Polagye

GPS-AAAAlternateFM GlobalEngineering Standards1151 Boston-Providence TurnpikePO Box 9102Norwood, MA 02062-9102Principal: Glenn Mahnken


I 3/1/2011

Denise Beach

GPS-AAAStaff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169-7471


12/1/2010

2

Attachment B: Revised Committee

Scope

GPS-AAA Committee Scope: This committee shall have primary responsibility for documents on the commissioning and maintenance of flammable gas piping systems used in commercial, industrial, and power plant applications, extending from the point of delivery to the equipment isolation or shutoff valve. Where commissioning and maintenance requirements are already covered by the NFPA National Fuel Gas Code and/or the NFPA Hydrogen Technologies Code, requirements shall be extracted from those documents.

Attachment C: Draft Document

NFPA 56PS

For NFPA GPS Committee Work Only. Prepared by D. Beach. Updated 5/6/2011.

NFPA® 56PS

Provisional Standard for the

the Commissioning and Maintenance

of Flammable Gas Piping Systems

2012 Edition

NFPA and National Fire Protection Association are registered trademarks of the National Fire Protection Association, Quincy, Massachusetts 02169.

Copyright © 2012 National Fire Protection Association®. All Rights Reserved.

NFPA 56 (PS) Provisional Standard for the Commissioning and Maintenance

of Flammable Gas Piping Systems

IMPORTANT NOTE: This NFPA document is made available for use subject to important notices and legal disclaimers. These notices and disclaimers appear in all publications containing this document and may be found under the heading “Important Notices and Disclaimers Concerning NFPA Documents.” They can also be obtained on request from NFPA or viewed at www.nfpa.org/disclaimers. NOTICE: An asterisk (*) following the number or letter designating a paragraph indicates that explanatory material on the paragraph can be found in Annex A. Changes other than editorial are indicated by a vertical rule beside the paragraph, table, or figure in which the change occurred. These rules are included as an aid to the user in identifying changes from the previous edition. Where one or more complete paragraphs have been deleted, the deletion is indicated by a bullet (•) between the paragraphs that remain. A reference in brackets [ ] following a section or paragraph indicates material that has been extracted from another NFPA document. As an aid to the user, the complete title and edition of the source documents for extracts in mandatory sections of the document are given in Chapter 2 and those for extracts in informational sections are given in Annex B. Extracted text may be edited for consistency and style and may include the revision of internal paragraph references and other references as appropriate. Requests for interpretations or revisions of extracted text shall be sent to the technical committee responsible for the source document.


Information on referenced publications can be found in Chapter 2 and Annex B.

Chapter 1 Administration

1.1 Scope. 1.1.1 Applicability. This standard applies to commissioning and maintenance procedures for flammable gas piping found in electric-generating plant, industrial and commercial applications. 1.1.1.1* Coverage of piping systems shall extend from the point of delivery to the gas-consuming equipment isolation valve. (A) For other than undiluted liquefied petroleum gas (LP-Gas) systems, the point of delivery shall be considered to be 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. (B) For undiluted LP-Gas, the point of delivery shall be considered to be the outlet of the final pressure regulator, exclusive of line gas regulators, in the system. (C) For facilities that produce flammable gas for consumption on site, the point of delivery shall be considered to be the discharge isolation valve for the gas producing equipment.

1.1.2 Nonapplication of Standard. This code shall not apply to the following items: 1.1.1.2* The minimum operating pressure shall be 2 psig (14 kPa).

(1)* Design and installation of

(2)*

piping systems covered by NFPA 54, National Fuel Gas Code

Design and installation

(3)*

of piping systems covered by NFPA 2, Hydrogen Technologies Code

Design and installation of piping systems at utility LP-Gas plants covered by

(4)* Design and installation of piping systems in LNG facilities covered by LNG Facilities covered by NFPA 59A, Standard for the Production, Storage and Handling of Liquefied Natural Gas

LP-Gas (including refrigerated storage) at utility gas plants (see NFPA 59, Utility LP-Gas Plant Code)

(5) Design and installation of piping systems for LP-Gas used with

(6)* Vehicle fuel dispensers

oxygen-fuel gas systems for cutting, welding or other hot work covered by NFPA 51, Standard for the Design and Installation of Oxygen-Fuel Gas Systems for Welding, Cutting, and Allied Processes

(7) Gas piping, meters, gas pressure regulators, and other appurtenances used by the serving gas supplier in distribution or transmission of gas other than undiluted LP-Gas (8) Commissioning and maintenance of appliances or equipment

1.1.2.1 Where commissioning or maintenance activities are covered by a code or standard listed in 1.1.2, the requirements shall be extracted into this standard.

1.2 Purpose. This standard provides minimum safety requirements for the commissioning and

1.1.2.2 Where a conflict exists between the extracted requirement of this standard and the source document, the requirements of the source document shall apply.


maintaining of flammable gas piping systems, including cleaning new or repaired piping systems, placing piping systems into service, and removing piping systems from service.

1.2.1 For the purposes of this document, a piping system shall be understood to mean a complete piping system, including valves, regulators and other appurtenances, and any segment thereof that can be isolated from the system.

1.3 Retroactivity. The provisions of this standard reflect a consensus of what is necessary to provide an acceptable degree of protection from the hazards addressed in this standard at the time the standard was issued.

1.3.1 Unless otherwise specified, the provisions of this standard shall not apply to facilities, equipment, structures, or installations that existed or were approved for construction or installation prior to the effective date of the standard; where specified, the provisions of this standard shall be retroactive.

1.3.2 In those cases where the authority having jurisdiction determines that the existing situation presents an unacceptable degree of risk, the authority having jurisdiction shall be permitted to apply retroactively any portions of this standard deemed appropriate.

1.3.3 The retroactive requirements of this standard shall be permitted to be modified if their application clearly would be impractical in the judgment of the authority having jurisdiction and only where it is clearly evident that a reasonable degree of safety is provided.

1.4 Equivalency. The provisions of this code are not intended to prevent the use of systems, methods, or devices of equivalent or superior quality, strength, fire resistance, effectiveness, durability, and safety over those prescribed by this standard.

1.4.1 Technical documentation shall be submitted to the authority having jurisdiction to demonstrate equivalency.

1.4.2 The system, method, or device shall be approved for the intended purpose by the authority having jurisdiction.

Chapter 2 Referenced Publications

2.1 General. The documents or portions thereof listed in this chapter are referenced within this standard and shall be considered part of the requirements of this document.

2.2 NFPA Publications. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471. NFPA 54, National Fuel Gas Code, 2009 edition. NFPA 58, Liquefied Petroleum Gas Code, 2008 edition.

2.3 Other Publications. 2.3.1 ASME Publications. American Society of Mechanical Engineers, Three Park Avenue, New York, NY 10016-5990.


ANSI/ASME Boiler and Pressure Vessel Code, 2007. ANSI/ASME B31.1, Power Piping, 2008. ANSI/ASME B31.3, Process Piping, 2002. 2.3.2 Other Publications. Merriam-Webster’s Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, 2003.

2.4 References for Extracts in Mandatory Sections. NFPA 30, Flammable and Combustible Liquids Code, 2008 edition. NFPA 55, Compressed Gases and Cryogenic Fluids Code, 2010 edition. NFPA 85, Boiler and Combustion Systems Hazards Code, 2007 edition.

Chapter 3 Definitions

3.1 General. The definitions contained in this chapter shall apply to the terms used in this standard. Where terms are not defined in this chapter or within another chapter, they shall be defined using their ordinarily accepted meanings within the context in which they are used. Merriam-Webster’s Collegiate Dictionary, 11th edition, shall be the source for the ordinarily accepted meaning.

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, or for 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 an organization 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 labeling the 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 the authority having jurisdiction and concerned with evaluation of products or services, that maintains periodic inspection of production of listed equipment or materials or periodic evaluation of services, and whose listing states that either the equipment, material, or service meets appropriate designated standards or has been 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.

3.3 General Definitions. 3.3.1 Bulk Gas System. A system in which compressed gas is delivered, stored, and discharged in the gaseous form to a piping system. 3.3.2* Competent Person. One who is capable of identifying existing and predictable hazards in


the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them. 3.3.3 Engines. Prime movers such as internal combustion engines, external combustion engines, gas turbine engines, rotary engines, and free piston engines using either gaseous fuels or liquid fuels or combinations thereof. [NFPA 37, 2010] 3.3.4 Equipment Isolation Valve. A manual shutoff valve for shutoff of the flammable gas to each piece of equipment. 3.3.5* Inert Gas. A nonreactive, nonflammable, noncorrosive gas such as argon, helium, krypton, neon, nitrogen, and xenon. [NFPA 55, 2010] 3.3.6* Line Gas Regulator. A pressure regulator placed in a gas line between the service regulator and the appliance regulator. 3.3.7 Pipeline Inspection Gauge (PIG). A scraping tool that is forced through a pipe or flow line to clean out accumulations of dirt, scale, and debris from the walls of the pipe. 3.3.8 Prime Mover. An initial source of motive power used to drive machinery. 3.3.9 Purge. To free a gas conduit of air or gas, or a mixture of gas and air. [54, 2012] 3.3.9.1 Purge into Service. The act of replacing the air or inert gas in a closed system by a flammable gas. 3.3.9.2 Purge out of Service. The act of replacing the normal flammable content of a closed system by inert gas, air or water.

Chapter 4 — General Requirements

4.1 Piping System Construction. Flammable gas piping systems shall be constructed in accordance with ASME B31.1, Power Piping; ASME B31.3, Process Piping; or NFPA 54, National Fuel Gas Code, as applicable.

4.2 Notification of Hazards. Personnel in the affected area(s), as determined by the process hazard analysis, who are not directly involved with the commissioning or maintenance of flammable gas piping systems shall be informed of the hazards associated with the activity prior to the initiation of any such activity.

4.3* Process Hazard Analysis. Commissioning and maintenance procedures shall include a process hazard analysis for each activity.

4.3.1 The process hazard analysis for each commissioning or maintenance activity shall address the following, as a minimum:

(1) Release or disposal of fluids

(2) Ignition Sources – static electricity and grounding

(3) Personnel safety and training

(4) Nonessential personnel evacuation

(5) Warnings/Alarms


(6) Emergency Response

(7) Restricted access to affected area

(8) Scope of work

(9) Notification of AHJ

(10) Well-defined responsibilities

(11) Assignment of duties

(12) Authority to shutdown

(13) Safety officers

(14) Review and compliance plans for other standards/regulations

(15) Monitoring of affected area during discharge

(16) Communication plans

(17) Management of Change

(18) Accurate Piping and Instrument Drawings

(19) Hot Work Permits

(20) Lockout/Tagout procedures

(21) Operation procedures

(22) Personal Protective Equipment

(23) Control of point of discharge

(24) Weather monitoring

(25) Air traffic

(26) Restoration of Service

(27) Complexity of the piping system

(28) Purge media Reynold’s number

(29) Method of Purge

(30) Instrumentation/Sample Points and Techniques for Monitored Stream

Chapter 5 — Training Requirements


5.1 Persons whose duties fall within the scope of this standard shall be provided with training that is consistent with the scope of their job activities.

5.1.1 Such training shall include hazards of flammable gas, hazards of any compressed gas used for cleaning or purging, safe handling practices of flammable gas and compressed gas as applicable, emergency response procedures, and company policy.

5.1.2 Personnel training shall be supervised by a competent person and shall be documented.

5.1.3 Training records shall be maintained for a period not less than 5 years from the date of completion of the activity.

Chapter 6 — Commissioning

6.1 General.

6.1.1 Commissioning of flammable gas piping shall include all pressure testing, cleaning, and flammable gas charging by the owner/operator or designated contractor(s).

6.1.2 Commissioning procedures shall be developed and implemented by a competent person.

6.1.3 Commissioning procedures shall be documented.

6.1.4 Commissioning shall occur when piping system construction is complete.

6.1.4.1 Piping system segments that can be isolated for cleaning prior to completion of the entire piping system shall be permitted to be cleaned, tested, and secured in a clean condition in accordance with Section 6.3.

6.1.4.2 Hangers, supports, or other means capable of restricting the movement of piping shall be installed prior to initiating commissioning activities in accordance with the process hazard analysis.

6.1.5* Fluid media for testing or cleaning shall not introduce a flammable atmosphere into or create a fire hazard in the piping system being tested or cleaned.

6.1.6 Where utilities such as steam, water, or compressed air are used for commissioning activities in quantities or duration that can disrupt distribution or operations internal or external to the facility, commissioning activities shall be coordinated with the managing authority of the utility.

6.1.7 Personnel not involved in the commissioning shall be evacuated from the affected area(s) as determined by the process hazard analysis.

6.1.8 Access to all parts of the piping system during commissioning activities shall be restricted in accordance with the process hazard analysis.

6.2* Pressure Testing and Inspection. Prior to cleaning or being charged with flammable gas, piping systems shall be inspected and pressure tested to determine that the materials, design, fabrication, and installation practices comply with the requirements of this standard and the


intended application.

6.2.1 Pressure testing and inspection procedures shall be documented.

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

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

6.2.4* Where piping is designed and constructed in accordance with ASME B31.3, leak testing and inspection shall be in accordance with Chapter VI of ASME B31.3.

6.2.5* Where pneumatic testing is conducted in accordance with B31.1 or B31.3, the test medium shall be air, carbon dioxide, or an inert gas. Oxygen shall never be used.

6.2.6 Where repairs or additions are made following the pressure test, the affected piping shall be tested in accordance with NFPA 54, ASME B31.1, or ASME B31.3, as applicable.

6.2.7* A piping system shall be tested as a complete unit or in sections. Under no circumstances shall a valve in a line be used as a bulkhead between flammable gas in one section of the piping system and test medium in an adjacent section, unless a double-block-and-bleed valve system is utilized.

6.2.8* A valve, including the valve closing mechanism, or component shall not be subjected to the test pressure unless it can be determined that the valve or component is designed to safely withstand the pressure.

6.2.9 Regulator and valve assemblies fabricated independently of the piping system in which they are to be installed shall be permitted to be tested with inert gas or air at the time of fabrication. [54, 8.1.1.6]

6.3 Cleaning of Flammable Gas Piping.

6.3.1 General.

6.3.1.1 Flammable gas shall not be used for internal cleaning of piping systems except as permitted by 6.3.5.

6.3.1.2 An alarm shall precede the start of cleaning in accordance with the process hazard analysis.

6.3.2* Acceptable Fluid Media. Air, inert gas, steam, or water shall be acceptable cleaning media except as permitted by 6.3.5.

6.3.3 Temporary Power/Fuel Supply

6.3.3.1 Where electric power is used as the prime mover for the cleaning media supply system, it shall be connected in accordance with NFPA 70, National Electric Code.

6.3.3.2 Where fuel gas is used as the fuel for the cleaning media supply system, it shall be piped and connected in accordance with NFPA 54, National Fuel Gas Code or NFPA 58, Liquefied Petroleum Gas Code, as applicable.


6.3.3.3 Where fuel oil is used as the fuel for the cleaning media supply system, it shall be piped and connected in accordance with NFPA 31, Standard for the Installation of Oil-Burning Equipment.

6.3.4 Temporary Piping (Including Hose Assemblies). Temporary piping systems, including hose assemblies, used to connect cleaning media supply source to the piping system shall be in accordance with ASME B31.1 Paragraph 122.10.

6.3.5 Pipeline Inspection Gauge Cleaning. A pipeline inspection gauge (PIG) shall be permitted to be used to clean piping systems.

6.3.5.1 The fluid used to propel the PIG through the piping system shall be permitted to be water, steam, air, inert gas, or flammable gas.

6.3.5.2 PIG Cleaning using flammable gas as the propellant shall be limited to piping between the point of delivery and the plant boundary.

6.3.6 Point of Discharge During Cleaning Process.

6.3.6.1 Target. Where a target is used to indicate debris during the cleaning process, it shall be designed and secured to withstand the velocity and pressure of the exiting media and debris without breaking or failing.

6.3.6.2 The point of discharge location shall be determined based on the following criteria:

(1) personnel

(2) important buildings/building openings

(3) vehicles/vehicular traffic

(4) ignition sources

(5) atmospheric conditions

(6) design/location of target, if used

(7) topography

(8) discharge fluid characteristics

(9) Noise transmission to neighbors

(10) Management of Change

(11) Breathing air displacement/asphyxiation or toxicity hazard

(12) Location of Instrumentation and Controls

6.4 Isolation and Protection of Clean Piping Systems or Segments. Where piping systems are cleaned in stages during fabrication or field assembly, the clean piping shall be isolated and protected against infiltration of dirt or debris.

6.5 Charging Piping System with Flammable Gas. 6.5.1 Where gas piping containing air is placed in operation, the air in the piping first shall be


displaced with an inert gas, which shall then be displaced with flammable gas in accordance with Section 6.5.2, except as permitted by 6.5.1.2.

6.5.1.1 Inert gas displacement shall result in an oxygen concentration in the piping system of not more than 60 percent of the limiting oxidant concentration as determined in accordance with NFPA 69, Section 7.2.3.

6.5.1.2 Piping systems between the point of delivery and the plant boundary shall be permitted to be purged into service without an intermediate media when a Process Hazard Analysis meeting the requirements of 4.3 indicates that a Reynold’s number above x,xxx will be maintained throughout the purging process.

6.5.1.2.1* When a piping system is purged into service without the use of an intermediate inert media, the purging process shall performed continuously until 90% flammable gas by volume is detected within the pipe at the discharge location or the connection point to the discharge piping or stacks where used to vent the purge gases outdoors.

6.5.2 Outdoor discharge of purged gases. 6.5.2.1 Where the operating pressure of a natural gas piping system is between 2 psig and 125 psig or the operating pressure of an LP-Gas system is between 2 psig and 20 psig, the discharge of purge gases shall be in accordance with 6.5.2.1.1.

6.5.2.1.1 Outdoor Discharge of Purged Gases. The open end of a piping system being pressure vented or purged shall discharge directly to an outdoor location. Purging operations shall comply with all of the following requirements:

(1) The point of discharge shall be controlled with a shutoff valve.

(2) The point of discharge shall be located at least 10 ft (3.0 m) from sources of ignition, at least 10 ft (3.0 m) from building openings and at least 25 ft (7.6 m) from mechanical air intake openings.

(3) During discharge, the open point of discharge shall be continuously attended and monitored with a combustible gas indicator that complies with 6.5.3.

(4) Purging operations introducing fuel gas shall be stopped when 90 percent fuel gas by volume is detected within the pipe.

(5) Persons not involved in the purging operations shall be evacuated from all areas within 10 ft of the point of discharge. [NFPA54: 8.3.1.3]

6.5.2.2 Where a flammable gas piping system is not covered by 6.5.2.1, the discharge of purge gases shall be in accordance with 6.5.2.2.

6.5.2.2.1 The open end of a piping system being pressure vented or purged shall discharge directly to an outdoor location.

6.5.2.2.2 Purging operations shall comply with the requirements in 6.5.2.2.2.1 through 6.5.2.2.2.5.

6.5.2.2.2.1 The point of discharge shall be controlled with a shutoff valve.

6.5.2.2.2.2 The point of discharge shall be located at least 10 feet from sources of ignition, at least 10 feet from building openings and at least 25 feet from mechanical air intake openings.

6.5.2.2.2.3 During discharge, the open point of discharge shall be continuously attended and monitored with a combustible gas indicator that complies with Section 6.5.3.


6.5.2.2.2.4 Purging operations introducing flammable gas shall be stopped when 90% flammable gas by volume is detected within the pipe.

6.5.2.2.2.5 Persons not involved in the purging operations shall be evacuated from all areas within 10 ft (3.1 m) of the point of discharge.

6.5.3 Combustible Gas Indicators. 6.5.3.1 Combustible gas indicators shall be listed and calibrated in accordance with the manufacturer’s instructions. [NFPA 54:8.3.1.4]

6.5.3.2 Combustible gas indicators shall numerically display a volume scale from 0 to 100 percent in 1 percent or smaller increments. [NFPA 54:8.3.1.4]

Chapter 7 — Maintenance

7.1 Isolation. Flammable gas piping shall be isolated from the flammable gas supply and downstream piping and equipment prior to maintenance.

7.2 Charging with Inert Gas. Where existing gas piping is opened, the section that is opened shall be isolated from the gas supply and the residual flammable gas in the piping shall be displaced with an inert gas.

7.2.1 Inert gas supply shall be in accordance with Section 6.3.2, 6.3.3, and 6.3.4.

7.2.2 Piping systems between the point of delivery and the plant boundary shall be permitted to be purged out of service without an intermediate media when a Process Hazard Analysis meeting the requirements of 4.3 indicates that a Reynold’s number above x,xxx will be maintained throughout the purging process.

7.2.2 Outdoor Discharge of Residual Flammable Gas.

7.2.2.1 * When a piping system is purged out of service without the use of an intermediate inert media, the purging process shall performed continuously until 90% air by volume is detected within the pipe at the discharge location or the connection point to the discharge piping or stacks where used to vent the purge gases outdoors.

7.2.2.1 Where the operating pressure of a natural gas piping system is between 2 psig and 125 psig or the operating pressure of an LP-Gas system is between 2 psig and 20 psig, the discharge of purge gases shall be in accordance with 7.2.2.1.1.

7.2.2.1.1 Outdoor Discharge of Purged Gases. The open end of a piping system being pressure vented or purged shall discharge directly to an outdoor location. Purging operations shall comply with all of the following requirements:

(1) The point of discharge shall be controlled with a shutoff valve.

(2) The point of discharge shall be located at least 10 ft (3.0 m) from sources of ignition, at least 10 ft (3.0 m) from building openings and at least 25 ft (7.6 m) from mechanical air intake openings.

(3) During discharge, the open point of discharge shall be continuously attended and monitored with a combustible gas indicator that complies with 6.5.3.

(4) Purging operations introducing fuel gas shall be stopped when 90 percent fuel gas by volume is


detected within the pipe.

(5) Persons not involved in the purging operations shall be evacuated from all areas within 10 ft of the point of discharge. [NFPA54: 8.3.1.3] 7.2.2.2 Where a flammable gas piping system is not covered by 7.2.2.1, the discharge of purge gases shall be in accordance with 7.2.2.2. 7.2.2.2.1 The open end of a piping system being pressure vented or purged shall discharge directly to an outdoor location.

7.2.2.2.2 Purging operations shall comply with the requirements in 7.2.2.2.2.1 through 7.2.2.2.2.5.

7.2.2.2.2.1 The point of discharge shall be controlled with a shutoff valve.

7.2.2.2.2.2 The point of discharge shall be located at least 10 feet (3.1 m) from sources of ignition, at least 10 feet from building openings and at least 25 feet from mechanical air intake openings.

7.2.2.2.2.3 During discharge, the open point of discharge shall be continuously attended and monitored with a combustible gas indicator that complies with Section 6.5.3.

7.2.2.2.2.4 Purging operations introducing inert gas shall be stopped when the flammable gas level (by volume) detected within the pipe and within a 5 ft (1.5 m) radius of the point of discharge is less than 25 percent of the lower flammable limit.

7.2.2.2.2.5 Persons not involved in the purging operations shall be evacuated from all areas within 10 ft (3.1 m) of the point of discharge.

7.3 Inert Gas Disposal.

7.3.1 Following charging with inert gas, the piping system shall be permitted to be opened to atmosphere or charged with air.

7.3.2 Inert gas shall be permitted to be released indoors where mechanical ventilation is activated to prevent displacement of breathable air.

7.3.2.1 Where inert gas is released indoors, an oxygen monitoring system shall be installed in the area and activate audible and visual alarms if oxygen levels fall below 19.5 percent by volume.

7.4 Hot Work Safety. Cutting, welding and allied processes shall be in accordance with NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and other Hot Work.

7.4.1 Prevention of Accidental Ignition. Where work is being performed on piping that has contained gas, the following shall apply:

7.4.1.1 Provisions for electrical continuity shall be made before alterations are made in a metallic piping system.

7.4.1.2 Smoking, open flames, lanterns, or other sources of ignition shall not be permitted.

7.4.1.3 A metallic electrical bond shall be installed around the location of cuts in metallic gas pipes made by other than cutting torches.

7.4.1.3.1 Where cutting torches, welding, or other sources of ignition are unavoidable, it shall be


determined that all sources of gas or gas–air mixtures have been secured and that all flammable gas or liquids have been cleared from the area.

7.4.1.3.2 Piping shall be charged with inert gas in accordance with 7.2 before welding or cutting with a torch is attempted.

7.4.1.4 Artificial illumination shall be restricted to listed safetytype flashlights and safety lamps, and electric switches shall not be operated, on or off. [54: 4.3.1]

7.5 Returning to Service. Flammable gas piping shall be returned to service in accordance with Section 6.5.

7.5.1 Returning affected equipment to service shall be in accordance with the manufacturer’s instructions and good engineering practice.

Chapter 8 Special Problems

8.1 Reserved.

Annex A Explanatory Material Annex A is not a part of the requirements of this NFPA document but is included for informational purposes only. This annex contains explanatory material, numbered to correspond with the applicable text paragraphs. A.1.1.1.1 The piping system includes segments that can be located between pieces of equipment, such as gas conditioning or compressing equipment. This document does not cover the commissioning or maintaining of that equipment. This document covers the commissioning or maintaining of those piping segments and equipment as a system as it relates to the flow or displacement of flammable gas. The equipment isolation valve is intended to be the final isolation valve prior to the manufacturer’s or supplier’s equipment gas train. For some common pieces of equipment in NFPA Standards, the isolation valve is identified and referenced as follows: (1) NFPA 37, Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines, uses the term “shutoff valve”, referenced in section 5.4.2. (2) NFPA 85, Boiler and Combustion Systems Hazards Code, uses the term manual shutoff valve referenced in Figure A.5.3.2.3 for single burner boilers, Figure A.6.6.5.1.5.4(A) and (B) for multiple burner boilers, and Figure A.8.8.5.8(A), (B), and (C) for heat recovery steam generators. (3) NFPA 86, Standard for Ovens and Furnaces, uses the term equipment isolation valve, referenced in section 6.2.3.4 (4) NFPA 87, Recommended Practice for Fluid Heaters, uses the term equipment isolation valve referenced in section 6.2.4.3

A.1.1.2(1) The scope of NFPA 54, National Fuel Gas Code, is included here for the convenience of the user.

A.1.1.1.2 Systems that have normal operating pressures of less than 2 psig (14 kPa) but that may experience excursions above 2 psig (14 kPa) are outside the scope of this standard.

1.1 Scope.


1.1.1 Applicability. 1.1.1.1 This code is a safety code that shall apply to the installation of fuel gas piping systems, appliances, equipment, and related accessories as shown in 1.1.1.1(A) through 1.1.1.1(D). (A) Coverage of piping systems shall extend from the point of delivery to the appliance connections. For other than undiluted liquefied petroleum gas (LP-Gas) systems, the point of delivery shall be considered to be the outlet of the service meter assembly or the outlet of the service regulator or service shutoff valve where no meter is provided. For undiluted LP-Gas, the point of delivery shall be considered to be the outlet of the final pressure regulator, exclusive of line gas regulators, in the system. (B) The maximum operating pressure shall be 125 psi (862 kPa). Exception No. 1: Piping systems for gas–air mixtures within the flammable range are limited to a maximum pressure of 10 psi (69 kPa). Exception No. 2: LP-Gas piping systems are limited to 20 psi (140 kPa), except as provided in 5.5.1(6). (C) Requirements for piping systems shall include design, materials, components, fabrication, assembly, installation, testing, inspection, operation, and maintenance. (D) Requirements for appliances, equipment, and related accessories shall include installation, combustion, and ventilation air and venting.

A.1.1.2(3) The scope of NFPA 2, Hydrogen Technologies Code, is included here for the convenience of the user.

1.3* Application. 1.3.1 This code shall apply to the production, storage, transfer, and use of hydrogen in all occupancies and on all premises. 1.3.2 The use of hydrogen shall include stationary, portable, and vehicular infrastructure applications. 1.3.3 The fundamental requirements of Chapters 1 through 8 shall apply in addition to the use-specific requirements provided in Chapters 9 through 20, as applicable. 1.3.4 Exemptions. This code shall not apply to the following: (1)Onboard vehicle or mobile equipment components or systems, including the onboard GH2 or LH2 fuel supply (2)Mixtures of GH2 and other gases with a hydrogen concentration of less than 95 percent by volume when in accordance with NFPA 55, Compressed Gases and Cryogenic Fluids Code (3)The storage, handling, use, or processing of metal hydride materials outside of metal hydride storage systems defined in Chapter 3

A.1.1.2(3) The scope of NFPA 59, Liquefied Petroleum Gas at Utility Gas Plants, is included here for the convenience of the user.

1.1 Scope. 1.1.1* This code shall apply to the design, construction, location, installation,


operation, and maintenance of refrigerated and nonrefrigerated utility gas plants. Coverage of liquefied petroleum gas systems at utility gas plants shall extend to the point where LP-Gas or a mixture of LP-Gas and air is introduced into the utility distribution system. 1.1.2 When operations that involve the liquid transfer of LP-Gas from the utility gas plant storage into cylinders or portable tanks (as defined by NFPA 58, Liquefied Petroleum Gas Code) are carried out in the utility gas plant, these operations shall conform to NFPA 58, Liquefied Petroleum Gas Code. 1.1.3 Installations that have an aggregate water capacity of 4000 gal (15.14 m3) or less shall conform to NFPA58, Liquefied Petroleum Gas Code.

A.1.1.2(4) The scope of NFPA 59A, Standard for the Production, Storage, and Handling of Liquefied Natural Gas (LNG), is included here for the convenience of the user.

1.1* Scope. 1.1.1 This standard shall apply to the following: (1) Facilities that liquefy natural gas (2) Facilities that store, vaporize, transfer, and handle liquefied natural gas (LNG) (3) The training of all personnel involved with LNG (4) The design, location, construction, maintenance, and operation of all LNG facilities 1.1.2 This standard shall not apply to the following: (1) Frozen ground containers (2) Portable storage containers stored or used in buildings (3) All LNG vehicular applications, including fueling of LNG vehicles

A.1.1.2(5) Vehicle fuel dispensers are covered by NFPA 2, Hydrogen Technologies Code, NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages, NFPA 52, Vehicular Gaseous Fuel Systems Code, and NFPA 58, Liquefied Petroleum Gas Code. A.3.2.1 Approved. The National Fire Protection Association does not approve, inspect, or certify any installations, procedures, equipment, or materials; nor does it approve or evaluate testing laboratories. In determining the acceptability of installations, procedures, equipment, or materials, the authority having jurisdiction may base acceptance on compliance with NFPA or other appropriate standards. In the absence of such standards, said authority may require evidence of proper installation, procedure, or use. The authority having jurisdiction may also refer to the listings or labeling practices of an organization that is concerned with product evaluations and is thus in a position to determine compliance with appropriate standards for the current production of listed items. A.3.2.2 Authority Having Jurisdiction (AHJ). The phrase “authority having jurisdiction,” or its acronym AHJ, is used in NFPA documents in a broad manner, since jurisdictions and approval agencies vary, as do their responsibilities. Where public safety is primary, the authority having jurisdiction may be a federal, state, local, or other regional department or individual such as a fire chief; fire marshal; chief of a fire prevention bureau, labor department, or health department; building official; electrical inspector; or others having statutory authority. For insurance purposes, an insurance inspection department, rating bureau, or other insurance company representative may


be the authority having jurisdiction. In many circumstances, the property owner or his or her designated agent assumes the role of the authority having jurisdiction; at government installations, the commanding officer or departmental official may be the authority having jurisdiction. A.3.2.4 Listed. The means for identifying listed equipment may vary for each organization concerned with product evaluation; some organizations do not recognize equipment as listed unless it is also labeled. The authority having jurisdiction should utilize the system employed by the listing organization to identify a listed product. A.3.3.2 The definition is extracted 29CFR1926.32(f). OSHA guidance material states additionally: “by way of training and/or experience, a competent person is knowledgeable of applicable standards, is capable of identifying workplace hazards relating to the specific operation, and has the authority to correct them. Some standards add additional specific requirements which must be met by the competent person.” A.3.3.5 Inert Gas. Inert gases do not react readily with other materials under normal temperatures and pressures. For example, nitrogen combines with some of the more active metals such as lithium and magnesium to form nitrides, and at high temperatures it will also combine with hydrogen, oxygen, and other elements. The gases neon, krypton, and xenon are considered rare due to their scarcity. Although these gases are commonly referred to as inert gases, the formation of compounds is possible. For example, xenon combines with fluorine to form various fluorides and with oxygen to form oxides; the compounds formed are crystalline solids. [NFPA 55, 2010] A.3.3.6 The service regulator in an undiluted Liquefied Petroleum Gas system can include any one of the following: 1. The second stage regulator or integral two-stage regulator 2. A 2-psi service regulator or integral 2 psi service regulator A.4.3 Commissioning or maintenance procedures should include, as a minimum, consideration of process safety management as described in 29 CFR part 1926.64 for construction of new facilities or 29 CFR 1910.119(e). The intent of the reference to the regulation is to direct users to the process hazard analysis; it is not intended to imply that all facilities are subject to the entire regulation. For further information on hazard analyses, users can reference AICHE Center for Chemical Process Safety Guidelines for Hazard Evaluation Procedures. A.6.1.5 Compressors can introduce lubricating oil or other flammable constituents to the compressed gas supply. Care should be taken to insure that these flammable constituents are not introduced to the piping system in concentrations that could lead to a flammable atmosphere within the pipe. This can include the use of “100% oil- free compressors”, or filtering systems that remove residuals prior to introduction to the piping system. A.6.2 Where pressure testing is completed before the piping system is cleaned of dirt and debris, operators should release the media and debris in a way that would not pose a risk to personnel. Operators can consider the following methods to discharge the pressure test media: (1) Releasing test media at a rate that prevents the ejection of debris or liquids at high

velocity (2) Providing means to capture debris or liquids exiting the system (3) Locating the discharge point a safe distance from any person, vehicle, or structure. A.6.2.4 ASME B31.3 requires a “leak test” wherein piping systems are subjected to pressures at least 1.5 times the design operating pressure and such pressure is held for at least 10 minutes.


NFPA 54 and ASME B31.1 require a similar test procedure and parameters but refer to the test as a “pressure test.” A.6.2.5 ASME B31.1 and B31.3 require the use of a “nonflammable and nontoxic”gas as the test medium for pneumatic testing. This document specifically limits the acceptable media further to air, carbon dioxide or inert gas. Oxygen is specifically prohibited because of the possible subsequent introduction of flammable gas and risk of developing a flammable atmosphere. A.6.2.8 Components can be relief valves, pressure switches, sensing lines, fill lines, thermowells, gauges, orifice plates, flanges, blinds, pressure-operated releases, or other similar appurtenances. A.6.3.2 This is not intended to exclude specialized cleaning chemicals used in solution with water in accordance with manufacturer’s instructions by competent personnel.

Annex B Informational References

B.1 Referenced Publications. The documents or portions thereof listed in this annex are referenced within the informational sections of this standard and are not part of the requirements of this document unless also listed in Chapter 2 for other reasons. B.1.1 NFPA Publications. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471. B.1.2 Other Publications.

B.2 Informational References. (Reserved)

ANSI/ASSE Z690.1, Vocabulary for Risk Management

ANSI/ASSE Z690.2, Risk Management – Principles and Guidelines

B.3 References for Extracts in Informational Sections. (Reserved)

ANSI/ASSE Z690.3, Risk Assessment Techniques

Attachment D: Written Comments

Part I – March 4 – April 1

Comments/Proposals Submitted for Discussion:

Definitions, Chapter 3: 56(PS)-(3.3.x Purge and 3.3.y Charge (New)) Submitter: Allan J. Zadiraka Akron, OH Recommendation: Revise text to read as follows: 3.3.x Purge. The process of replacing any flammable or combustible gas or vapor with

air or an inert gas in a pipe, enclosure or other volume. 3.3.y Charge. The process of replacing air or an inert gas in a pipe with fuel gas.

Substantiation: The terms Purge and Charge need to be defined to clarify their use in the document.

56(PS)-(3.3.x Line Gas Regulator and A.3.3.x (New) ) Submitter: Bruce J. Swiecicki, National Propane Gas Association Recommendation: New text to read as follows: 3.3.x* Line Gas Regulator. A pressure regulator placed in a gas line between the service regulator and the appliance regulator. A.3.3.x

1. The second stage regulator or integral two-stage regulator

A.1.1.1.1(A) The service regulator in an undiluted Liquefied Petroleum Gas system can include any one of the following:

2. A 2-psi service regulator or integral 2 psi service regulator Substantiation: This definition is needed because the coverage statement in 1.1.1.1 relies upon the term "line gas regulator" in defining the scope of the document. The definition is taken from NFPA 54 and the annex material is taken from the ROP for the 2012 edition of NFPA 54. 56(PS)-(3.3.8 Prime Mover) Submitter: W. Collins, UTC Power Recommendation:

Substantiation: Prime mover is not defined in the document, but is used in several places.

3.3.8 Prime Mover. Part of the power unit component; the energy source that drives the principal power output device of the power unit. [1936, 2010]

General Requirements, Chapter 4 56(PS)-4.2.1* Submitter: W. Collins, UTC Power Such training shall include hazards of fuel gas, hazards of any compressed gas used for cleaning or purging, safe handling practices of fuel gas and compressed gas as applicable, emergency response procedures, and company policy. A.4.2.1 Training should cover, as a minimum, the following hazards; compressed gases, flammable and explosive fluids, toxic gases and asphyxiants.

56(PS)-(4.x (New)) Submitter: Dennis M. Kovach, American Electric Power Recommendation: Currently, there is a total absence of discussion in this document about electrical hazards and area classification. Substantiation: NFPA 70/NFPA 497 do a good job addressing areas where fuel gas pressures exceed 100 psi, but in the 2 psi-100 psi range (which may encompass quite a bit of what is addressed in NFPA 56) there is not much guidance. At the very least, consideration should be given to providing material in the Annex of NFPA 56 regarding this issue. This is not original material; its reference/source is as follows: All comments are being submitted by myself on behalf of the AEP Generation Natural Gas Fuel Facilities and Operations Team 56(PS)-(4.2.2 (New) ) Submitter: Dennis M. Kovach, American Electric Power Recommendation: There needs to be better direction regarding the safety hazards involved with using inert gases for piping cleaning - especially high volume nitrogen. Substantiation: Our belief is that inert gases are likely to be used for pipe cleaning operations, especially gas blows, going forward. That process will introduce its own set of hazards, especially in terms of personnel exposure to possible asphyxiation. Simply coming out with a new standard saying "don't do gas blows" and not giving further direction about how to SAFELY implement alternative procedures seems irresponsible. While personnel exposure might be outside the traditional realm of a fire code, the precedent for providing in-depth explanations about the hazards of such gases has already been set in documents such as NFPA 12 and NFPA 2001. This is not original material; its reference/source is as follows: All comments are being submitted by myself on behalf of the AEP Generation Natural Gas Fuel Facilities and Operations Team Commissioning, Chapter 5: 56(PS)-(5.2) Submitter: Bruce J. Swiecicki, National Propane Gas Association Recommendation: Revise text to read as follows: 5.2* Pressure Testing and Inspection. Prior to cleaning or being charged with fuel

gas, piping systems shall be inspected and pressure tested to determine that the materials, design, fabrication, and installation practices comply with the requirements of this standard and the intended application. Substantiation: It doesn't seem appropriate to require pressure testing of the piping

before it is cleaned. the order of operations should be left to the contractor or owner. 56(PS)-(5.2.5) Submitter: James P. Walawender, Black & Veatch Corporation Recommendation: Revise text to read as follows: 5.2.5 The test medium shall be water, air, nitrogen, carbon dioxide, or an inert gas.

OXYGEN SHALL NEVER BE USED.

Substantiation: The inclusion of nitrogen in this article is redundant because it is already defined as an inert gas in Article 3.3.6. 56(PS)-(5.2.5) Submitter: Dennis M. Kovach, American Electric Power Recommendation: Revise text to read as follows: The pressure test medium shall be water, air, nitrogen, carbon dioxide, or an inert gas.

NEITHER FUEL GAS NOR OXYGEN SHALL NEVER BE USED

Substantiation: 1) As written, this section could easily be taken out of context and interpreted to apply to all fuel gas piping tests. This clearly is not the intent. Therefore, "pressure" needs to be added to the first sentence.

for conducting initial pressure tests.

2) In light of recent incidents and the CSB's recommendations following the Kleen Energy accident, it is recommended that natural gas be prohibited as a pipe testing/cleaning medium. As written, this section still fails to prohibit that practice. This is not original material; its reference/source is as follows: All comments are being submitted by myself on behalf of the AEP Generation Natural Gas Fuel Facilities and Operations 56(PS)-(5.2.8) Submitter: Dan Curry, Eclipse, Inc. Recommendation: Revise text to read as follows: 5.2.8 A piping system shall be tested as a complete unit or in sections. Under no

circumstances shall a single valve in a line be used as a bulkhead between to isolate gas in one section of the piping system and test medium in an adjacent section, unless and instead two valves are shall be installed in series with a valved "telltale" third vent valve located between these valves and the possible release of gas from the vent shall not become a hazardSubstantiation: The terms bulkhead and valved "telltale" are not defined and their meaning within this text is not clear. Adding a verbal description that a single valve is not permitted to separate and isolate one section of piping from its adjacent section avoids misinterpretation. The terminology "vent valve" avoids confusion whether "telltale" means a type of indicator or flow sensing device is required. The persons conducting the test could open the valves in the wrong sequence or the isolating valves could leak so the standard should require protection from any gas that is leaked through the vent valve. The addition at the end of the sentence makes this a requirement.

. [54:8.1.1.5]

56(PS)-5.3.2.1 Submitter: L. Danner, GE Would it be worthwhile to include an Annex discussion of portable (skid or trailer mounted and various prime movers) compressors provided on a temporary basis? It may be necessary to install a GROUP of compressors to achieve sufficient flow volume for larger piping sizes as used in power plants, does this need amplification?

56(PS)-5.3.2.1 and 5.3.2.2 Submitter: L. Danner, GE This is typically a tube trailer or portable (road able) tank. 56(PS)-5.3.2.3 Submitter: L. Danner, GE On combined cycle power plants, the Heat Recovery Steam Generator (HRSG) often has an Auxiliary Boiler that can be used for this purpose. Do we want to include some explanatory material in the annex? 56(PS)-(5.3.2.3.1) Submitter: Allan J. Zadiraka Akron, OH Recommendation: Revise text to read as follows: 5.3.2.3.1 Boilers for steam supply shall comply with the ASME Boiler and Pressure

Vessel Code and, as applicable, either ASME CSD-1, Controls and Safety Devices for Automatically Fired Boilers

Substantiation: As written, text presumes that a boiler used for steam supply would be small unit that falls under CSD-1 which may not be true for all situations. Steam could be supplied from an adjacent boiler or axillary boiler covered by NFPA 85.

or NFPA 85, Boiler and Combustion Systems Hazards Code.

56(PS)-5.3.3.2 Submitter: W. Collins, UTC Power Temporary piping, hose and accessories shall be designed and constructed to

withstand at least 1.25 times the expected pressure of the cleaning process. • Temporary piping is usually makeshift. Is 1.25 enough margin or would 1.5 be

proper? 56(PS)-5.3.4.2 Submitter: W. Collins, UTC Power Personnel not involved in the cleaning process shall be evacuated to a point not less

than 25 ft (7.7 m) from the point of discharge. • Why isn’t 50 feet like in section 5.2.11 the threshold?

56(PS)-5.3.4.2 Submitter: L. Danner, GE Given that the pressure used for this can be nearly as high as the leak test pressure, and may be a continuous flow, I would think this value would be consistent with the 50 foot specified by 5.2.11(3)

56(PS)-(5.3.4.2) Submitter: Dan Curry, Eclipse, Inc. Recommendation: Move 5.3.4.2 to 5.3.6 (New) - i.e., delete 5.3.4.2 and add a new paragraph to 5.3.6 with the same wording as the deleted text. Substantiation: Paragraph 5.3.4 deals with all parts of the piping system being cleaned and 5.3.4.2 refers only to the point of discharge. Therefore it should be grouped with paragraph 5.3.6 dealing specifically with the point of discharge. 56(PS)-(5.3.4.2) Submitter: James P. Walawender, Black & Veatch Corporation Recommendation: Delete the following text: 5.3.4.2 Personnel not involved in the cleaning process shall be evacuated to a point

not less than 25 ft (7.7 m) from the point of discharge. Substantiation: This requirement is already addressed in Articles 5.3.6.1.2 and

5.3.6.2. 56(PS)-(5.3.4.2)

Submitter: Dennis M. Kovach, American Electric Power Recommendation: Revise text to read as follows: Personnel not involved in the cleaning process shall be evacuated to a safe distance

Substantiation: The wording in this section is inconsistent with sections 5.3.6.1.2 and 5.3.6.2. In addition, the use of inert gases may necessitate a much larger evacuation area than the 25 or 50 ft mentioned in these sections. While suggested minimum distances may be appropriate for discussion in the Annex, the "safe distance" needs to be determined on a case-by-case basis.

point not less than 25 ft (7.7 m) from the point of discharge.

This is not original material; its reference/source is as follows: All comments are being submitted by myself on behalf of the AEP Generation Natural Gas Fuel Facilities and Operations 56(PS)-5.3.5 Submitter: L. Danner, GE There are PIGs specifically designed to clean piping that is filled with a flammable gas. These units are often electrically powered and include mechanical cleaning devices to physically scrub the pipe interior. The use of these PIGs is via “Traps” in the piping that isolate the pipe and provides a non-hazardous environment for insertion and removal of the PIG. The PIG goes about the cleaning process once inserted. Do we want to at least include an annex description of this option? (L. Danner)

56(PS)-(5.3.6.x (New) ) Submitter: Dan Curry, Eclipse, Inc. Recommendation: Add a new section to read as follows: 5.3.6.x The discharge area shall be clearly marked with warnings of discharge

hazards. Substantiation: During the cleaning cycle a person could walk into the point of

discharge after the visual and audible alarm of 5.3.1.2 not knowing that debris may eject at any moment. Adding warnings in the form of temporarily placed signs with text and graphics will give meaning to the visual and audible alarm. 56(PS)-(5.3.6.y (New) ) Submitter: Dan Curry, Eclipse, Inc. Recommendation: Add a new section to read as follows: 5.3.6.y The discharge area shall be visually verified to be compliant with 5.3.6.1.2 or 5.3.6.2 within the time period of 5.3.1.2 before starting the cleaning cycle. Substantiation: With an unattended point of discharge, a person or object could be in the hazardous area if there is a long delay from when trained personnel last checked the area to the start of the cleaning cycle. 56(PS)-(5.3.6.1) Submitter: James P. Walawender, Black & Veatch Corporation Recommendation: Revise text to read as follows: 5.3.6.1 Target. Where a target is used to provide an indication of

5.3.6.1.1 The target shall be designed and secured to withstand the velocity and pressure of the exiting media and debris without breaking or failing.

capture debris during the cleaning process, it shall comply with 5.3.6.1.1 and 5.3.6.1.2.

5.3.6.1.2 The target shall be located not less than 25 ft (7.7 m) from any person, vehicle or structure, or it shall be provided with means to ensure 100 percent capture of exiting debris. Substantiation: The capture of all of the material is impractical by the nature of how the piping system is permitted to be cleaned (blow or flush the system) in accordance with Article 5.3. 56(PS)-5.5.1.1 Submitter: C. Dubay, NFPA Add A.5.5.1.1 NFPA 69-2008 section 7.2.3 is provided here for the convenience of the users of this document: 7.2.3 Limiting Oxidant Concentrations (LOCs). 7.2.3.1* Table C.1(a) and Table C.1(b) shall be permitted to be used as a basis for determining LOCs of flammable gases or suspensions of combustible dusts. 7.2.3.1.1 For gases and vapors, if the LOC values according to ASTM E 2079, Standard Test Method for Limiting Oxygen (Oxidant) Concentration for Gases and Vapors, are available, then these shall be used.

7.2.3.1.2 For gases and vapors, if the LOC values according to ASTM E 2079 are not available, then the LOC values obtained in flammability tubes shall be used after adjustment by subtracting 2 percent by volume oxidant as indicated in the adjusted columns in Table C.1(a). 7.2.3.2 For fuel, inert, and oxidant combinations not listed in Table C.1(a) or Table C.1(b) or for situations when the process conditions differ from the conditions under which the existing data were obtained, the test methods described in ASTM E 2079 shall be permitted to be used. 7.2.3.3 The extent of oxidant reduction shall be determined by testing where conditions vary significantly from the test conditions under which the data were obtained. 56(PS)-(5.5.2) Submitter: Allan J. Zadiraka Akron, OH Recommendation: Revise text to read as follows: 5.5.2 Outdoor discharge of purged gases during charging5.5.2.1 The open end of a piping system being pressure vented or purged

. charged

5.5.2.2 Purging shall discharge directly to an outdoor location.

Charging

5.5.2.2.4 Purging

operations shall comply with the requirements in 5.5.2.2.1 through 5.5.2.2.5.

Charging

5.5.2.2.5 Persons not involved in the purging

operations introducing fuel gas shall be stopped when 90 percent fuel gas by volume is detected within the pipe.

charging

Substantiation: Inconsistent use of terms describing the operation. Charging is making the system unsafe by admitting combustible gas to it. Purging is making a system safe by replacing combustible gases with air or inert gas. All NFPA codes except 54 follow this convention where charging arms the system and purging safes it.

operations shall be evacuated from all areas within 10 ft (3.1 m) of the point of discharge.

56(PS)-(5.5.2.1) Submitter: Dennis M. Kovach, American Electric Power Recommendation: Revise text to read as follows: The open end of a piping system being pressure vented or purged shall discharge

directly to an outdoor location Substantiation: Not all outdoor locations are safe, as is evidenced by the additional

rules in 5.5.2.2. Adding these words makes that more apparent and will direct the user to continue to read this section further to understand what might constitute a "safe" outdoor location.

where venting will not create a hazard.

This is not original material; its reference/source is as follows: All comments are being submitted by myself on behalf of the AEP Generation Natural Gas Fuel Facilities and Operations

56(PS)-(5.5.2.2.1) Submitter: Dennis M. Kovach, American Electric Power Recommendation: Revise text to read as follows: The point of discharge shall be controlled with a shutoff valve

Substantiation: As written this section could be understood to require a valve to be AT the discharge point, which would be a personnel safety hazard.

located a safe distance away from the point of discharge.

This is not original material; its reference/source is as follows: All comments are being submitted by myself on behalf of the AEP Generation Natural Gas Fuel Facilities and Operations 56(PS)-5.5.2.2.2 Submitter: W. Collins, UTC Power The point of discharge shall be located at least 10 feet from sources of ignition, at least

10 feet from building openings and at least 25 feet from mechanical air intake openings.

• Values sound low. The underlying assumption in NFPA 853 is low pressure fuel supply and cabinet ventilation fans. Basically a situation where a plume not jet is being dealt with and the plume case has the larger clearance area?

[NFPA Staff NOTE: These values are extracted from NFPA 54 TIA 54-09-3]

[853:5.2.3] 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.

56(PS)-(5.5.2.2.2) Submitter: Allan J. Zadiraka Akron, OH Recommendation: Revise text to read as follows: 5.5.2.2.2 The point of discharge shall be located at least 10 ft from sources of ignition,

at least 10 ft from building openings and at least 25 ft from mechanical air intake openings so that there is no possibility of the discharged gas being drawn into a building, combustion air intake, the ventilating system, or the windows of a boiler or HRSG room or adjacent buildings and shall be extended above the building, boiler or HRSG and adjacent structures so that gaseous discharge does not present a hazard. Substantiation: Since the size of the line being charged is not specified, the distances given may not be adequate for larger lines such as used with boilers, HRSG, or combustion turbines.

56(PS)-(5.5.2.2.2) Submitter: Dennis M. Kovach, American Electric Power Recommendation: Revise text to read as follows: In the absence of an engineering analysis using plume modeling to determine safe

distances,

Substantiation: While it is understood these distances come from the AGAXFO277 guideline, depending on a number of variables these distances may not be sufficient. There also should be a clear explanation in the Annex or the body of this standard as to why these distances may not be great enough to protect personnel when fuel gas is being reintroduced into a pipeline.

the point of discharge shall be located at least 10 ft from sources of ignition, at least 10 ft from building openings and at least 25 ft from mechanical air intake openings.

This is not original material; its reference/source is as follows: All comments are being submitted by myself on behalf of the AEP Generation Natural Gas Fuel Facilities and Operations 56(PS)-(5.5.2.2.4) Submitter: Allan J. Zadiraka Akron, OH Recommendation: Revise text to read as follows: 5.5.2.2.4 Purging operations introducing fuel gas shall be stopped when 90 percent

fuel gas by volume is detected within at the discharge of the pipe being charged

. Substantiation: Location needs to be specified since charging is intended to fill the entire line.

56(PS)-(5.5.2.2.4) Submitter: Dennis M. Kovach, American Electric Power Recommendation: Revise text to read as follows: Purging operations introducing fuel gas shall be stopped when at least

Substantiation: The goal is to achieve 100 percent fuel gas by volume. While 90 percent may be a "good' stopping point, there may be reasons from a process standpoint where going above 90 percent is necessary. Restricting the purging operations to stopping at a 90 percent limit seems overly restrictive.

90 percent fuel gas by volume is detected within the pipe.

This is not original material; its reference/source is as follows: All comments are being submitted by myself on behalf of the AEP Generation Natural Gas Fuel Facilities and Operations 56(PS)-(5.5.2.2.5) Submitter: Dennis M. Kovach, American Electric Power Recommendation: Revise text to read as follows: Persons not involved in the purging operations shall be evacuated from all areas within

50 ft (16 m) Substantiation: While it is understood the 10 ft distance come from the AGAXFO277

guideline, depending on a number of variables the distance will most likely not be sufficient to prevent injury in the event of an ignition. Based on other areas of this standard, 50 ft seems like a more appropriate, conservative number to use. There also

10 ft (3.1 m) of the point of discharge.

should be a clear explanation in the Annex or the body of this standard as to why this distance may not be great enough to protect personnel when fuel gas is being reintroduced into the pipeline. This is not original material; its reference/source is as follows: All comments are

being submitted by myself on behalf of the AEP Generation Natural Gas Fuel Facilities and Operations

56(PS)- 5.5.2.2.5 Submitter: W. Collins, UTC Power Persons not involved in the purging operations shall be evacuated from all areas within

10 ft (3.1 m) of the point of discharge. See comments for 5.5.2.2.2. [This comment also submitted by L. Danner]

56(PS)-(5.5.3.1.1 (New) ) Submitter: Dennis M. Kovach, American Electric Power Recommendation: Revise text to read as follows:

Substantiation: Many portable combustible gas detectors are designed only for use where sufficient levels of oxygen are present. Where oxygen concentrations are limited either due to high levels of combustible gas or high levels of inert gases, these portable detectors may display falsely low readings. In fact, catalytic bead type sensors will actually start displaying lower gas concentrations as the gas concentrations rises above 100 percent of the LEL. If the end user is not familiar with these issues, he or she may be given a false sense of security and may actually place themselves in greater danger by simply relying on portable gas detectors to determine whether or not an atmosphere is "safe".

Combustible gas indicators shall be suitable for measuring gas concentrations in oxygen-deficient atmospheres.

This is not original material; its reference/source is as follows: All comments are being submitted by myself on behalf of the AEP Generation Natural Gas Fuel Facilities and Operations 56(PS)-(5.5.3.3 (New) )

Submitter: Masahiko Mishiro, Mitsubishi Heavy Industries Ltd., Recommendation: Add the following new paragraph in Section 5.5.3. 5.5.3.3 Portable type combustible gas indicators in accordance with the requirements

in 5.5.3.1 and 5.5.3.2 may be used. Substantiation: The current draft does not specify if portable indicators are permitted

to be used or not. Added paragraph will clarify this point. AS specified in 5.5.2.2.3 and 6.6.2.2.3, the open point of discharge shall be continuously attended and therefore the use of portable indicators will be able to achieve the requirements of the Standard as well.

Maintenance, Chapter 6: 56(PS)-(6.1.x (New)) Submitter: Dennis M. Kovach, American Electric Power Recommendation: Add some reference to static grounding on the plastic pipe prior to opening the line. Substantiation: It appears the document is directed primarily to metal pipe, but we do have non-metallic pipe in non-temporary service. One of our plants has underground HDPE pipe bringing the gas to the plant building. Any flow through the plastic line will create a static electrical charge on the pipe outside

diameter. Since the plastic material is not conductive, grounding in one area will not "drain" off the charge. What the manufacturers recommend is to use wetted cloth wrapped around the pipe, from the location of repair outward a distance of several feet in each direction, and ground the cloth. This is not original material; its reference/source is as follows: All comments are

being submitted by myself on behalf of the AEP Generation Natural Gas Fuel Facilities and Operations Team

56(PS)-(6.3.2.1) Submitter: Dennis M. Kovach, American Electric Power Recommendation: Revise text to read as follows: Where inert gas is released indoors or outdoors

Substantiation: When inert gases are used, an asphyxiation hazard could be created outdoors just as easily as indoors. For example, at a construction site using as gas heavier-than-air could create hazards in low lying area such as trenches or manholes where other work may be going on.

, an oxygen monitoring system shall be installed in the area and activate audible and visual alarms if oxygen levels fall below 19.5 percent by volume.

This is not original material; its reference/source is as follows: All comments are being submitted by myself on behalf of the AEP Generation Natural Gas Fuel Facilities and Operations 56(PS)-(6.4.1.2) Submitter: Dennis M. Kovach, American Electric Power Recommendation: Revise text to read as follows: Smoking, open flames, lanterns, heaters,

Substantiation: Portable heaters seem to be a frequent problem for us on construction sites. Particularly when purging is being performed in colder weather, portable heaters are very likely to be a present source of ignition.

or other sources of ignition shall not be permitted.


56(PS)-(6.6.2.1) Submitter: Dennis M. Kovach, American Electric Power Recommendation: Revise text to read as follows: The open end of a piping system being pressure vented or purged shall discharge

directly to an outdoor location Substantiation: Not all outdoor locations are safe, as is evidenced by the additional

rules in 6.6.2.2. Adding these words makes that more apparent and will direct the user to continue to read this section further to understand what might constitute a "safe" outdoor location.

where venting will not create a hazard.

This is not original material; its reference/source is as follows: All comments are being submitted by myself on behalf of the AEP Generation Natural Gas Fuel Facilities and Operations 56(PS)-(6.6.2.1 and 6.6.2.2.5) Submitter: Dennis M. Kovach, American Electric Power Recommendation: Format issue: Section numbers are incorrectly started with 6.6 instead of 6.2. Substantiation: Either the section numbers are wrong or this section was placed out-of-order in the proposed document. This is not original material; its reference/source is as follows: All comments are being submitted by myself on behalf of the AEP Generation Natural Gas Fuel Facilities and Operations 56(PS)-(6.6.2.2.1) Submitter: Dennis M. Kovach, American Electric Power Recommendation: Revise text to read as follows: The point of discharge shall be controlled with a shutoff valve

Substantiation: As written this section could be understood to require a valve to be AT the discharge point, which would be a personnel safety hazard.

located a safe distance away from the point of discharge.

This is not original material; its reference/source is as follows: All comments are being submitted by myself on behalf of the AEP Generation Natural Gas Fuel Facilities and Operations 56(PS)-(6.6.2.2.2) Submitter: Dennis M. Kovach, American Electric Power Recommendation: Revise text to read as follows: In the absence of an engineering analysis using plume modeling to determine safe

distances,

Substantiation: While it is understood these distances come from the AGAXFO277 guideline, depending on a number of variables these distances may not be sufficient. There also should be a clear explanation in the Annex or the body of this standard as to why these distances may not be great enough to protect personnel when fuel gas is being reintroduced into a pipeline.

the point of discharge shall be located at least 10 ft (3.1 m) from sources of ignition, at least 10 ft from building openings and at least 25 ft from mechanical air intake openings.


56(PS)-6.6.2.2.2 Submitter: W. Collins, UTC Power The point of discharge shall be located at least 10 feet (3.1 m) from sources of ignition,

at least 10 feet from building openings and at least 25 feet from mechanical air intake openings. See comments for 5.5.2.2.2. [This comment also submitted by L. Danner]

56(PS)-6.6.2.2.4 Submitter: W. Collins, UTC Power Purging operations introducing inert gas shall be stopped when the fuel gas level (by

volume) detected within the pipe and within a 5 ft (1.5 m) radius of the point of discharge is less than 25 percent of the lower flammable limit.

• You might want to rework this. Outside in a slight breeze @ 5 ft you might never reach 25% LFL depending where the sensor is. A better point to sample might be in the exhaust stream jet within a foot of the pipe.

56(PS)-(6.6.2.2.5) Submitter: Dennis M. Kovach, American Electric Power Recommendation: Revise text to read as follows: Persons not involved in the purging operations shall be evacuated from all areas within

50 ft (16 m) Substantiation: While it is understood the 10 ft distance come from the AGAXFO277

guideline, depending on a number of variables the distance will most likely not be sufficient to prevent injury in the event of an ignition. Based on other areas of this standard, 50 ft seems like amore appropriate, conservative number to use. There also should be a clear explanation in the Annex or the body of this standard as to why this distance may not be great enough to protect personnel when fuel gas is being reintroduced into a pipeline. This is not original material; its reference/source is as follows: All comments are being submitted by myself on behalf of the AEP Generation Natural Gas Fuel Facilities and Operations

10 ft (3.1 m) of the point of discharge.

56(PS)-6.6.2.2.5 Submitter: W. Collins, UTC Power Persons not involved in the purging operations shall be evacuated from all areas within

10 ft (3.1 m) of the point of discharge. • See comments for 5.5.2.2.2. [This comment also submitted by L. Danner]

56(PS)-6.3.2.1 Submitter: W. Collins, UTC Power Where inert gas is released indoors, an oxygen monitoring system shall be installed in

the area and activate audible and visual alarms if oxygen levels fall below 19.5 percent by volume.

• Reference source - 29 CFR1910.146 Definitions of hazardous area (3) Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent; - might want for annex in case OSHA changes level at some point.

56(PS)-6.4.1.4 Submitter: W. Collins, UTC Power Artificial illumination shall be restricted to listed safety-type flashlights and safety lamps,

and electric switches shall not be operated, on or off. [54: 4.3.1] • Suggest …electric devices shall not be energized or de-energized.

56(PS)-A.3.3.4 Submitter: L. Danner, GE Consistent with my comment on the scope, perhaps we should include additional information here. Yes, I now that takes us out of the strict extract mode. Perhaps we need that discussion with the 37 committee …

Attachment E: Written Comments

Part II – April 10-May 6

PART II: April 7 – May 6; Comments/Proposals Submitted for Discussion 56(PS)-Document Title Submitter: Glenn Mahnken, FM Global Recommendation: Provisional Standard for Fire Safety during

Substantiation: The document title is potentially misleading about the scope of the standard. Our scope is very limited – it does not include all aspects of commissioning and maintenance of piping. Clarify that the Standard only applies to fire safety aspects of C&M.

the Commissioning and Maintenance of Flammable Gas Piping Systems

56(PS)-1.1.1 Submitter: Glenn Mahnken, FM Global Recommendation: 1.1.1 Applicability. This standard applies to fire safety during commissioning and maintenance procedures for of flammable gas piping found in electric-generating plants, natural gas processing plants, refineries, petrochemical plants,Substantiation: (1) The scope does not include all aspects of commissioning and maintenance of piping. Clarify that the scope only applies to fire safety.

and industrial and commercial applications.

(2)Specifically state that refineries, natural gas processing plants and petrochemical plants are intended to be within the scope.

56(PS)-1.1.1 Submitter: Ismail Gosla, Fluor Corporation Recommendation: See the comments below: 1) See all missing sections in the draft below [Staff Note: Cross-references have been corrected.] 2) This NFPA 56 standard has no lower (starting) pressure limit. EU, similar standards apply for pressure systems 0.5 bar.g (7.25 psi) or above. 3) Question: If there is no lower pressure limit, will this standard also apply to flammable gas where it is applied in mbar pressure (inches gauge) as blanketing/inerting gas within cone roof tank spaces etc ? If so, would it be worth highlighting ? 56(PS)-1.1.1 Submitter: Mike Osmundson, Lexicon Propane Group Recommendation: The title of the standard and the scope of the document indicate that the standard will apply to nearly all fuel gas systems except in residential applications. Since NFPA 54 covers the same or similar subjects, it was not clear to me what the difference in the two codes was. Following a conversation with you, I became aware that the primary purpose of NFPA 56 was to address an issue which arose with the cleaning of debris from the fuel gas piping at a large, high pressure fuel gas consuming facility. There should be a clear and logical delineation between this standard (56) and other related standards like NFPA 54. If this is not done, there will be on going confusion regarding application of the standard just as there is for facilities under NFPA 58 or NFPA 59.

Suggestions: 1. Rename NFPA 56 the ‘High Pressure Fuel Gas Code’ and include any incorporate any appropriate subjects in NFPA 54 or other standards which would apply to installations over 125 psi or, 2. Remove any references or requirements regarding pipe cleaning or purging from other codes and place them in NFPA 56 and title the standard ‘Commissioning, Cleaning and Purging of Fuel Gas Piping’ or, 3. Identify the unique risks associated with pipe cleaning with any size or pressure system (and perhaps purging since the activities are similar) and incorporate appropriate requirements in NFPA 54 and other standards. This would eliminate the need for an additional standard. Other notes: 1. This standard is intended to cover fuel gas piping systems for electrical generating, industrial, and commercial applications. None of these applications are defined. 2. The end points which define covered piping differ between NFPA 56 and NFPA 54. This means that it is possible that sections of fuel piping for a particular installation could be covered by more than one standard. 56(PS)-1.1.2 Submitter: Frank Mortimer, EMC Insurance Co. Recommendation: Revise Text as Follows: 1.1.2 Nonapplication of Standard. This code shall not apply to the following items: (1)* Piping systems covered by NFPA 54, National Fuel Gas Code (2)* Piping systems covered by NFPA 58, Liquefied Petroleum Gas Code (3)* Piping systems covered by NFPA 2, Hydrogen Technologies Code (4)* LP-Gas (including refrigerated storage) at utility gas plants (see NFPA 59, Utility 56(PS)-1.1.2 Submitter: Norman Rockwell, Tennessee Valley Authority Recommendation: 1.With respect to ‘retroactivity’ of this provisional standard: many of the items described here are relevant and routine for operational plants and are not just for brand new plants or facilities being constructed. 2.Why would you not indicate that (for example) 6.5.1 should apply to all gas facilities immediately? I.e. from now on, the NFPA code should require inert gas purge prior to re-filling a section of pipe with natural gas. A lot of operating sites do this; most do not even have inert gas available on site. After maintenance work on gas vessels (e.g. scrubbers or filter pots), they go straight from air to gas – as do most gas-fired generation utilities. 3.Several times throughout this document it references “in according with Section 5.2” or “in accordance with Section 5.5.2” or “in accordance with Section 5.3”. What code or document are these referred-to sections in? These sections are certainly not in this document. Whatever code or document it is referencing these sections should be named. Am I just missing something?

56(PS)-1.1.2 Submitter: Gil Poe, ExxonMobil Production Company Recommendation: Section 1.1.2 Add the following non-applications (8) Pressure relief disposal systems (9) Facilities used for the production transportation and refining of oil and gas. Substantiation: pressure relief and flare systems are either not purged prior to use (e.g. tail pipe on PSV) or purged into service and continuously during service with gas (e.g. flare systems). Safe techniques including N2 purge and in some cases gas purge are used in the oil and gas industry. 56(PS)-1.3 Submitter: Gene Jinkins, Colorado Energy Management Recommendation: The proposed standard talks about applicability and retroactivity as noted: 1.3 Retroactivity. The provisions of this standard reflect a consensus of what is necessary to provide an acceptable degree of protection from the hazards addressed in this standard at the time the standard was issued. 1.3.1 Unless otherwise specified, the provisions of this standard shall not apply to facilities, equipment, structures, or installations that existed or were approved for construction or installation prior to the effective date of the standard; where specified, the provisions of this standard shall be retroactive. However as I read through the rest of the document I did not see anywhere we the standard specified it applied to any facilities that already existed prior to the effective date of this standard. I guess my assumption, or hope, would be that the maintenance section would apply to all facilities regardless of whether or not they existed prior to this standard’s effective date. These systems are worked on quite a bit within the power industry and if the new standard does not apply how do we get the existing facilities to take the safety precautions necessary to ensure personnel and public safety? If I missed the applicability in the standard I apologize and would appreciate clarification on where it is at. I believe this proposed standard is an outstanding idea but also one that needs to be made mandatory, especially the maintenance section, for all facilities. 56(PS)-1.3.1 Submitter: Glenn Mahnken, FM Global Recommendation: 1.3.1 Unless otherwise specified, the provisions of this standard shall not apply to facilities, equipment, structures, or installations that existed or were approved for construction or installation prior to the effective date of the standard; where specified, the provisions of this standard shall be retroactive.

Substantiation: Purging of existing equipment should not be grand-fathered.

1.3.1.1 Procedures for purging shall be applied during maintenance activity conducted after the effective date of this standard.

56(PS)-Chapter 4 Submitter: Glenn Mahnken, FM Global Recommendation: Require Job Safety Analysis in addition to PHA in Section 4 Change heading of 4.3. and add new 4.3.2 4.3* Job Safety Analysis and Process Hazard Analysis. Commissioning and maintenance procedures shall include a job safety analysis and a

4.3.1 The process hazard

process hazard analysis for each activity.

job safety

(1)… (26)

analysis for each commissioning or maintenance activity shall address the following, as a minimum:

4.3.2 The process hazard analysis for each commissioning or maintenance activity shall address the following, as a minimum [ to be developed]

:

Substantiation: A comment was made that our current list under 4.3.1 is more of a JSA. This seems to be true, but both JSA and PHA should be required. 56(PS)-Chapter 4 Submitter: Eugene Ngai, Chemically Speaking LLC Recommendation: The description of a “Process Hazards Analysis” is not consistent with the typical PHA. The OSHA PSM and EPA RMP regulations have different requirements for a PHA. So as to not add to the confusion, the PHA should be reworded to JSA as follows 4.2 Notification of Hazards. Personnel in the affected area(s), as determined by the process hazard job safety analysis, who are not directly involved with the commissioning or maintenance of flammable gas piping systems shall be informed of the hazards associated with the activity prior to the initiation of any such activity. 4.3* Process Hazard Job Safety Analysis. Commissioning and maintenance procedures shall include a process hazard job safety analysis for each activity. 4.3.1 The process hazard job safety analysis for each commissioning or maintenance activity shall address the following, as a minimum: 4.3.2 Many of the requirements of the job safety analysis should be determined or evaluated from the system process hazard analysis, occupational safety procedures, and site emergency plan. The job safety analysis is a mechanism to address and manage unique commissioning and maintenance hazards in general site documentation, procedures, and programs. This standard would not apply to a gas supplier that is filling methane cylinders while it would apply to a customer using methane in their reactor/instrument? 56(PS)-Chapter 4 and 5 Submitter: Scot Pruett, Black & Veatch Corporation Recommendation: Move Chapter 5 – Training Requirements in front of Chapter 4 General requirements or add an experience comment section to Chapter 1. Substantiation: It is beneficial to call out the experience and knowledge requirement in the initial document to clarify that the person intended to implement this standard is experienced on this topic. With the text placed after the general requirements, it appears to be aimed at the site

workers and not the person generating the process hazard analysis. In NFPA 850, the document has a qualification statement in Section 1.3.1. “1.1.3 This document is intended for use by persons knowledgeable in the application of fire protection for electric generating plants and high voltage direct current converter stations.” Potential text to chapter 1: Section 1.? This document is intended for use by persons knowledgeable in the application of commissioning and maintenance of flammable gas piping systems.” 56(PS)-4.3.1 Submitter: Scot Pruett, Black & Veatch Corporation Recommendation: Recommendation: Add text to Section 4.3.1 (1) Section 4.3.1(1) Release or disposal of fluids Substantiation: The fluid media recommended in Section 6.3.2 includes Air, inert gas, steam, or water. Recommend adding the reference to gasses in the releasing discussion to correspond with the gasses called out in Section 6.3.2. The issues associated with the different types of medias may pose substantially different types of hazards.

and gases.

56(PS)-5.5.1 Submitter: Clayton Shoup, Zurich Services Corporation Recommendation: Proposed text change: 5.1.1 Such training shall include hazards of flammable gas, hazards of any compressed gas used for cleaning or purging, safe handling practices of flammable gas and compressed gas as applicable, emergency response procedures and equipment, the results of any hazard analysis performed in Section 4.3 and company policy. Substantiation for change: Assure that employee health and safety aspects of hazard analysis, such as lockout/tag-out (LO/TO), personal protective equipment (PPE), non-essential personnel evacuation, etc. are covered in training. 56(PS)-6.1.2 and 6.1.8 Submitter: David Namyst, Intel Corporation Recommendation: 6.1.8 Access to all parts of the piping system during commissioning activities shall be restricted in accordance with the process hazard analysis. In a PHA that would cover Gas Piping “Access to all parts of the piping system” would be difficult to restrict. 6.1.2 Commissioning procedures shall be developed and implemented by a competent person. Suggest a bit more substance to this statement.

56(PS)-6.1.1 Submitter: Rich Gallagher, Zurich Services Corporation Recommendation: Proposed text change: Commissioning of flammable gas piping shall include all pressure testing, leak testing, cleaning, pipe conditioning, and flammable gas charging by the owner/operator or designated contractor(s).

Substantiation for change: Expand the commissioning guidance of NFPA 56 to include leak testing and pipe conditioning. A.6.1.1 The commissioning of flammable gas piping may involve a several process steps including: (1) Pressure testing. Codes such as ANSI/ASME B31.1 Power Piping and NFPA 54 National Fuel Gas Code provide guidance on pressure testing. (2) Leak testing. Leak detection can also be carried out using a noncorrosive leak detection fluid applied to pipe system joints. Commercially available fluids intended for fuel gas piping leak testing can be obtained that are noncorrosive and have the necessary viscosity to remain in place as well as form bubbles should a leak be present. Also, see NFPA 54 Annex D Suggested Method of Checking for Leakage. (3) Cleaning. See Chapter 6 of this standards for guidance. (4) Pipe conditioning. Pipe conditioning refers to a temporary increase of fuel gas odorant dosage rate for the purpose of conditioning or "pickling" new fuel gas piping to avoid a condition referred to as "odorant fade". The conditioning process is a chemical reaction between the steel pipe and the odorant that forms an iron sulfide "patina" on the interior pipe surface. Pipe conditioning or "pickling" reduces one potential cause of odorant fade that can allow a fuel gas leak to go undetected by personnel. For further information, see "Odor Fade - Possible Causes and Remedies" by Michael J. Usher, Elf Atochem North America, Inc., 2000 Market Street, Philadelphia, PA 19103. (5) Flammable gas charging. See Chapter 6 of this standard for guidance. Substantiation for change: Provide new annex text to guide the user regarding each commissioning action covered by this standard. 56(PS)-6.1.5 Submitter: James P. Walawender, Black & Veatch Corporation Recommendation: Revise text to read as follows: 6.1.5* Fluid media for testing or cleaning shall not introduce a flammable atmosphere into or create a fire hazard in the piping system being tested or cleaned except as permitted by 6.3.5. Substantiation: This article contradicts Articles 6.3.1.1, 6.3.5.1, and 6.3.5.2.

56(PS)-6.3.3.2 Submitter: Scot Pruett, Black & Veatch Corporation Recommendation: Reword text in Section 6.3.3.2 for clarification. 6.3.3.2 Where fuel gas is used to power the equipment necessary to implement the pipe cleaning

Substantiation: The text is confusing and difficult to determine if fuel gas is being used to clean the pipe, or fuel gas is used to power equipment that is cleaning the pipe.

as the fuel for the cleaning media supply system, it shall be piped and connected in accordance with ………….

56(PS)-6.3.6.2 Submitter: James P. Walawender, Black & Veatch Corporation Recommendation: Revise text to read as follows: 6.3.6.2 The point of discharge location shall be determined based on the process hazard analysis in accordance with 4.3 and the following criteria: Substantiation: The inclusion of the process hazard analysis in this article clarifies the requirement previously imposed by 4.3 56(PS)-6.5.2.2.1 Submitter: James P. Walawender, Black & Veatch Corporation Recommendation:6.5.2.2.1 The point of discharge shall be controlled with a remotely operatedSubstantiation: The text needs to be revised to indicate this a a remotely operated shutoff valve otherwise an individual may need to be right next to the pipe at the start and finish of the purging operation.

shutoff valve.

56(PS)-6.5.2.2.5 Submitter: James P. Walawender, Black & Veatch Corporation Recommendation: Revise text to read as follows: 6.5.2.2.5 Persons involved and not involved in the purging operations shall be evacuated from the all areas within 10 ft (3.1 m) of around the point of discharge in accordance with process hazard analysis [56: 4.3]. Substantiation: Depending on the hazards which are present, a 10 foot zone around the point of discharge may be insufficient to ensure an individual's safety during the commissioning process. 56(PS)-7.2.2 Submitter: Scot Pruett, Black & Veatch Corporation Recommendation: Add word purge to Section 7.2.2 for clarification 7.2.2 Outdoor Discharge of Residual Flammable Gas (purge). Substantiation: The addition of “purge” clarifies that the only reason they would see flammable gas is due to a purge and NOT that they could use flammable gas to clean the pipe.

56(PS)-7.2.2.1 Submitter: Gil Poe, ExxonMobil Production Company Recommendation: Section 7.2.2.1 The open end of a piping system being pressure vented or purged shall discharge directly to an outdoor location. The location shall take into account dispersion to avoid accumulation of flammable or inert gas in pocketed areas Substantiation: Outdoor locations do not guarantee dispersion away from occupied or occupiable areas where people can be exposed. 56(PS)-7.2.2.2.1 Submitter: James P. Walawender, Black & Veatch Corporation Recommendation: Revise text to read as follows: 7.2.2.2.1 The point of discharge shall be controlled with a remotely controlled shutoff valve. Substantiation: The text needs to be revised to indicate this is a remotely operated shutoff valve otherwise an individual may need to be right next to the pipe at the start and finish of the purging operation. 56(PS)-7.2.2.2.5 Submitter: James P. Walawender, Black & Veatch Corporation Recommendation: Revise text to read as follows: 7.2.2.2.5 Persons involved and not involved in the purging operations shall be evacuated from the all areas within 10 ft (3.1 m) of around the point of discharge in accordance with process hazard analysis [56: 4.3]. Substantiation: Depending on the hazards which are present, a 10 foot zone around the point of discharge may be insufficient to ensure an individual's safety during the commissioning process. 56(PS)-7.4.1.2 Submitter: James P. Walawender, Black & Veatch Corporation Recommendation: Revise text to read as follows: 7.4.1.2 Smoking, open flames, lanterns, or other sources of ignition shall not be permitted with in the area as defined by process hazard analysis [56: 4.3]. Substantiation: A minimum safe distance needs to be set to ensure that all hazards are eliminated prior to purging process.

56(PS)-Various Submitter: Charles Henrici, Fire Chief (Ret.) Recommendation: 3.3 General Definitions. I recommend that a definition of Commissioning as used in this standard is defined 3.3.4 Equipment Isolation Valve. A manual shutoff valve for shutoff of the flammable gas to each piece of equipment. I question the word manual in this definition. Can it be an automatic valve also? I suggest removing the word manual. 6.2.7* A piping system shall be tested as a complete unit or in sections. Under no

circumstances shall a valve in a line be used as a bulkhead between flammable gas in one section of the piping system and test medium in an adjacent section, unless a double-block-and-bleed valve system is utilized. This needs to be defined.

6.2.8* A valve, including the valve closing mechanism, or component shall not be subjected to the test pressure unless it can be determined that the valve or component is designed to safely withstand the pressure. How is this determined? I suggest the deletion of “it can be determined”.

6.3.1.2 An alarm shall precede the start of cleaning in accordance with the process hazard analysis.

I suggest changing this to “A warning alarm” 6.3.6.1 Target. Where a target is used to indicate debris during the cleaning process, it

shall be designed and secured to withstand the velocity and pressure of the exiting media and debris without breaking or failing. Target needs to be defined as it is used here.

6.3.6.2 The point of discharge location shall be determined based on the following criteria: (10) Management of Change What is Management of Change? 6.5.2.2.1 The point of discharge shall be controlled with a shutoff valve. The standard

needs to address where this valve should be located. 6.5.3 Combustible Gas Indicators. This section needs to include requirements for the location of these Gas Indicators. 7.2.2.2.1 The point of discharge shall be controlled with a shutoff valve. The standard

should address the location of the shutoff valve. 7.2.2.2.4 Purging operations introducing inert gas shall be stopped when the fuel

flammable gas level (by volume) detected within the pipe and within a 5 ft (1.5 m) radius of the point of discharge is less than 25 percent of the lower flammable limit. This needs to be expanded as to how this is measured and with what.

7.4.1.3.1 Where cutting torches, welding, or other sources of ignition are unavoidable, it shall be determined that all sources of gas or gas–air mixtures have been secured and that all flammable gas or liquids have been cleared from the area. As an AHJ I can have a field day with this! This needs a lot of work. What is meant by secured? All flammable gas or liquids have been cleared from the area.

This is too broad of a statement. As the AHJ I would require all other piping systems and containers in the area to be removed. What are the boundaries of “the area”?

56(PS)-Various Submitter: John Ritzmann, Alexandria, VA Recommendation: 1.1.2 (7). Because of the double negatives in this statement, it is not obvious to me whether propane vapor or liquid piping is covered or not, say in a propane vapor piping system on a farm or potato chip factory. I think you meant it to be covered, but I get lost in the negatives. (not apply to... except undiluted gas). Definition of PIG. I guess this is what is meant in this document but there are many types of pigs, a scraper pig being only one. Definition of Bulk Gas System. I am a little confused about Liquid Petroleum Gas here. Technically it is a liquid in storage, not a compressed gas. 6.5.2.2.4 Isn't more than 90% acceptable? I think you meant "at least" 90%. Nit-picky, but enforcers can be that way, too, especially when trying to understand new rules they are not familiar with. 90% is a conservative requirement, but easily achieved in small diameter piping. Tanks and large piping present a different story. 6.5.3.1 I think it is important to stress that the combustible gas meter is to be calibrated for the gas being measured. One common mistake is to grab a CGI calibrated for natural gas and apply it to propane vapor. There is a significant difference in how the meters react and read. 6.3.6.2 My most nit-picky comment: I think the list of criteria is a list of considerations, not criteria. Personnel in the area is something to be considered, not a criteria to me. Finally, the document is only dealing with purging into and out of service, not the piping design, although this is noted in the scope. Shouldn't the title reflect this a little more clearly? From the title, it sounds at first like it seeks to lay out design rules. 56(PS)-Various Submitter: Dale Evely, Southern Company Recommendation: 1. Section 6.2.7 has an asterisk by it but there is not any accompanying Annex A material. 2. The referenced sections within the text are incorrect in sections: 6.5.1, 6.5.2.2, 6.5.2.2.3, 7.2.1, 7.2.2.2, 7.2.2.2.3, and 7.5. 3. I was pleased to find the defined terms “Purge into Service” and “Purge out of Service” in Chapter 3. Unfortunately, the terms were not used in the text but, instead, the confusing use of the term “Purge” to mean both of these was continued as is done in NFPA 54. Chapters 6 and 7 should be revised to use these new terms where appropriate. 4. In my opinion, the minimum 10 feet distance stated in sections 6.5.2.2.2 and 7.2.2.2.2 does not seem adequate for proper protection of personnel and equipment, even if it is what is specified in NFPA 54.

56(PS)-Various Submitter: Richard Palluzi, ExxonMobil Research and Engineering Co Recommendation: I believe section1.1.2 should be modified to EXCLUDE pilot plants and laboratories. Both are rather specialized and outside the scope of this standard. Section 6.1.5: There are some cases where it is necessary to clean using a combustible or even flammable material for cleanliness or purity. Rather than a blanket prohibition. I suggest the section be modified to say "unless a detailed hazard analysis and risk mitigation plan has been developed by a competent person". Section 6.2.1 is a bit vague. I suggest that words like "At a minimum this documentation shall include what parts of the system were tested, with what and note the results of the test." Section 6.3.2 is not clear as to specifics of the alarm. I think requiring a audible notification to all personnel involved in the testing or facility might be a better wording. Section 6.5.1 suggests that simply adding inert gas is enough providing the requirements of section 6.5.1.1 are met. I think that some cautionary wording noting that inert gas often does not sweep a line in a clearly defined plug is necessary and that a longer purge out period or a number repeated pressure/vent cycle may be necessary to ensure oxygen concentration has been lowered sufficiently. 56(PS)-Various Submitter: Russ Cochran, AES Global Insurance Company Recommendation: 6.2.7 – When a test medium is used in a section of pipe and the flammable gas is close buy, containment of the flammable gas is usually by inserting a blank after the block valve if the pipe is disconnected. A double block and bleed should only be used when the pipe is not required to be disconnected, and then the integrity of the valve should be checked. 6.2.8 – this section suggests that a “valve shall not be subjected to the test pressure unless it can be determined that the valve is designed to safely withstand the pressure”. This is a little “grey” does it imply you have to test the valves capability or just rely on the manufacturers data sheet? 6.5.1 – the reference to section 5.5.2 should be 6.5.2? 6.5.2.2 – as above 6.5.2.2.3 – as above 7.2.1 – there is no section 5.3.2.2? 7.2.2.2 – the reference to section 6 should be section 7? 7.2.2.2.3 – the reference to section 5 should be section 6? 7.3.2 – allowing inert gas to be released indoors should have some controls identified, just measuring the oxygen levels seems risky?

56(PS)-Various Submitter: Kevin Ritz, Baltimore Gas & Electric Recommendation: Please see the following comments associated with identified paragraph numbers:

1) The terms industrial and commercial applications are undefined in the definitions chapter 3 and should be included. The definition in the NFPA Glossary for industrial occupancy may be appropriate. Commercial occupancy/facility is not defined in the NFPA glossary.

2) 1.1.2(4) Annex material should also identify 49 CR 193 in addition to NFPA 59A 3) 1.1.2(7) Annex material should be added similar to that found in NFPA 59 A.1.1.1

identifying 49 CFR 192 pipeline safety regulations 4) 1.2 Purpose – The purpose statement is not clear. The statement uses the tram

“maintaining” related to the piping system. This leads to confusion because the way in which the term is used tends to indicate how this standard includes requirements for maintaining piping systems, such as prevention of corrosion (internal, external, etc.), where I believe the intent of 1.2 was to say preparing of piping systems for maintenance.

5) 1.2.1 The use of illustrations in assisting users in understanding what a piping system is meant to include should be considered. NFPA 59 and NFPA 59A use a number of illustrations for similar purposes and have been found to be very useful

6) 2.3.1 Both B31.1 and B31.3 have more recent editions and should be utilized accordingly.

7) 3.3.7 The definition for Pipeline Inspection Gauge (PIG) is insufficient. PIG provide a much wider variety of uses than just being fitted with a scrapping tool. PIG are used extensively in the pipeline industry for separation of products being sent through the pipeline at the same time, and even more important they are used to perform internal inspections of pipeline conditions looking for any defects.

8) 4.3.1(2) The definition of ignition sources and how they are used should align with those found in NFPA 59 and 59A as ignition sources are more than just static

9) 4.3.1(9) Why would you need to notify an AHJ when performing any purge. While it might be considered as part of the hazard analysis, the size, location, and purge media being used must be considered. It is likely that all AHJ would not want to be notified all the time on a number of purges

10) 4.3.1(17) Identifying “Management of Change” is not clear. A more detailed explanation of the term should be considered either in the main body of the standard or in the annex. The intent of 4.3.1(17) is to ensure the hazard analysis and plan is communicated with affected personnel and public.

11) 4.3.1(19) Should reference NFPA 51B standard 12) 6.1.1 Pressure testing as used in this sentence should be further clarified to

state that pressure testing shall be conducted as required by applicable codes/standards (ASME B31.3, NFPA 59A, NFPA 59, etc.)

13) 6.3.6.2(5) The term “atmospheric conditions” should be expanded upon to further describe what factors should be considered and how each might affect the point of discharge location

14) 6.3.6.2(10) see statement in bullet item 10 above 15) 6.5.1 – I do not believe this is necessary for all size piping. Depending upon

size, purge flow, turbulence within the pipe, you may not always create a hazard 16) 6.5.3.2 CGI’s should also be capable of displaying LEL and should be calibrated

based on the gas or ranges of gases being testing/monitored 17) 7.2.2.2.4 The LEL should be monitored at the end of the pipe and not a 5 foot

radius around the pipe. 18) 7.3.2.1 I believe the term “used” instead of installed should be utilized in the

sentence. The way installed is used implies that a fixed instrument must be permanently installed were as the term used would imply the use of a hand held instrument be used such as a CGI

19) 7.4.1.3.2 I believe the proper reference should be 6.3 20) 7.5 – I believe the reference should be 6.5 21) A1.1.1.1 NFPA 54 also has a definition for a service shutoff valve which is

equivalent to an isolation valve. NFPA 54 should be included in list