CommentsOn - American Petroleum Institutemycommittees.api.org/standards/cre/soee/Ballot...

CommentsOn

Template for comments and secretariat observations

Date:

Document: ISO/

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MB1

Clause/Subclause/Annex/Figure/Table(e.g. 3.1, Table 2)

Paragraph/List item/Note/(e.g. Note 2)

Type of com-ment2

Comment (justification for change)

Proposed change

Secretariat observationson each comment submitted

API Ballot Comments and Resolution

Ballot: Review of API 500 - Third Edition

Proposal:

Ballot ID: 1592

Date: March 3, 2009

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Voter Name(Vote)

Clause No./Subclause No./Annex(e.g. 3.1)

Type of Comment

Comment (justification for change) by the Voting Member

Proposed change by the Voting Member

Comment Resolution

Dan Eaton

Marathon Petroleum Company LLC

(Affirmative)

1.2.1

Technical

Nonelectrical disciplines have frequently tried to use RP 500 to determine whether motorized vehicles may be driven into and around process units. RP 500 was not intended for this purpose. The added wording would discourage users from making the assumption that this document applies to powered vehicles.

Revise Item c) to read as follows: the suitability of locations for the placement of non-electrical incendiary equipment including powered vehicles and

Dan Eaton


(Affirmative)

2.1

Technical

NFPA 45 contains a section that discusses area classification for laboratories. This should be referenced in RP 500.

Add a Reference to NFPA 45 Laboratories

Dan Eaton


(Affirmative)

6.1

Technical

Different gasses may be present during startup and idling of process units. For example refinery fuel gas containing more than 30% hydrogen may be used to purge a Crude unit during startup up. It is not general practice to designate such areas as Group B based merely on these conditions.

Add at the end of section: Abnormal conditions may include startup our idling of process units. Although different materials may be present during these conditions these conditions would not normally be used for determining the gas grouping unless they exist for a significant period of time or are likely to introduce new hazards.

Dan Eaton


(Affirmative)

Figure 6 (Reference Section 8.2.1.1.1)

Technical

Covered floating roof type tanks are not adequately covered in either Figure 6 or Figure 7. Adding this note would eliminate an unnecessary Division 1 area around vents for covered floating roof tanks. It would be prudent to classify the internal area above the floating roof as Division 1 but the small amount of normal vapor leakage would quickly dissipate at the opening of a vent.

Add Note 5: For covered tanks with an internal floating roof the 1.5m (5 ft) Division 1 sphere around the openings for vents and hatches may be omitted.

Dan Eaton


(Affirmative)

D.5.2

Technical

Table D.1 showing hazard radii for pumps appears to be missing from the ballot draft copy.

Add Table D.1

Dan Eaton


(Affirmative)

Figure D.4

Technical

The title is not a correct description for this table. It does not provide recommended hazard radii for lighter than air gases. It instead provides the recommended extent for the classified area for a given hazard radius.

Change title to "Adequately Ventilated Process Area with Point Source Containing Lighter-than-air Gases or Vapors"

Dan Eaton


(Affirmative)

D.5.7 and D 5.8

Technical

The paragraph header for D 5.7 is misplaced and D 5.8 header is missing.

On page 146 add "D 5.7 Flanges" in bold on new line in front of the paragraph starting with the words "Flanges many flanged joints are rarely broken...". Delete "Flanges" from first sentence in paragraph.

On page 147 add a new paragraph header for "D 5.8 Determining the Extent of the Division 2 Location" where "D 5.7" is presently located.

Dan Eaton


(Affirmative)

D.6.1

Technical

This section does not provide guidance for determining the hazard radius for point sources containing light than air gases. The only clear determination is for compressors where a hazard radius of 15 feet is specified.

Add a table similar to table D.2 for determining the hazard radius for point sources containing lighter than air gases.

Dan Eaton


(Affirmative)

Table D.2

Editorial

"G" is no longer used in Fluid Category Figure D.1

Change "G" to "Gas" on second line of table.

Dan Eaton


(Affirmative)

D 5.4 Table D.2

Technical

For clarification purposes add a line for Category 4 materials showing a hazard radius of 0.

Add line to table:

Category 4 and dashes in other columns.

Dan Eaton


(Affirmative)

9.2.1.1.1

Technical

I would like to see more guidance for classification of electrical manholes and conduit duct banks located beneath Division 2 areas. The note in this section cautions that duct banks and manholes may collect flammable liquids and vapors but offers no guidance on classification of these areas. The classification is not significant for equipment location but may have an impact on seal locations for conduits as come above grade.

I offer the suggested change as a starting point for this discussion.

Add the following note: "Below grade electrical manholes and duct banks are normally classified the same as the area above grade where these are located."

Lorraine Padden

Padden Engineering, LLC

(Affirmative)

1.1.2

Editorial

NFPA 70 "and" API 14F

change or to and

PA 70 "and" API 14F

Lorraine Padden


(Affirmative)

6.2.1.1

Editorial

The definitions of Class I should align with tne new definition in 2008 NEC.

Change "flammable gases or vapors" to "flammable gases, flammable liquid-produced vapors, or combustible liquid-produced vapors"

Change "flammable gases or vapors" to "flammable gases, flammable liquid-produced vapors, or combustible liquid-produced vapors"

Lorraine Padden


(Affirmative)

6.2.1.1(a)

Technical

The definitions of Class I, Division 1 should align with tne new definition in 2008 NEC.

(1) Change "flammable gases or vapors" to "flammable gases, flammable liquid-produced vapors, or combustible liquid-produced vapors"

(2) Change "gases or vapors" to "flammable gases, flammable liquid-produced vapors, or combustible liquid-produced vapors"


Paragraph 2, classification usually includes: Consider adding information from NEC 500.5(B)(1) FPN 1 parts (4) and (7)and FPN 2 parts (1) through (5)




Paragraph 2: Consider adding:Drying rooms or compartments for the evaporation of flammable solvents,Gas generator rooms and other portions of gas manufacturing plants where flammable gas may escape;

(1)The inside of inadequately vented enclosures containing instruments normally venting flammable gases or vapors to the interior of the enclosure

(2) The inside of vented tanks containing volatile flammable liquids

(3) The area between the inner and outer roof sections of a floating roof tank containing volatile flammable fluids

(4) Inadequately ventilated areas within spraying or coating operations using volatile flammable fluids

(5) The interior of an exhaust duct that is used to vent ignitible concentrations of gases or vapors

Lorraine Padden


(Affirmative)

6.2.1.1(B)

Technical

The definitions of Class I, Division 2 should align with tne new definition in 2008 NEC.

(1) Change "volitile flammable liquids or liquified flammable gases" to "flammable gases, flammable liquid-produced vapors, or combustible liquid-produced vapors"


(3) Change "gases or vapors" to "flammable gases, flammable liquid-produced vapors, or combustible liquid-produced vapors above their flash point"

(1) Change "volitile flammable liquids or liquified flammable gases" to "flammable gases, flammable liquid-produced vapors, or combustible liquid-produced vapors"


(3) Change "gases or vapors" to "flammable gases, flammable liquid-produced vapors, or combustible liquid-produced vapors above their flash point"

Lorraine Padden


(Affirmative)

General

Editorial

Throughtout to document definitions for "gases and vapors" should align with tne new definitions in 2008 NEC.

Change "volitile flammable liquids or liquified flammable gases" to "flammable gases, flammable liquid-produced vapors, or combustible liquid-produced vapors"

Change "gases or vapors" to "flammable gases, flammable liquid-produced vapors, or combustible liquid-produced vapors"

Change "volitile flammable liquids or liquified flammable gases" to "flammable gases, flammable liquid-produced vapors, or combustible liquid-produced vapors"

Change "gases or vapors" to "flammable gases, flammable liquid-produced vapors, or combustible liquid-produced vapors"

Louis Barrios

Shell Global Solutions (US) Inc.

(Affirmative)

Whole Document

Technical

I will send Gordon Robertson a separate spreadsheet with my comments.

Jim Cospolich

Waldemar S. Nelson & Company, Inc.

(Affirmative)

Inside Cover of 2nd Ballot Draft - page 3 of 175

Editorial

The 2nd Ballot Draft, 12/9/08, contains an inside cover page with an error (page 3 of 175 in the file-possibly the inside cover not on cover stock). The error is that the additional wording "Upstream Segment" appears under the document title wording. API PR 500 is applicable to upstream, downstream, and pipeline so this added wording is very misleading.

Delete the additional wording "Upstream Segment" that appears under the document title wording on the second cover page (page 3 of 175 in the file "2nd Ballot Draft, 12/9/08").

Jim Cospolich

Waldemar S. Nelson & Company, Inc.

(Affirmative)

Introduction (page 8 of 175 in 2nd Ballot Draft,

Editorial

The Introduction section is missing information on the second edition and subsequent reaffirmation of API RP 500 subsequent to the first edition issued June 1, 1991. Also it is suggested that in the last sentence of the first paragraph the description of joint jurisdictions for the first edition be reordered to read, "API Refining, Production, and Transportation Departments" to correspond to the old RP 500A, RP 500B, and RP 500C order whose history immediately follows.

Revise the last sentence at the end of the first paragraph and add two additional sentences as follows:

The first edition of this Recommended Practice was issued June 1, 1991 under the joint jurisdiction of the API Refining, Production, and Transportation Departments. The second edition was published in November 1997. The second edition was reaffirmed in November 2002.

Rick Mitchell

Devon Energy

(NonVoter)

Technical

Estellito Rangel Jr.

Petrobras

(NonVoter)

As related

Technical

Introduction

For all comments, it was considered that - first of all - the following principle, expressed on 1.1.1, needs to be followed:

"This publication is only a guide and requires the application of sound engineering judgment".

So, a special care has to be taken when some distances are "defined" on figures, because the professional team responsible for the study has the duty of defining distances.

Today we are faced with some "area classification studies" that only "copy and paste" the API RP 500 figures, and so, this practice is not engineering - even worst, this is not safe to the utility and persons.

So, it is very important to highlight that "Neither API nor any of API's employees, subcontractors, consultants, committees, or other assignees make any warranty or representation, either express or implied, with respect to the accuracy, completeness, or usefulness of the information contained herein, or assume any liability or responsibility for any use, or the results of such use, of any information or process disclosed in this publication" (see Special

Notes section).

1) 1.2.1 - first paragraph

Sugestion: remove the expression "where may be a risk of ignition due to"

Motivation: area classification is related with the possibility of explosive atmospheres

Proposed change: "It is intended to be applied where there may be a risk of the presence of flammable gases, flammable liquid-produced vapors, or combustible liquid-produced vapors, mixed with air, under normal atmospheric conditions (identified throughout this document as flammable gases and vapors)."

2) 1.2.2 - first para:

Suggestion: remove the words "specific" and "commonly"

Motivation: Today we have many new process units, especially regarding heavy oils, that may be not so "common" in old units.

Proposed change: "Recommendations for determining the degree and extent of classified locations for some examples of situations encountered...

3) 2.1

Suggestion: remove API Publication 4322, Fugitive Hydrocarbon Emissions from Petroleum Production Operations, Volume I and Volume II

Motivation: Both volumes are withdrawn

Proposed change: remove them

4) 2.1

Suggestion: remove "ISA Electrical Systems for Oil and Gas Production Facilities"

Motivation: document not found

Proposed change: remove

5) 2.1

Suggestion: remove "ISA Electrical Instruments in Hazardous Locations"

Motivation: document not found

Proposed change: remove

6) 3.2.5.5

Suggestion: remove "fire or explosion hazards may exist due to"

Motivation: the area classification concept is related with the probable presence of explosive atmosphere. Ignitions sources must be avoided on those locations after they have been identified.

Proposed change: "A location where explosive atmospheres due to flammable gases or vapors, flammable liquids, combustible dust, or ignitable fibers or flyings may exist. Unless specifically indicated otherwise, locations containing combustible dust, ignitable fibers or flyings are outside the scope of this RP."

7) 3.2.18

Suggestion: modify the definition

Motivation: harmonization with other standards

Proposed change: to use the same definition of NFPA 30: 2008 3.3.20 - "Releases of flammable vapor that continuously or intermittently occur from process equipment during normal operations."

8) new item 3.2.41

Suggestion: include a new defined term

Motivation: in non-English spoken countries the term "lubricator" can be confusing.

Proposed change: "Lubricator = A specially fabricated length of pipe with union connectors and bleed-off valves that is temporarily installed above the upper valve on the christmas tree. Lubricators afford a method of sealing off pressure yet still allow the passage of devices, usually run on wireline, into a producing well without having to kill the well."

As above


Petrobras

(NonVoter)

as related

Technical

9) 6.2.3.3

Suggestion: leave the "transition zone concept"

Motivation: this concept seems to have no sound justification. The definition of division 2 in related with abnormal conditions, and only when the consequences of an abnormal condition imply on bigger extent than motivated by Division 1 conditions, should it be represented on drawings beyond Division 1 regions.

Proposed change: The Division 2 classification is related with abnormal conditions. These abnormal conditions might be, for example, unfavorable air currents or an abnormally large release of flammable material. A vaportight barrier can be used, however, to prevent the gas or vapor from spreading. Also, as discussed in 6.2.1.1 b), adequate positive-pressure ventilation from a source of clean air can be used as safe measure.

10) 6.2.3.4

Suggestion: remove definite distances outside a building, as "3 m (10 ft) from the non-vaportight"

Motivation: considering that each location can have specific ventilation characteristics, it can't be guaranteed that a given distance is safe.

Proposed change: " If no specific transition zone is recommended by Section 8 through Section 14 (as applicable), the Division 2 area should extend to the distance given after considering the ventilation characteristics of the location."

11) 6.2.3.6

Suggestion: remove definite distances outside a building, as "1.5 m (5 ft) past the openings"

Motivation: only the knowledge of the ventilation characteristics of the location and the leakage characteristics can define safe distances. shortage

Proposed change: "The area outside such openings in buildings that are classified Division 2 should be considered Division 2 if considering the ventilation characteristics of the location, a possibility to reach an explosive atmosphere is applicable.

12) 6.2.3.7

Suggestion: remove the concept of "transition zone"

Motivation: Division 2 by definition is related with "abnormal" situations. So, a bigger extent than Division 1 can be justified only in cases where the consequences of an abnormal operation are bigger than those related with normal operation.

Proposed change: Modify the item to: "Consider the case of a nonenclosed source that releases flammable gas or vapor during normal operations. The classified area around the source would appear as a Division 1 concentric circle around the source. This would be surrounded by a concentric Division 2 circle only if in abnormal operations a flammable mixture is expected to

occur beyond the defined Division 1 area.

13) 6.3.2.4.5 - NOTE

Suggestion: put a warning about the use of the equation

Motivation: Considering that a mathematical formula express a given model, it is recommended to alert users regarding this.

Proposed change: The specific equations below will estimate the minimum area for... considering the conditions described below.

14) 6.4.3

Suggestion: It is necessary to alert users that extents need to be evaluated.

Motivation: Figure 4 seems not to reflect the correct evaluation of the situation, because it can't be said that all the enclosed area will be classified despite its internal volume or internal ventilation.

Proposed change: An enclosed area that is adjacent to a classified area, and that is not separated from the classified area by a vaportight barrier, should be classified the same as the highest classification included, and the extents of the hazardous location shall be assessed. Reference Figures 4 and 5

as above


Petrobras

(NonVoter)

as related

Technical

16) 6.5.1

Suggestion: interchange 6.5.1 with 6.5.2

Motivation: the 6.5.1 item requires 6.5.2 to be read first

Proposed change: interchange

17) 6.5.2

Suggestion: remove "to meet the objectives of 6.5.1 follow"

Motivation: the objective of the item is to define the type of detectors.

Proposed change: change the first phrase to: "The criteria for use of combustible gas detection

equipment are:"

18) 6.5.1 a)

Suggestion: modify the phrase

Motivation: gas detection is not 100% confident, because some portions can accumulate flammable

gases outside the range of the sensors, masking the real scenario.

Proposed change: An inadequately ventilated area containing equipment that could release flammable

gas or vapor can be designated as Division 2, considering that the system complies with 6.5.2 e).

19) 6.5.2 e) NOTE

Suggestion: Promote the NOTE to the text

Motivation: To aim safety of the installation, the NOTE needs to be a requirement.

Proposed change: In the case of sensing 40 % LFL or a gas detection system malfunction, corrective

action to reduce the gas concentration shall be initiated immediately.

20) 6.5.4

Suggestion: Include a new item

Motivation: To alert users about the use of gas detectors

Proposed change: include the text: Area classification is based on an "estimated scenario model",

considering estimatives of the process operational data. Gas detectors are based on real presence

of gas. The reccomendations given at 6.5 and subsections must consider that: the expansion of gas

release can rise the concentration from 10% LEL to 100% LEL very quickly; the detection of the gas

cloud is primary dependent on the detector location; the response and efficiency of the chosen

dilution system can be inadequate to provide an effective action in safe time; the dilution and

detection systems can be affected by malfunctions. These factors need to be assessed before

deciding to use gas detectors to reduce area classification.

21) 7.1.3

Suggestion: modify the text

Motivation: location of sources is not the only factor to be considered in area classification

Proposed change: modify the phrase to: "The extent of classified locations is determined by the local ventilation characteristcs and the location of potential sources of release....

22) 7.2.3

Suggestion: modify the last phrase.

Motivation: It is necessary to emphasize that area classification is an engineering study, not just a "copy and paste" practice.

Proposed change: "These techniques are recommended to be used with good engineering judgment to define area classification boundaries for specific applications.

23) 7.2.3 - NOTE

Suggestion: modify last phrase

Motivation: the area classification study needs to be as precise as possible

Proposed change: The alternate method may be used to classify new grassroot facilities if the level of detailed information necessary to apply the method is available when the area classification is determined.

as above


Petrobras

(NonVoter)

as related

Technical

24) 8.1.1

Suggestion: modify second phrase

Motivation: it is necessary to fix the misconception that a figure can be applies to all

situations, without any additional engineering concept.

Proposed change: The examples have been developed by experience in industry and may be applicable

to many petroleum facilities, depending on the process characteristics. Section 9 through Section

14 provide guidance for classifying locations within specific refining, production, and

transportation facilities.

25) 8.2.1.2.1


Motivation: the area classification study is a duty of professional team analysis and the related

extents can't be defined without considering the conditions given in section 7.

Proposed change: Areas in and around fixed roof flammable liquid storage tanks in nonenclosed

adequately ventilated areas are in many situations, classified as shown in Figure 6. Reference 5.2

for a discussion of flammable liquids.

26) 8.2.1.2.1 NOTE


Motivation: the extents of classified locations must be defined by the responsible person(s), and

not by the standard. (as example, see Fig 6 note 2)

Proposed change: If there is no dike or no remote impounding, the Division 2 area can be extended

until 3 m (10 ft) horizontal distance from the tank shell.

27) 8.2.1.2.2


Motivation: the extents of classified locations must be defined by the responsible person(s),

after analysing the location characteristics and not by the standard.

Proposed change: replace "... areas are classified as shown in Figure 6" by "... areas can,

depending of the location characteristics, be classified as shown in Figure 6."

28) 8.2.1.3.1


Motivation: the extents of classified locations must be defined by the responsible professional

team, after analysing the location characteristics and not by the standard

Proposed change: replace "... areas are classified as shown in Figure 7" by "... can, depending of

the location characteristics, be classified as shown in Figure 7."

29) 8.2.2.1




Proposed change: replace "... are classified as shown in Figure 9" by "... can, depending of the

location characteristics, be classified as shown in Figure 9."

30) 8.2.2.2




Proposed change: replace "..., are classified as shown in Figure 10" by "... can, depending of the


31) 8.2.2.3






32) 8.2.2.4



team, after analysing the location characteristics and can't be guaranteed by the standard for all

situations.



as above


Petrobras

(NonVoter)

as related

Technical

33) 8.2.2.5




situations.



34) 8.2.2.6

Suggestion: fix the notation of the distance

Motivation: write the correct unit

Proposed change: replace "058 m" by "0.58 m"

35) Figure 12

Suggestion: add a note

Motivation: it is not recommended to say in 8.2.2.4 that the location "is classified as shown". It

is safer to say that for many situations the figure applies.

Proposed change: add the note: Distances given are for typical petroleum facilities: they must be

used with judgement, with consideration given to all factors discussed in the text.

36) Figure 13


Motivation: it is not recommended to say in 8.2.2.5 that the location "is classified as shown". It

is safer to say that for many situations the figure applies.



37) Figure 14


Motivation: In 8.2.3.1.1 is written that "the criteria are too diverse to specify distances.



38) 8.2.3.2.1




situations.



39) Figure 15


Motivation: Depending on ventilation and process characteristcs, classified location extents can

differ from a given figure.



40) Figure 18


Motivation: In 8.2.3.3.4 is written that "the criteria are too diverse to specify distances.



41) Figure 19


Motivation: In 8.2.4.2 is highlighted that "the extent is based on the longest tank...", so

special considerations apply.



42) 8.2.6.8

Suggestion: remove the item

Motivation: it seems to be conflicting with the definitions. Division 1 or 2 classification should

be defined after considering if an explosive atmosphere can be formed during the normal charging

process. "Inadvertent overcharging" is not expected to define classification.

Proposed change: remove the item

43) 10.4.1.1 NOTE 1

Suggestion: remove part of the text

Motivation: "satisfactory experience" is not a sound argument.

Proposed change: end the phrase with: "...considered to satisfy the requirements of adequate

ventilation."

as above


Petrobras

(NonVoter)

as related

Technical

44) Figures 29 to 32


Motivation: In 10.4.1.1 there are some considerations about the location that must be assessed.



45) 10.4.3

Suggestion: modify the numbering of subitens

Motivation: it is not practical zero as subsection

Proposed change: give new numbering for subitens as 10.4.3.1, 10.4.3.2 and 10.4.3.3.







47) Figure 57

Suggestion: 1) add a note 2) remove see 10.13 note 4





48) 10.12 NOTE 4

Suggestion: fix reference to figure 57 as 10.13 does not exist.

Motivation: figure 57 is not for open drains

Proposed change: remove "Reference Figure 57"

49) Figure 58

Suggestion: fix reference as 10.13 does not exist

Motivation:

Proposed change:


Suggestion: fix reference as 10.13 does not exist, and add a note

Motivation:

Proposed change:add the note: Distances given are for typical petroleum facilities: they must be



Suggestion: fix reference as 10.16.4.2 does not exist and add a note

Motivation:





Motivation:





Motivation:

Proposed change: add the note: Distances given are for typical marine units: they must be used

with judgement, with consideration given to all factors discussed in the text.

54) Figure 93 to 106


Motivation:



55) E 6.2

Suggestion: add elevation view as a recommended information to be included in the documentation

Motivation: plan view does not inform about the heights of hazardous location extents

Proposed change: The customary means of documenting this information is with an area

classification drawing with plan and elevation views' drawings of the location depicting:

56) E 6.2 c

Suggestion: modify text

Motivation: elevations are important

Proposed change: ...Elevations or sections are required where different classifications apply at

different elevations. ...

as above


Petrobras

(NonVoter)

as related

Technical

15) Figures 4 and 5

Suggestion: Modify the figure

Motivation: It does not seem reasonable that all the enclosed area will be classified despite its internal volume or internal ventilation.

Proposed change: Show the hatched area only partially inside the enclosed area

as above

Art Neubauer

Arseal Technologies LLC

(Negative)

2.1

Editorial

NFPA 45 is now referenced in the document and it should be added to the list of industry standards.

Add: NFPA 45 Standard on Fire Protection for Laboratories Using Chemicals

Art Neubauer


(Negative)

4.1(c)

Editorial

Remove the letter "s" from "installations" and "devices" to make the sentence read better.

The mixture must be ignited. When classifying locations, the potential source of ignition is understood to be an electrical installation or device operating at energy levels or at temperatures sufficient to cause ignition.

Art Neubauer


(Negative)

5.2.4.1

Editorial

Re word sentence to place introductory thought at the front of the sentence.

Class III liquids will release vapor in the flammable range at their surfaces if heated above their flash points, but the extent of the classified location ordinarily will be very small and near the point of release.

If heated above their flash points, Class III liquids will release vapor in the flammable range at their surfaces but the extent of the classified location ordinarily will be very small and near the point of release.

Art Neubauer


(Negative)

Figure 2

Editorial

Figure 2 is supposed to be depicting a non-enclosed area adjacent to a source of vapor, however the area is enclosed.

Change figure to have open sides on right and bottom of enclosed area.

Art Neubauer


(Negative)

6.5.2 (c)

Editorial

The first sentence is not clear as written.

b)The gas detection equipment is of a type listed or approved by a nationally recognized testing laboratory (NRTL) as gas detection equipmentcombustible gas detectors that have been evaluated for explosions in Class I hazardous atmospheres and the risk of fire and electric shock. This evaluation also includes performance testing for the specific gas listed and safe operation of the instrument in the presence of flammable and explosive mixtures of representative gases with air.

b)The gas detection equipment is of a type listed or approved by a nationally recognized testing laboratory (NRTL) as gas detection equipment. For example, combustible gas detectors must be evaluated for the the risk of fire and electric shock and explosions in Class I hazardous atmospheres. This evaluation also includes performance testing for the specific gas listed and safe operation of the instrument in the presence of flammable and explosive mixtures of representative gases with air.

Art Neubauer


(Negative)

6.3.1.2

Editorial

New sections have been added to the document that do allow the reclassification of area from classified to unclassified based on ventialtion only.

Providing ventilation to allow the reclassification of an enclosed area from classified to unclassified is not allowed in enclosed areas containing devices handling hydrocarbons. Equipment as described by 6.2.4.1; hydrocarbon-fueled prime movers with fuel gas pressure at 125 psig or less as provided for in 8.2.5; and, laboratory and analyzer applications as described in sections 8.2.8.2.4, 8.8.3.3 and 8.2.8.5.3.1 are excluded.

Art Neubauer


(Negative)

8.2.8.3.3

Technical

Per section 8.2.8.3.2, if a location is inadequately rated, the area would be classified as Division 2. If a location is adequately ventilated by mechanical means and that mechanical ventilation fails, then the location will default to a Division 2 location. If the equipment used in that area is not rated for Division 2, then it should be automatically shutdown.

All locations or areas that are determined to be adequately ventilated as per the requirements of Section 6.3 by mechanical means with a minimum of six (6) air changes per hour where the sample containers are open may have the interior classified as unclassified where the loss of ventilation initiates an alarm for corrective action and automatically disconnects power from all electrical devices in the area that are not suitable for Division 2.

NOTE Electrically heated parts and components could remain at or above the ignition temperature for some time after de-energization.

Art Neubauer


(Negative)

Figure 88 and 89

Technical

These figures should be part of Section 11, but they show up within the text of Section 12.

Relocate Figures 88 and 89 prior to the beginning of Section 12.

Art Neubauer


(Negative)

Annex C, 8th Paragraph

Editorial

The current wording indicates that there are no exceptions to having a classified area.

This RP applies the methodology of fugitive emissions that was adopted by the 1990 edition of NFPA 30 and is now an informative Annex F to NFPA 30. The method recommended by this Recommended Procedure results in a safety factor of 16 that includes the inherent safety factor of four (since the maximum vapor-air concentration permitted is 25 % of the LFL). In many cases, this permits an area to be classified Division 2 instead of Division 1; however an enclosed area cannot be designated unclassified if it contains process, storage, transfer, or similar equipment handling flammable gases or vapors. These areas must carry at least a Division 2 classification except as identified in section 6.3.1.2.

Art Neubauer


(Negative)

Annex D.3.2 Paragraph 2

Editorial

Reword sentence to clarify.

For example, when liquid propane is released, it immediately flashes to a vapor. At 90F and 150 psi, one-third of propane flashes immediately and cools the liquid to 44F, the liquid continues to boil and vaporize as it absorbs heat from the ground.

Daniel Adjetey

BP America

(NonVoter)

3.2.3

Technical

barrier, vaportight:

A wall or other obstruction that will limit the passage of gas or vapor at atmospheric pressure, thus preventing the accumulation of vapor-air or gas-air mixtures in concentrations above 25 percent of their lower flammable (explosive) limit, LFL (LEL).

Definition of "limit" is ambiguous.

Change "limit the passage" to "prevent the passage" to avoid any ambiguity in the definition of limit.

Daniel Adjetey

BP America

(NonVoter)

3.2.5.6

Technical

"unclassified locations (non-hazardous location):Locations determined to be neither Class I, Division 1 nor Class I, Division 2; or any combination thereof.

Why have the words or any combination thereof?

Deleting or any combination thereof" since it does not appear to add any more meaning to the definition of unclassified locations.

Daniel Adjetey

BP America

(NonVoter)

3.2.32; 3.2.33; 3.2.34

Technical

"3.3.32 Intrinsically safe system: An assembly of inter-connected intrinsically safe apparatus, associated apparatus, and interconnecting cables in which those parts of the system that may be used in hazardous (classified) location are intrinsically safe circuits. An intrinsically safe system may be include more than one intrinsically safe circuit.

"3.2.33 intrinsically safe circuit: A circuit in which any spark or thermal effect is incapable of causing ignition of a mixture of flammable or combustible material in air under test conditions prescribed by UL 913."

"3.2.34 intrinsically safe apparatus: Apparatus in which all the circuits are intrinsically safe."

Why these definitions are deleted in the new edition.

Include these definitions in the new edition

Daniel Adjetey

BP America

(NonVoter)

5.2.3.3

Technical

"5.2.3.3 Where combustible liquids are stored at temperatures at or above their flashpoints, they should be treated as flammable liquids."

It is now clear how much degree above the flashpoint.

Define the pressure and/or temperature above the flashpoint of combustible liquids to be consistent with OSHA 1910.106(a)(18)(iii) which states "When a combustible liquid is heated for use to within 30 deg. F (16.7 deg. C.) of its flashpoint, it shall be handled in accordance with the requirements for the next lower class of liquids".

Daniel Adjetey

BP America

(NonVoter)

11.2.3.1; 11.2.3.3; 11.2.3.4; 11.2.3.5; 11.2.3.6

Technical

"11.2.3.1 Ventilation, adequate: The degree of ventilation (i.e., the movement and transfer of air) achieved when, under normal operating conditions, the ventilation provided meets the locations required criteria (for example, equal to or greater than a specified minimum number of air changes per hour)."

"11.2.3.3 Ventilation, inadequate: The degree of ventilation (i.e., the movement and transfer of air) achieved when, under normal operating conditions, the ventilation provided does not meet the locations required criteria (for example, less than a specified minimum number of air changes per hour)."

Why are the definitions of adequate and inadequate ventilations in section 11 Mobile Off-shore Drilling Units (MODUs) different from other sections such as such as 3.2.37 & 3.2.28 which are consistent with 6.3.2.1 through 6.3.2.3?

Make such definitions the same throughout the document.

Daniel Adjetey

BP America

(NonVoter)

6.5.2(e)

Technical

"6.5.2(e) Sensing a gas concentration of 40 percent LFL (maximum) or a gas detector system malfunction should both activate an alarm (audible or visual, or both, as most appropriate for the area) and initiate automatic disconnection of power from all electrical devices in the area that are not suitable for Division 2..."

This statement tends to imply that unclassified electrical devices that are automatically disconnected from their power sources at 40% LFL could be installed in Division 2, which contracts section 6.5.1(b).

Modify 6.5.2(e) to read, "6.5.2(e) Sensing a gas concentration of 40 percent LFL (maximum) or a gas detector system malfunction should both activate an alarm (audible or visual, or both, as most appropriate for the area) and initiate automatic disconnection of power from all electrical devices in the area that are not suitable for Division 2 provided the enclosed area does not contain a source of flammable gas or vapor..." as stated in Section 6.5.1(b).

Daniel Adjetey

BP America

(NonVoter)

8.2.3.3.4

Editorial

"8.2.3.3.4. The criteria affecting the extent of the classification of the areas around relief valve vents in nonenclosed adequately ventilated areas are too diverse to specify distances. Individual engineering judgment is required for specific cases, but in no case should the classification be less than that shown by Figure 18."

The referenced section 8.2.3.4.1 in figure 18 does not exit.

Change the section numbering of 8.2.3.3 "Relief Valves and Rupture Disks" in the new edition to 8.2.3.4 as in the current edition to match referenced sections.

Daniel Adjetey

BP America

(NonVoter)

8.2.8.2.1

Technical

"8.2.8.2.1 All laboratory and analyzer rooms or buildings with a source of small quantities of flammable or combustible gas or liquid for analysis should be classified as identified in Sections 8.2.8.2.2, 8.2.8.2.3, or 8.2.8.2.4.

"Small quantities" is ambiguous

Consider defining "small quantities" to avoid ambiguity in the interpretation of the statement.

Daniel Adjetey

BP America

(NonVoter)

8.2.8.2.4

Technical

"8.2.8.2.4 All buildings and rooms that are determined to be adequately ventilated as per the requirements of Section 6.3 by mechanical means with a minimum of six (6) air changes per hour, and be provided with gas detection meeting all of the requirements of Section 6.5 may be unclassified. In addition to the requirements of 6.5.2 e, the loss of ventilation should also initiate automatic disconnection of power from all electrical devices in the area that are not suitable for Division 2."

"Unclassified" designation could not be met since flammable liquid, vapor or gas is piped into the room or building. This contradicts Section 6.5.1(b) which states that "The interior of a building (or similar area) that does not contain a source of flammable gas or vapor can be designated unclassified, even though a door or similar pierced portion or all of the outside of the building is located in a Division 2 area, provided the building is of a type construction that provides a vaportight barrier"

Rewording section 8.2.8.2.4 to agree with section 6.5.1(b).

Daniel Adjetey

BP America

(NonVoter)

8.2.8.5.4

Technical

"8.2.8.5.4 Inadequately ventilated enclosed areas where flammable or combustible chemicals for analyzer or laboratory operations are used are classified Division 1 to the extent of the area."

Exception: In buildings where samples of flammable liquid, vapor, or compressed flammable gas materials are used under Chemical Fume Hoods provided and installed as detailed per Chapter 8 of NFPA 45. Correct same as above previous exception

The last sentence Correct same as above previous exception was added inadvertently to the Excerption statement

Delete "Correct same as above previous exception" at the end of the Exception statement

Daniel Adjetey

BP America

(NonVoter)

10.1.3; 10.1.4

Technical

Higher pressures represent larger releases and possibly increased areas where a flammable mixture may exist after such a release is realized. Table 1 indicates Pressure Adjustment Factors that should be used to determine the appropriate hazard radii of all radii shown based on equipment operating within the indicated pressure range. For example, the area around a separator operating at 950 psig would be classified in accordance with Figure 48. The hazard radii at 3 m (10 feet) illustrated in Figure 48 would be increased by the correction factor in table 1 which would result in a hazardous radius of 9 m (30 feet).

This section is to be directed towards Production Facilities

Where and when would this be applied to a drilling system which does not process hydrocarbons?

What is the basis for the pressure adjustment factor table? Since this is a significant change, it would be appropriate to put some rational in the standard as to why the committee has made this change. Since this standard is used in regulatory requirements, it is needed to provide some rational for this change since the issue of applying this revision to existing facilities will be in question.

Extending Division 2 distances in open air areas seems reasonable but applying this table would mean that all areas including Division 1 volumes around pig launchers (see Figure 49) would be extended. In this instance, extending the Division 1 area to 15 for a 1000 psi launcher is counter to the definition of a Division 1 area. Launchers are blown down and isolated prior to opening and thus do not have the risk that warrants increasing the Division 1 area based on pressure as shown in the table. This change is inconsistent with other similar classifications with-in the standard.

Recommend further application clarity be added to the pressure adjustment factor table when applying it to the various figures.

Daniel Adjetey

BP America

(NonVoter)

10.2

Technical

10.2 Drilling Areas

"g" (or gas buster)

"j" (choke manifold)

"k" (cement unit)

a. Why has gas buster been added since this is an atmospheric vessel which vents via designed vent lines above the derrick crown assembly only when hydrocarbons are entrained in the drilling mud and is not part of a regular production process.

b. Why has choke manifold been added since this is a well control system which is tested for leaks at a minimum every two weeks. Hydrocarbon vapor or fumes should never emanate from the choke manifold other then through the choke and vent line. The system is only vented during a well control event and the vents via designed vent lines above the derrick crown assembly.

Utilize the classification areas as depicted on Figure Nos. 74 & 75 in Section 11 - Mobile Offshore Drilling Units (MODUs).

Daniel Adjetey

BP America

(NonVoter)

10.4.7.1

Technical

a.Why is the gas buster included. Any gas which breaks out of the mud is vented to a vent line. There should be no source of gas leaks from the body of the gas buster. Reference Figure No. 75 in Section 11 - Mobile Offshore Drilling Units (MODUs).

b.Sections 10.4.7.2, 10.4.7.3, and 10.3.7.4 each have or gas buster added. These sections are impacted by the clarification to section 10.4.7.1.

Degasser and Gas busters should be considered separately since they are typically located in different locations within the drilling system. Recommend revising this section to be consistent with Section 11 figure 75 Mobile Offshore Drilling Units(MODUs). This is another location where the changes have made the standard inconsistent

Daniel Adjetey

BP America

(NonVoter)

10.4.9

Technical

Why has choke manifold been added since this is a well control system which is tested for leaks at a minimum every two weeks. Hydrocarbon vapor or fumes should never emanate from the choke manifold other then through the choke into the vent line to be discharged above the derrick crown. This occurs infrequently and only during a well control event.

Delete the section on choke manifold from the new edition

Daniel Adjetey

BP America

(NonVoter)

10.5.1.1

Technical

Figure Nos. 39 & 40 were modified by reducing the Division 2 area around the Sample Valve, bleed Valve, or similar device down to 0.5m (18 in.).

It appears inconsistent that the Div. 2 classified area around a sample or bleed valve on a flowing well, which is a likely potential source of hydrocarbon vapor or fumes, is being reduced to only 18 inches, while at the same time the Div. 2 classified area around the choke manifold and gas buster on the drilling rig, which should never be a source of vapor or fumes is increase to 10 ft. from the outside surface.

Make area classification in figures 39 and 40 consistent with section 10.4.9 Choke Manifold and 10.6.4.1 Header or Manifold

Daniel Adjetey

BP America

(NonVoter)

10.5.1.1

Editorial

There is no section 10.15.3.2 referenced in the figure 39 and 40. Section 10.15 is now 10.14 in the new edition.

Change Section 10.14 back to 10.15 to match referenced sections in the document

Daniel Adjetey

BP America

(NonVoter)

10.5.1.5

Editorial

"10.5.1.4 Surface Safety Valves. See Section 10.15.2, Process Control Valves."

There is no referenced section 10.15.2. Section 10.15 is now 10.14

Change Section 10.14 back to 10.15 to match referenced sections in the document.

Daniel Adjetey

BP America

(NonVoter)

10.5.1.6

Editorial

"10.5.1.6 10.5.1.6 Sample Valves, Instrument Drain Valves, Gauge Valves and Similar Devices. See Section 10.15.4.3 Sample Valves, Instrument Drain Valves, Gauge Valves, and Similar Devices."

Section numbering is duplicated

Delete duplicated 10.5.1.6.

Daniel Adjetey

BP America

(NonVoter)

10.6.6.1.0.1

Editorial

"10.6.6.1.0.1, 10.6.6.1.0.2, 10.6.6.1.0.3" These sections are numbered incorrectly

Change the sections numbering to 10.6.6.1.1, 10.6.6.1.2, 10.6.6.1.3

Daniel Adjetey

BP America

(NonVoter)

10.9.4

Technical

"10.9.4 The area around a compressor or pump handling flammable liquids, gases, or vapors in an adequately ventilated nonenclosed area is classified as shown in 54b".

Figure 54b shows a 5 ft radius of Division 2 for a turbine in adequately ventilated nonenclosed area without any reference to fuel pressure which contradicts Section 8.2.5 which partly states adequately ventilated enclosed areas containing diesel-fueled or gas-fueled, 861.8 kPa (125 psi) or less engine/turbines need not be classified solely by reason of the engine/turbine fuel, reference NFPA 37.

1. Add a new section 10.9.5 to read The area around a compressor or pump handling flammable liquids, gases, or vapors in an adequately ventilated nonenclosed area containing gas-fueled engine/turbines with fuel pressures 861.8 kPa (125 psi) or less is unclassified as shown in 54c.

2. Add a new figure 54c similar to figure 54b depicting unclassified radius around the turbine.

3. Change Section 10.9.4 to The area around a compressor or pump handling flammable liquids, gases, or vapors in an adequately ventilated nonenclosed area containing gas-fueled engine/turbines with fuel pressures exceeding 861.8 kPa (125 psi) is classified as shown in 54b.

4. Change the description of figure 54b to read, "Compressor or pump in an Adequately Ventilated Nonenclosed Area containing engine/turbine with fuel pressure exceeding 861.8 kPa (125 psi)."

Daniel Adjetey

BP America

(NonVoter)

10.11.4

Editorial

"10.11.4 The area surrounding an open sump that can contain flammable liquid and is located in a nonenclosed adequately ventilated area is classified as shown by Figure 57."

There is no sections 10.12.1 and 10.12.2 referenced in the figure 57. Section 10.12 is now 10.11.3 in the new edition.

Change Section 10.11.3 back to 10.12 to match referenced sections in the document.

Daniel Adjetey

BP America

(NonVoter)

10.14.1.1

Technical

"10.14.1.1 The area around screwed connections, flanges, block valves and check valves in nonenclosed adequately ventilated areas is classified Division 2 within 50 cm (18 inches) of the connection, flange or valve"

This Division 2 area classification is inconsistent with section 9.1.5 which states that such areas are unclassified, and reads Experience has shown that the occurrence of flammable material liberation from some operations and apparatus is so infrequent that it is not necessary to classify the surrounding areas. An example of such an area is an adequately ventilated location where flammable substances are contained in suitable, well maintained closed process piping systems that include only the pipe, fittings, flanges, meters, and small valves.

Make area classification in sections 9.15, 10.14.1.1, 10.16.1 and similar areas in the document consistent.

Daniel Adjetey

BP America

(NonVoter)

11.4.1

Technical

The drilling areas on MODUs considered for classification do NOT include the following:

a.Degasser

b.Gas Buster

c.Choke Manifold

d.Cement Unit

Clarify what drives areas on a Marine Fixed Platform drilling rig to be classified differently as in Section 10.2 compared to the same areas which are not required to be classified on a MODU as in Section 11?

(1). Add items "a" through "d" to Section 11.4.1

(2). Utilize the classification areas as depicted in Figure Nos. 74 & 75 in Section 11 for Mobile Offshore Drilling Units (MODUs(.

Daniel Adjetey

BP America

(NonVoter)

11.5.2.1

Technical

"11.5.2.1 Enclosed hazardous (classified) locations are to be provided with ventilation as required to maintain them at a pressure lower then adjacent less hazardous locations by a minimum differential of 25 Pa (0.1 in. of water).

The above statement was shared with three (3) other individuals. Each concluded we think we know what is meant; however, as written, it is not clear and subject to misinterpretation.

Re-write this section and clarify.

Daniel Adjetey

BP America

(NonVoter)

12.1.1.3

Technical

"12.1.1.3 Classification locations should be in accordance with Section 1 through Section 8, Section 10, and the annexes of this document.

Clarify what drives areas on a Marine Floating Facility drilling rig to be classified differently as in Section 10 compared to the same areas which are not required to be classified on a MODU as in Section 11?

Utilize classification areas on all Drilling Rigs as depicted in Figure Nos. 74 & 75 in Section 11 Mobile Offshore Drilling Units (MODUs) consistently throughout RP 500, and specifically in:

(1). Section 10 - Recommendations fro Determining Degree and Extent of Classified Locations at Drilling Rigs and Production Facilities on Land and on Marine Fixed Platforms.

(2). Section 11 - Recommendations for Determining Degree and extent of Classified Locations on Mobile Offshore Drilling Units (MODUs

Daniel Adjetey

BP America

(NonVoter)

Appendix D

Editorial

References are made to section D.5.8 but there is no such section, figure or table

Re-number the following statement in Section D.5.6 as follows:

D.5.7 Flanges

Many flanged joints are rarely broken except during major maintenance work, and then typically at intervals of two or more years...."

Daniel Adjetey

BP America

(NonVoter)

D.5.7

Editorial

"D.5.7 After the hazard radius is determined by the methods given in Sections D.5.1 through D.5.7, Figure D-3 is used to determine the extent of the Division 2 boundaries."

Section D.5.7 is numbered incorrectly

Renumber Section D.5.7 as Section D.5.8

Norbert Klekowski

BP p.l.c.

(Affirmative)

Second Title Page

Editorial

Several of the editorial comments provided by Mark Goodman to Gordon Roberson on 11/2/08 have not been corrected. For example, the second title page (page i?)still identifies this as an "Upstream Segmant" document; section 8.2.2.6 still shows an incorrect number (should be 0.5, not 058).

API Editorial Staff should recheck every correction provided in Mr. Goodman's 11/2/08 e-mails to assure that they have been addressed.

Norbert Klekowski

BP p.l.c.

(Affirmative)

8.2.2.6

Editorial

Several of the editorial comments provided by Mark Goodman to Gordon Roberson on 11/2/08 have not been corrected. For example, the second title page (page i?)still identifies this as an "Upstream Segmant" document; section 8.2.2.6 still shows an incorrect number (should be 0.5, not 058).

API Editorial Staff should recheck every correction provided in Mr. Goodman's 11/2/08 e-mails to assure that they have been addressed.

Norbert Klekowski

BP p.l.c.

(Affirmative)

8.2.8.5.4

Editorial

Last phrase should be deleted.

Delete "correct same as above previous exception"

Paul Hamer

Chevron Products Company

(Affirmative)

Annex C, middle of page

Technical

Need to bring text up to date with the present 2008 edition of NFPA 30

In the present (2008) Edition of NFPA 30, the definition of ventilation is: As specified in this code, movement of air that is provided for the prevention of fire and explosion." According to NFPA 30-2008, Sections 17.11.2 and 17.11.3:

(remaining text unchanged)

Paul Hamer


(Affirmative)

8.2.1

Technical

Section 8.2.1: The draft added this paragraph about adding screwed fitting appurtenances to storage tank walls possibly creating an additional classified area. This is simply a statement, not a recommended practice.

8.2.1.1 Appurtenances added to the storage tank walls can be an additional source of flammable vapor and can affect the area classification surrounding the storage tank. Classify any screwed fittings or threaded appurtenance penetrating a storage tank wall Division 2 within 50 cm (18 in) of the penetration.

Paul Hamer


(Affirmative)

8.2.8.1.1

Technical

The flammability ratings in NFPA 704 are only an indicator of what it takes for that liquid to burn. Unfortunately, a 2 rating is usually assigned to liquids with flash points >100F but not exceeding 200F. NFPA 704 does not make mention of the need to heat those liquids to their flash point before sufficient vapors are released to ignite. So using the NFPA 704 in this paragraph will cause some labs to classify areas only handling higher flash point liquids and unless those liquids are being heated, there is no justification for the Cl 1, Div 1 rating. This would be a very expensive laboratory that only handled diesel fuels. A better definition for this section is to use the NFPA 30 flammable liquid definitions and stipulate that electrical classification does not apply for combustible liquids (Class 2 and 3 liquids) unless those liquids are handled at temperatures within 15F of their flash point.

8.2.8.1.1 This section addresses only the electrical classification of locations where flammable liquids, or combustible liquids within 8 C (15 F) of the liquid's flash point, are analyzed (for example, gas chromatographs, oil analysis, water cut determination, and other flammable material analysis methods). It also includes areas that are used for analysis purposes where flammable liquids or combustible liquids (within 8 C (15 F) of the liquid's flash point) are utilized in the analysis process and are stored or used (for example, toluene). This section describes safe practices for electrical area classification of areas that store these products. The fire protection safe practices are provided in NFPA 30.

NOTE: The 8 C (15 F) margin listed above for combustible liquids is to account for the uncertainty of temperature measurements.

Paul Hamer


(Affirmative)

8.2.8.3.2

Technical

This section should be revised to say where samples of flammable liquid, vapor, or flammable gas materials are ONLY opened, transferred, used, and or analyzed under Chemical Fumes Hoods. The reason is the proposed language is somewhat vague and only refers to using these compounds. The term use is vague. Plus, it opens the possibility for users to mistakenly assume that because they have fume hoods and do some of their analytical work inside those hoods, that they dont need to classify the rest of the lab AND can still transfer and mix and use and dispose of flammable compounds outside the fume hoods. Is the intent of this paragraph to declassify the lab ONLY if all usage, transfer, heating, mixing, and disposal of flammable compounds takes place inside the confines of a properly designed and operated fume hood?

8.2.8.3.2 All locations or areas that are determined to be inadequately ventilated as per the requirements of Section 6.3 where the sample containers are open, should have the interior classified as Division 2.

In locations or areas where samples of flammable liquid, vapor, or flammable gas materials are only transferred, used, or analyzed under Chemical Fume Hoods provided, and installed as detailed per Chapter 8 of NFPA 45, the areas outside of the hood(s) should be unclassified.

Paul Hamer


(Affirmative)

10.1.3

Technical

Chevron agrees with and supports the idea of using a multiplier to increase electrical classified zones based on pressures within the equipment being classified as shown in 10.1.3. But the wording and example isnt 100% clear. Recommend adding to the example to show the steps for classifying the separator, ie Step 1: Determine the type of equipment (separator) and then go to the applicable drawing (Figure 48). Identify the required electrical classification distances from this figure. Step 2: Determine the maximum allowable design pressure for that piece of equipment and then determine the Adjustment Factor from Table 1 below. Step 3: Multiply the electrical classification distances in Step 1 by the Adjustment Factor in Step 2, this becomes the applicable electrical classification zone distances for that piece of equipment.

10.1.3Higher pressures represent larger releases and possibly increased areas where a flammable mixture may exist after such a release is realized. Table 1 indicates Pressure Adjustment Factors that should be used to determine the appropriate hazard radii of all radii shown based on equipment operating within the indicated pressure range. Example: Step 1 - Determine the type of equipment (e.g., separator) and then go to the applicable drawing (Figure 48). Identify the required electrical classification distances from this figure. Step 2 - Determine the maximum allowable design pressure for that piece of equipment and then determine the Adjustment Factor from Table 1 below. Step 3: Multiply the electrical classification distances in Step 1 by the Adjustment Factor in Step 2, this becomes the applicable electrical classification distances for that piece of equipment.

Paul Hamer


(Affirmative)

8.2.8.5

Technical

Section 8.2.8.5 is confusing. It talks about Usage but seems to conflict with some of the guidance in previous sections.

For example, 8.2.8.4.3 says if we use flammable or combustible liquids in non-DOT approved containers > 1 gallon we have to classify the lab, regardless of ventilation. But 8.2.8.5.3.1 below tells me that if I adequately ventilate that area I dont need to classify the lab. And then 8.2.8.5.3.2 tells me that if I am only using combustible chemicals below their flash point I dont need to classify my usage area. We recommend not trying to discriminate between usage and storage and analytical work etc. If they have Class I flammable liquids in there it should be classified, only allowed in a fume hood, or be properly ventilated. If they use combustible liquids at or above the liquid's flash point, the same classification rules should apply. Keep this simple.

Delete Section 8.2.8.5

Royce King

ConocoPhillips

(Affirmative)

3.1 Acronyms

Editorial

The document uses "RP" in many places but it is not on the list of acronyms

ADD RP to the list of acronyms

RP = Recommended Practice

Royce King

ConocoPhillips

(Affirmative)

8.2.8.3.1

Editorial

There is a reference in the last sentence of this section that refers to 9.2.9.5

That section does NOT exist.

Change the reference in the last sentence to the proper reference number that the task group wished to reference.

Royce King

ConocoPhillips

(Affirmative)

8.2.8.5.4

Editorial

There is a statement at the end of the section that states

"Correct same as above previous exception."

This appears to probably be a comment made for the purposes of the working group while the document was being updated. I think the comment needs to be deleted.

Royce King

ConocoPhillips

(Affirmative)

10.3 (b)

Editorial

In the previous version, underlauncher or receiver, the two types were 4a and 4b. Now they are 5) and 6). This change does not seem appropriate

Consider making 5)ball or pig launcher or receiver 4a)

And consider making 6) through flow line (TFL) tool launcher or receiver 4b)

If the task group does not feel this is appropriate then 4) should be deleted as 5) and 6) cover the issues in two parts.

Royce King

ConocoPhillips

(Affirmative)

10.3 (b)

Editorial

The same issue in the comment on launcher or receiver above applies for items 12) and 13) under Instruments.

Change item 12) to 11a

Change item 13) to 11b

if this is not done, then

Change 12 to read, "instruments not operated by flammable gas"

Change 13 to read, "instruments operated by flammable gas"

And delete 11) instruments.

Royce King

ConocoPhillips

(Affirmative)

10.5.1.6

Editorial

There is a repeat of the section number in the text

Delete the nonbold 10.5.1.6 that follows the bold section number

Royce King

ConocoPhillips

(Affirmative)

Figure 64 and Figure 65 and Figure 66

Editorial

The reference at the end of the description of the Figure 64 is in error I believe

It is currently (See 10.16.3)

I think the same issue occurs in Figure 65 that the reference to (See 10.16.4.1) is in error

I think the same issue occurs in Figure 66 that the reference to (See 10.16.4.2) is in error

I believe the correct reference is (See 10.15.3)in Figure 64

I believe the correct reference is (See 10.15.4.1) in Figure 65

I believe the correct reference is (See 10.15.4.2) in Figure 66

Royce King

ConocoPhillips

(Affirmative)

Annex D

Technical

Major changes to this Annex without much indication where the technical background was derived. I hope the task group has carefully weighed the changes. Unfortunately I was not able to participate in the task group to hear the discussions.

Royce King

ConocoPhillips

(Affirmative)

Annex D, Page 145, section D.5.2,

Editorial

This comment applies to the text on Page 145 immediately under Figure D.2

There is a reference here to Table D.1

No such table exists

Change the reference to the correct reference.

Royce King

ConocoPhillips

(Affirmative)

Annex D, Section D5.7

Technical

The section number is in the wrong place I believe.

It currently is on page 147 below Table D.4

However, I think it needs to be up a couple lines to the text below TAble D.3 starting with "Flanges Many flanges joints are rarely......."

I think Flanges should be bold and the Section D.5.7 number needs to be moved to the location stated on Page 146

Richard Virgilio

Foster Wheeler USA Corporation

(Affirmative)

Cover Sheet

Editorial

Delete reference to "Upstream Segment"

Introduction states "....under the joint jurisdiction of the API Production, Refining and Transportation Departments."

Delete reference to "Upstream Segment"

Richard Virgilio


(Affirmative)

Introduction

Editorial

First paragraph, last sentence, add additional issue dates.

after June 1, 1991 add:

, second edition was issued November 1997 and reaffirmed November 2002,......

Richard Virgilio


(Affirmative)

Introduction

Editorial

Third paragraph, first sentence API IIJ(alpha) to API 11J(numeric)

API 11J

Richard Virgilio


(Affirmative)

8.2.2.6

Editorial

Correct distance from "058m" to ".5m"

.5m (18 in.)

Richard Virgilio


(Affirmative)

10.5.2.5

Editorial

Delete italic text

Gas Lift Well.

Richard Virgilio


(Affirmative)

10.5.2.6

Editorial

Delete italic text

Plunger Lift Well.

Richard Virgilio


(Affirmative)

10.6.7

Editorial

correct section number from 10.6.7.0.1 to 10.6.7.1



10.6.7.1

10.6.7.2

10.6.7.3

Richard Virgilio


(Affirmative)

10.8.1

Editorial

change standard text to bold text

Bold Text: "Produced/processed/injected water is any......"

Richard Virgilio


(Affirmative)

Annex C

Editorial

Second paragraph, last sentence correct referenced

section number from 4.6.2.2.5 to 6.3.2.4.7

also change text from bold to standard

6.3.2.4.7 and Annex B of this RP.

Richard Virgilio


(Affirmative)

Figure 22

Technical

Figure 22 is correctly entitled "Inadequately Ventilated Process Location With Heavier-than-air Gas Or Vapor" HOWEVER FIGURE 22 AS SHOWN IS THAT OF AN ADEQUATELY VENTILATED COMPRESSOR SHELTER WITH LIGHTER-than-air GAS OR VAPOR

Change Figure 22 to the correct depiction as shown in RP 500 1997

API RP 500 Ballot Comments

Louis Barrios

2/25/2009

Section

Change

Justification

Introduction

Add at the end of the first paragraph: "The second edition of this recommended practice was issued November 1997 and was reaffirmed in 2002."

Provides up to date history of the standard.

3.2.5.4

Modify to read "For the purpose of testing, approval, and area classification, various air mixtures (not oxygen enriched) are subdivided into Groups A, B, C or D for Class I, Division 1 and Class I, Division 2 locations."

Removes the "shall" from the sentence, makes it less of a requirement, and makes it similar to NFPA 497.

3.2.35

Delete.

Editorial. Definition already exists at 3.2.5.6.

4.1c)

Remove "an" before "electrical installations or devices".

Editorial - grammar.

5.2.1

Change to read "Refer to NFPA 497 for properties of specific chemicals."

Table 4.4.2 in NFPA 497 is entitled "Selected Chemicals". The proposed modification better describes this table than "flammable liquids and flammable gases, and volatile solids".

5.3.1

Change "and mixtures of such" to "and similar mixtures".

Editorial - improved wording.

5.5.2

Remove references to "maximum explosion pressure".

Per NFPA 497, the material grouping is no longer based on the maximum explosion pressure, but only on the MESG and MIC.

8.2.2.6

Modify to read "Locations where tank cars or tank trucks are loaded or unloaded, transferring combustible liquids operating below their flash point are unclassified except for the area surrounding any vent opening, which requires a 0.58 m (18 in.) Division 2 classification.

Added "operating below their flash point" to remove ambiguity of the sentence. Changed "require" to "requires" to correct grammar. Changed "058" to "0.58" to correct the lack of a decimal in the draft. Also, this is a very awkwardly worded sentence. The committee may want to consider rewording to improve the overall flow of the sentence.

Chapter 8

To enhance usability of the standard, API publications staff should try to arrange the standard so that the text referencing the figures is as close as possible to the figures they reference.

For example, Section 8.2.3 on page 30 covering Vents and Relief Valves is several pages away from the relief valve figure.

Figure 14

Change "1.5m(5')" and "3m(10')" to "1.5m(5') Minimum" and "3m(10') Minimum".

Adding the word "minimum" better reflects the text in 8.2.3.1.1 which states that "in no case should the classification be less than thatshown by Figure 14". This also better matches Figure 18, which includes the word "minimum".

8.2.8.1.1

Remove "only" from "This section addresses only the classification"

The first sentence indicates that this section only covers a specific area. However, the second sentence begins with "It also includes areas".

8.2.8.1.1

Modify second sentence to read "This section also addresses the electrical classification of locations where flammable or combustible materials, chemicals or solvents having a Flammability Hazard Rating per NFPA 704 of 2, 3 or 4 are utilized in the analysis process or stored (e.g. toluene)."

Editorial - The existing sentence is awkward. The proposed changes makes the sentence parallel to the first in the paragraph and hopefully makes it more readible.

8.2.8.2.1

Provide guidance on what is considered "small quantities".

"Small quantities" is vague and is open for broad interpretation.

8.2.8.2.4

Remove "be" from first sentence in the phrase "six (6) air changes per hour, and be provided with gas detection"

Editorial - grammar. The "be" is not necessary.

8.2.8.2.4

Change "insure" to "ensure" in last sentence.

Editorial - spelling. While "ensure" and "insure" tend to be synonyms, the term "insure" is more appropriately used when referencing the selling or purchasing of insurance.

8.2.8.4

Change title to "Storage Areas".

More closely matches title of section 8.2.8.5 "Usage Areas".

8.2.8.4.1

Remove "sub-" from "sub-section".

Editorial.

8.2.8.4.18.2.8.4.2

Need to be consistent on use of "Non-enclosed" or "Nonenclosed".

Term is hyphenated in one section and non-hyphenated in the other section.

8.2.8.4.3

Modify last sentence to read "Areas where the total quantity is one gallon or less are unclassified."

Editorial - grammar. Removed the phrase "For those" because it is not necessary.

8.2.8.5.1

Modify to read "This section covers nonenclosed and enclosed areas (e.g. rooms, cabinets and lockers) where flammable and combustible laboratory or analyzer chemicals are used."

Editorial - make parallel to sentence in 8.2.8.4.1.

8.2.8.5.1

Remove first "operations in" in second sentence - "Used" is defined as operations in laboratory operations"

Editorial - first "operations" is redundant to the second "operations".

8.2.8.5.4

Remove the last phrase "Correct same as above previous exception".

These appear to be notes from the Task Force that were left in the text.

Figure 22

The wrong figure is shown for Figure 22. What is shown is adequately ventilated compressor shelter with lighter than air gas or vapor source.

Incorrect figure used for Figure 22.

10.3(b)(4)

#5 "ball or pig launcher or receiver" and #6 "through flow line (TFL) tool launcher or receiver" should be "a)" and "b)" subsection under #4 "launcher or receiver"

Editorial - correctly reflect two subsections under 10.3(b)(4).

10.3(b)(11)

#12 "no operated by flammable gas" and #13 "operated by flammable gas" should be "a)" and "b)" subsections under #11 "instruments".

Editorial - correctly reflect two subsections under 10.3(b)(11).

10.6.6.1

Remove the "0" in the subsections. For example "10.6.6.1.0.1" should be "10.6.6.1.1". Likewise, "10.6.6.1.0.2" should be "10.6.6.1.2". Likewise "10.6.6.1.0.3" should be "10.6.6.1.3".

Editorial - section numbering.

10.6.7

Same comment as above. Remove "0" in the subsections to 10.6.7.


10.11.3

Should section 10.11.3 Sumps be 10.12 Sumps per the original standard?


10.12

Should section 10.12 Drains be 10.13 Drains per the original standard?


D.3.2

2nd paragraph starting with "Category 1 materials" Normally, kerosene at room temperature and low pressures is considered an unclassified material." Add period at the end of the sentence.

Editorial

D.4

Changed "non-enclosed, adequately ventilated" to "nonenclosed adequately ventilated" in two places.

Editorial - provides more consistent use of the term with the rest of the standard.

Figure D.1

Title of the vertical axis should be "True Fluid Vapor Pressure (PSIA)" and not "Ture". This is an error from the 2nd edition.

Correct misspelling of "True" from the 2nd edition.

D.5.7

Section D.5.7 should begin with "Flanges" located on page 146 of the draft. This section should read: "D.5.7 Flanges". New paragraph: "Many flanged joints are rarely broken"

Editorial - section numbering

Table D.4

Remove "Fluid" from "Fluid Category".

Editorial - maintain consistency with other tables like D.2.

Table D.4

Change "2 or Gas" to "2 or G".

Editorial - Per section D.3.2, there is a "Category G" which represents materials processed as gases or vapors". Also, maintains consistency with other tables like D.2.

D.5.7

Change the section in the draft indicated as "D.5.7" which begins with "After the hazard radius is determined" to "D.5.8".

Editorial - section numbering. This is a mandatory editorial change because most of the previous sections refer to section D.5.8 in order to determine the overall extent of the classified area.

1MB = Member body (enter the ISO 3166 two-letter country code, e.g. CN for China)** = ISO/CS editing unit

2Type of comment:ge = generalte = technical ed = editorial

NBColumns 1, 2, 4, 5 are compulsory.

page 1 of 1

FORM 13B (ISO) version 2001-09

page 52 of 55

API electronic balloting template/version April 2003

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