Statement of Problem and Substantiation for Public Comment ...

Public Comment No. 64-NFPA 54-2013 [ Global Input ]

L.1.2.4 ASTM D2513 change in title and date change from -09 to -12.

Additional Proposed Changes

File Name Description Approved

Volgstadt_Public_Comment_re_PA11_and_D2513_NFPA_54-15_Proposal..pdf Original Comment

Statement of Problem and Substantiation for Public Comment

The problem is that the proposed revision to NFPA 54-15 removes the use of PA11 piping, a piping system which is permitted in the 2012 edition. This situation can be rectified by a retaining reference to D2513-09 and correcting the title to Standard Specification for Thermoplastic Gas Piping, Tubing and Fittings. The better resolution is to reference D2513-12 and add reference to F2945 Standard Specification for PA11 gas Piping, Tubing and Fittings and editorially changing any PA11 references in the Code to the PA11 standard, namely F2945.

Submitter Information Verification

Submitter Full Name: FRANK VOLGSTADT

Organization: [ Not Specified ]

Street Address:

City:

State:

Zip:

Submittal Date: Wed May 08 12:18:27 EDT 2013

Committee Statement

Committee Action: Rejected but see related SR

Resolution: SR-6-NFPA 54-2013

Statement: The 2009 edition of ASTM D 2513 is added to Annex L to be consistent with section 5.6.4.1.2.

Copyright Assignment

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

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

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

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5.9 Overpressure Protection.

5.9.1 Where required.

Where the serving gas supplier delivers gas at a pressure greater than 2 psi for piping systemsserving appliances designed to operate at a gas pressure of 14 in. wc or less, overpressureprotection devices shall be installed. Piping systems serving equipment designed to operate at inletpressures greater than 14 in. wc shall be equipped with overpressure protection devices asrequired by the applicable equipment construction and/or installation codes and standards for theconnected equipment.

5.9.2 Pressure limitation requirements.

5.9.2.1 Where piping systems are required to be equipped with overpressure protection devices byparagraph 5.9.1 each overpressure protection device shall be adjusted to limit the gas pressure toeach connected appliance to 2 psi or less upon a wide-open failure of the primary line pressureregulator.

5.9.2.2 Each overpressure protection device installed to meet the requirements of this section shallbe capable of limiting the pressure to its connected appliances as required by this sectionindependently of any other pressure control equipment in the piping system.

5.9.2.3 Each gas piping system for which an overpressure protection device is required by thissection shall be designed and installed so that a failure of the primary pressure control device(s) isdetectable.

5.9.2.4 Each pressure relief valve shall be designed to maintain downstream pressure at or belowthe limits specified in paragraph 5.9.2.1 at a gas flow rate equal to or greater than that supplied to itby a regulator failed wide open at the regulator’s design operating inlet pressure.

Type your content here ...



NFGC_Comment_5.9.docx original comment


These proposed provisions of CI 59 are not clear and should be further developed.5.9.1 appears to exempt most residential gas systems since the normal pressure of the gas supplied is around 14 inches water column. However the gas pressure upstream of the point of delivery is often significantly higher. The issue is not whether the supply delivers gas at more than 2psi; rather it is can the pressure of the gas being delivered ever exceed 2 psi.What is the purpose of 5.9.2.4? This provision would require the pressure relief valve to maintain the gas flow rate at all pressure above normal up tp 2 psi.. If an appliance is designed to operate at 14 inched wc and the pressure relief valve is acting such that the gas pressure is 1.75 psi the flow rate is not the major concern. While this may not be the intent, this provision implies that it is expected that the appliance will continue to operate in the example described above.

Related Item

Committee Input No. 59-NFPA 54-2012 [Section No. 5.9]


Submitter Full Name: FRANK STANONIK

Organization: GAS APPLIANCE MANUFACTURER


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Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but see related SR


Statement: Section 5.9 has for many years required the installation of overpressure protection devices in certainlimited applications. The previous edition text was applicable to regulators supplied and maintainedby the serving utility or LP gas supplier and which are properly governed by either 49 CFR Part 192or by NFPA 58. As a practical matter, installers working within the scope of this Code will have noknowledge of whether or not the supplied gas contains materials that could seriously interfere withthe operation of the system or whether or not the gas pressure in the street is 60 psi or less (two ofthe previously-applicable triggers for overpressure protection). Further, the previous edition textexempted from any overpressure protection any systems meeting all of the attributes of 5.9.1.3 (3).The Committee considers an exclusion of this breadth unacceptable. Accordingly, the revised texteliminates the requirements which were primarily applicable to utility service regulators (and thereforeoutside the scope of this Code) and replaces them with requirements applicable to within-scopeequipment such as line regulators. Exemptions were tightened so that overpressure protection is nowrequired on each system containing an appliance with a maximum inlet pressure of 14” wc which issupplied with gas at the point of delivery at a pressure greater than 2 psig, and on each systemcontaining higher-operating-pressure appliances which is supplied with gas at the point of delivery ata pressure greater than that for which the appliances are rated. By narrowing the previously-permitted exemptions, the revised text provides assurance that appliances with a maximum inletpressure of 14” wc will not be subjected to more than 2 psig even with a line regulator failure andextends similar overpressure protection to appliances designed to operate with maximum inletpressures greater than 14” wc.


I, FRANK STANONIK, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyrightin this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intendthat I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or anothersimilar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority toenter into this copyright assignment.

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


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G.1.5.a. Gas Detector: The CGD should be capable of indicating the presence of the type of fuel gas forwhich it is to be used (e.g. natural gas or propane). The combustible gas detector should be capable of thefollowing:

PPM: Numeric display with a parts per million (ppm) scale from 1ppm percent to 900 ppm in 1 ppmincrements.

LEL: Numeric display with a percent lower explosible limit (% LEL) scale from 0 percent to 100 percent in 1percent increments.

Audio: An audio sound feature to locate leaks.

G .6. (5) Vented Room Heaters

a. OFF. For built-in wall room heaters and wall furnaces inspect that the burner compartment is free of lintand debris.

G. 6 (6) Vent-free Heaters

b. OFF. Inspect the ceramic logs provided with gas log type vent free heaters that they are properlylocated and aligned.



NFGC_Comment_Annex_G.pdf original comment


G.1.5.a Appears to be a typo. Unit being discussed is ppm.G. 6 (5) More clearly describes the products.G.6 (6) Logs may be made of materials other than ceramic. No need to specify the material.

Related Item

Committee Input No. 55-NFPA 54-2012 [Chapter G]




Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:



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Resolution: SR-23-NFPA 54-2013 PC 58: The committee agrees that the word “exterior” is needed forclarification but will locate it between “all” and “building” in the first sentence. The word “interior” isalso added for clarification to the first between “all” and “doors”. PC 59, 60, and 61: The committeeagrees that the appliance installation should be evaluated to determine if spillage occurs underseveral other conditions. An additional spillage test was added to the revised Annex G under a newG.5.2 (4).

Statement: Annex G has been expanded and rewritten to provide comprehensive guidance on procedures tofollow when inspecting gas appliances, particularly before and after weatherizing a home. Inaddition, Annex G has been rewritten to reflect modern appliances and installation practices and hasbeen updated to include more inspection details (including actionable CO and gas leakmeasurements/levels) and to cover additional appliances.





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7.13.2* CSST. CSST gas piping systems shall be bonded to the electrical service grounding electrodesystem.

7.13.2.1. The bonding jumper shall connect to a metallic pipe or fitting between downstream of the point ofdelivery and the first downstream CSST fitting.

7.13.2.2. The bonding jumper shall not be smaller than 6 AWG copper wire or equivalent. Gas pipingsystems that contain one or more segments of CSST shall be bonded in accordance with this section.

7.13.2.3 The length of the jumper between the connection to the gas piping system and a groundingelectrode system shall be as short as practical, but shall not exceed 150 ft (45.6 m) 75 ft. (22.9 m). Anyadditional electrodes shall be bonded to the electrical service grounding electrode system.

7.13.2.4 Where a gas piping manifold is installed, it shall also be bonded to the electrical service groundingelectrode system.



NFGC_Comment_Form_7.13.2.pdf original comment


The results of the research being done for the GTI Phase II CSST bonding research project demonstrate that CSST bonding is effective as long as the bonding clamp is located anywhere between the point of delivery and the appliance(s) shut-off valve. The results also indicate that shorter bonding conductors will reduce the level of imposed energy on the CSST as well as reduce the residence time of the energy imposed on the CSST. The recommended 150-ft length is well within the conditions used in this research for demonstrating that bonding is effective. The results from the research also indicate that the incremental improvement in bonding effectiveness by installing multiple bonding connections is so minor such that it does not support the special requirement, 7.13.2.4, for piping manifolds.

Related Item

Committee Input No. 38-NFPA 54-2012 [Section No. 7.13.2]




Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:



Statement: The committee reviewed and discussed the final research report provided by GTI. The final reportclearly indicates that bonding a CSST piping system to the building’s grounding electrode systemwith a 6 AWG copper wire will dramatically reduce the likelihood of perforation or failure of the CSSTin the event of an indirect lightning strike compared to CSST that is not so bonded. The GTI report


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additionally indicates through modeling and testing that a single 6 AWG copper wire effectivelymitigates the hazard of induced currents resulting from indirect lightning strikes. Therefore, additionalbonding locations on the same piping system are not required. The GTI report indicates that therewas no perforation of the CSST in modeled scenarios with a 6 AWG copper wire length of up to 164ft. The committee chose a conservative approach by selecting a value of 75 ft as a margin of safety.Paragraph 7.13.2 is further revised to specifically allow bonding to a lightning protection systemwhere one is installed as an option to the building ground electrode or electrical panel bond. Thisrecognizes an alternate bond location in some cases. The test protocol used by GTI (Gas TechnologyInstitute) and LTI (Lightning Technologies, Inc.) utilized the recommendations for attaching thebonding jumper to the CSST contained in existing text A.7.13.2. The test results confirmed theefficacy of the bonding, therefore the connection method is validated. In addition,new sections7.13.2.4 and 7.13.2.5 provide needed criteria for the installation of the bonding connection and thedevices used. The final research report indicated that the arc fault current test recommended bySEFTIM in their Phase II proposal was not performed. The committee has not been provided with anytest data or supporting documentation relating to this issue. The committee also notes that this issuewas not included in the original Standards Council Decision 10-2. It is not clear to the committee ifthis testing would be instructive on the indirect lightning-related damage concerns. The StandardsCouncil decision requested the consideration of alternate methods, such as separation from otherequipment. The committee did not consider separation as a viable mitigation technique because ofthe inability to control the condition and location of wiring and piping after the initial construction iscompleted. In conclusion, CSST, bonded in accordance with the requirements of NFPA 54, providesa reasonable level of safety for fuel gas piping systems. Please note that SR 20 addresses the annexmaterial related to 7.13.2.





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Public Comment No. 53-NFPA 54-2013 [ Section No. 2.3.2 ]

2.3.2 ASTM Publications.

ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959,(610)832-9585, www.astm.org.

ASTM A 53, Standard Specification for Pipe, Steel, Black and Hot-Dipped, Zinc-Coated Welded andSeamless,2012.

ASTM A 106, Standard Specification for Seamless Carbon Steel Pipe for High-Temperature Service,2011.

ASTM A 254, Standard Specification for Copper-Brazed Steel Tubing, 1997 (Reaffirmed 2007).

ASTM B 88, Standard Specification for Seamless Copper Water Tube, 2009.

ASTM B 210, Standard Specification for Aluminum and Aluminum-Alloy Drawn Seamless Tubes, 2004.

ASTM B 241, Standard Specification for Aluminum and Aluminum-Alloy Seamless Pipe and SeamlessExtruded Tube,2010.

ASTM B 280, Standard Specification for Seamless Copper Tube for Air-Conditioning and RefrigerationField Service, 2008.

ASTM D 2513, Standard Specification for Polyethylene (PE) Gas Pressure Pipe, Tubing, andFittings,2012a.

ASTM D 2513, Standard Specification for Thermoplastic Gas Pressure Pipe, Tubing, and Fittings, 2008.

ASTM E 136, Standard Test Method for Behavior of Materials in a Vertical Tube Furnace at 750 DegreesC, 2011 2012 .

ASTM F 1973, Standard Specification for Factory Assembled Anodeless Risers and Transition Fittings inPolyethylene (PE) and Polyamide 11 (PA11) and Polyamide 12 (PA12) Fuel Gas Distribution Systems,2008.

ASTM F 2509, Standard Specification for Field-Assembled Anodeless Riser Kits for Use on OutsideDiameter Controlled Polyethylene Gas Distribution Pipe and Tubing, 2006 (Reaffirmed 2012).

ASTM E2652, Standard Test Method for Behavior of Materials in a Tube Furnace with a Cone-shapedAirflow Stabilizer, at 750°C, (2009a 2012 )


standards date updates


Submitter Full Name: Marcelo Hirschler

Organization: GBH International

Street Address:

City:

State:

Zip:

Submittal Date: Thu May 02 00:17:18 EDT 2013

Committee Statement

Committee Action: Accepted


Statement: The ASTM standards are updated to reflect the most current editions.


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

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


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2.3.3 CSA America Publications.

Canadian Standards Association, 8501 East Pleasant Valley Road, Cleveland, OH 44131-5575,(216)524-4990, www.csa-america.org.

ANSI LC 1/CSA 6.26, Fuel Gas Piping Systems Using Corrugated Stainless Steel Tubing (CSST), 2005.

ANSI LC 4/CSA 6.32, Press-Connect Copper and Copper Alloy Fittings for Use in Fuel Gas DistributionSystems, 2007 2012 .

ANSI Z21.8, Installation of Domestic Gas Conversion Burners, 1994 (Reaffirmed 2000).

ANSI Z21.11.2, Gas-Fired Room Heaters — Volume II, Unvented Room Heaters, 2011.

ANSI Z21.24/CSA 6.10, Connectors for Gas Appliances, 2006 (Reaffirmed 2011).

ANSI Z21.41/CSA 6.9, Quick-Disconnect Devices for Use with Gas Fuel Appliances, 2003.

ANSI Z21.54/CSA 8.4, Gas Hose Connectors for Portable Outdoor Gas-Fired Appliances, 2002(Reaffirmed 2007).

ANSI Z21.69/CSA 6.16, Connectors for Movable Gas Appliances, 2009.

ANSI Z21.75/CSA 6.27, Connectors for Outdoor Gas Appliances and Manufactured Homes, 2007.

ANSI Z21.80/CSA 6.22, Line Pressure Regulators,2011.

ANSI Z21.90/CSA 6.24, Gas Convenience Outlets and Optional Enclosures, 2001 (Reaffirmed 2005).

ANSI Z83.4/CSA 3.7, Non-Recirculating Direct Gas-Fired Industrial Air Heaters, 2003.

ANSI Z83.18, Recirculating Direct Gas-Fired Industrial Air Heaters, 2004.


The standard has been updated. This is the current version of the standard.


Submitter Full Name: CURTIS DADY

Organization: VIEGA

Street Address:

City:

State:

Zip:

Submittal Date: Mon Apr 29 20:15:08 EDT 2013

Committee Statement

CommitteeAction:



Statement: The title and publication dates of CSA Standards are updated to comply with the NFPA Manual ofStyle. ANSI Z21.93/ CSA 6.30 was added in accordancde with the second revision on 5.13.


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

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


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ANSI LC

44a /CSA 6.32, Press-Connect

Copper and Copper AlloyFittings for Use in Fuel Gas Distribution Systems,

20072013 .


ANSI Z21.11.2, Gas-Fired Room Heaters — Volume II, Unvented Room Heaters , 2011.

ANSI Z21.24/CSA 6.10, Connectors for Gas Appliances , 2006 (Reaffirmed 2011).





ANSI Z21.80/CSA 6.22, Line Pressure Regulators, 2011.


ANSI Z83.4/CSA 3.7, Non-Recirculating Direct Gas-Fired Industrial Air Heaters , 2003.



This is to reference the latest edition of CSA LC-4 (ANSI/CSA LC-4a 2013).


Submitter Full Name: Frank Shingleton

Organization: Viega LLC

Affilliation: Viega LLC

Street Address:

City:

State:

Zip:

Submittal Date: Mon Mar 11 13:17:14 EDT 2013

Committee Statement

CommitteeAction:




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

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


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ANSI LC 4/CSA 6.32, Press-Connect Copper and Copper Alloy Fittings for Use in Fuel Gas DistributionSystems, 2007.


ANSI Z21.11.2, Gas-Fired Room Heaters — Volume II, Unvented Room Heaters, 2011.

ANSI Z21.24/CSA 6.10, Connectors for Gas Appliances, 2006 (Reaffirmed 2011).





ANSI Z21.80/CSA 6.22, Line Pressure Regulators,2011.


ANSI Z83.4/CSA 3.7, Non-Recirculating Direct Gas-Fired Industrial Air Heaters, 2003 2013 .




NFGC_Comment_2.3.3.docx Original Comment


The 2013 version of this standard was just recently issued.




Street Address:

City:

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Committee Statement

CommitteeAction:





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Public Comment No. 26-NFPA 54-2013 [ Section No. 3.3.5.8 ]

3.3.5.8 Nonresidential, Low-Heat Appliance.

An A commercial, industrial, or institutional appliance needing a chimney capable of withstanding acontinuous flue gas temperature not exceeding 1000°F (538°C).


As a representative of the GOT Committee, I can report that the GOT committee is against this change. The GOT Committee's work has been to create general and consistent definitions of the same term throughout the NFPA system of documents, therefore we do not advocate the deletion of an extracted definition in favor of creating a unique definition. At the same time, the Committee acknowledges that the change to the definition that was agreed on by the NFPA 54 Committee creates a more generic definition. The 54 Committee may want to submit a proposal to the NFPA 211 Committee and recommend they change their definition and extract it from NFPA 54.


Submitter Full Name: Susan Desrocher


Affilliation: Glossary of Terms Committee member

Street Address:

City:

State:

Zip:

Submittal Date: Wed Apr 24 09:33:34 EDT 2013

Committee Statement

CommitteeAction:

Rejected

Resolution: The committee reaffirms the action taken in the First Draft meeting. It is impossible to define acommercial or industrial appliance. Therefore, the revised definition is more appropriate.


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

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


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3.3.55.5 Unit Heater.

A self-contained, automatically controlled, vented, fuel gas–burning

space heating

space–heating appliance, intended for installation in the space to be heated without the use of ducts,having integral means for circulation of air.


I propose an editorial change to the definition, inserting an en-dash between "space" and "heating appliance."


Submitter Full Name: Susan Desrocher

Organization: Freelance Editor

Street Address:

City:

State:

Zip:


Committee Statement



Statement: The revision is editorial.


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

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


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3.3.74 Pipe.

Rigid conduit of iron, steel, copper,

brass

copper alloys , aluminum, or plastic.

3.3.74.1 Equivalent Length Pipe.

The resistance of valves, controls, and fittings to gas flow expressed as equivalent length of straight pipefor convenience in calculating pipe sizes.


Brass and Bronze are copper alloys. This change eliminates outdated language and provides the appropriate terminology to the end user.


Submitter Full Name: Pennie Feehan

Organization: Pennie L. Feehan Consulting

Affilliation: Copper Development Association

Street Address:

City:

State:

Zip:

Submittal Date: Wed Mar 13 12:02:26 EDT 2013

Committee Statement

CommitteeAction:



Statement: Brass and bronze are copper alloys. This change eliminates outdated language and providesthe appropriate terminology to the end user.


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

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


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3.3.83.4 Monitoring Regulator.

A pressure regulator set in series with another pressure regulator for the purpose of automatically takingover in an emergency the control of the pressure downstream of the regulator in case that pressure tendsto exceed a set maximum, and it senses the same pressure as the line regulator .


This is comment made from Public Input #65.

This current definition does not distinguish between a monitor and series regulator. Gas Engineers Handbook states that a monitory regulator senses the same pressure as the line regulator. In series regulation, the two regulators do not sense the same pressure.


Submitter Full Name: Kevin Carlisle

Organization: Karl Dungs, Inc.

Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held

Resolution: The committee recognizes that there may be some confusion regarding the application anddefinitions of series and monitoring regulators. However, the committee is not convinced that theproposed language will clarify the issue. The committee notes that the concept of a series regulatorshould be specifically reviewed by the piping panel as it relates to 5.9.2.


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

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


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5.4.2.1*

The volumetric flow rate of gas to be provided shall be the sum of the maximum input of the appliancesserved. Where the input rating is not indicated, the gas supplier, appliance manufacturer, or a qualifiedagency shall be contacted, or the rating from Table 5.4.2.1 shall be used for estimating the volumetric flowrate of gas to be supplied.

Table 5.4.2.1 Approximate Gas Input

for Typical Appliances

Input

Btu/hr

Appliance (Approx.)

Space Heating Units

Warm air furnace

Single family 100,000

Multifamily, per unit 60,000

Hydronic boiler



Space and Water Heating Units

Hydronic boiler



Water Heating Appliances

Water heater, automatic storage 30 to 40 gal tank 35,000

Water heater, automatic storage 50 gal tank 50,000

Water heater, automatic instantaneous

Capacity at 2 gal/min 142,800



Water heater, domestic, circulating or side-arm 35,000

Cooking Appliances

Range, free standing, domestic 65,000

Built-in oven or broiler unit, domestic 25,000

Built-in top unit, domestic 40,000

Other Appliances

Refrigerator 3,000

Clothes dryer, Type 1 (domestic) 35,000

Gas fireplace direct vent 40,000

Gas log 80,000

Barbecue 40,000

Gas light 2,500

For SI units: 1 Btu/hr = 0.293 W.


Because ICC and IAPMO do not adopted NFPA 54 in its entirety, this table will not be available to the many end users. This table provides a Btu base value for fuel gas appliances so the installers and inspectors can keep


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projects moving prior to the purchase of fuel gas equipment.




Affilliation: Self

Street Address:

City:

State:

Zip:

Submittal Date: Thu Mar 21 16:48:14 EDT 2013

Committee Statement

CommitteeAction:

Rejected

Resolution: The committee reaffirms the action taken in the First Draft meeting. The table is provided forguidance only, and therefore is appropriately relocated to the annex.





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5.6.2.3* Copper and Brass Copper Alloys .

Copper and brass copper alloys pipe shall not be used if the gas contains more than an average of 0.3grains of hydrogen sulfide per 100 scf of gas (0.7 mg/100 L).







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5.6.2.4 Threaded Copper, Brass Copper Alloys , and Aluminum.

Threaded copper, brass copper alloys , or aluminum alloy pipe shall not be used with gases corrosive tosuch material.







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5.6.3.2* Copper and Brass Copper Alloys .

Copper and brass copper alloys tubing shall not be used if the gas contains more than an average of 0.3grains of hydrogen sulfide per 100 scf of gas (0.7 mg/100 L). Copper tubing shall comply with standardType K or Type L of ASTM B 88, Specification for Seamless Copper Water Tube, or ASTM B 280,Specification for Seamless Copper Tube for Air Conditioning and Refrigeration Field Service.







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5.6.8 Metallic Piping Joints and Fittings.

The type of piping joint used shall be suitable for the pressure and temperature conditions and shall beselected giving consideration to joint tightness and mechanical strength under the service conditions. Thejoint shall be able to sustain the maximum end force due to the internal pressure and any additionalforces due to temperature expansion or contraction, vibration, fatigue, or the weight of the pipe and itscontents.

5.6.8.1 * Pipe Joints.

Pipe joints shall be threaded, flanged, brazed, or welded. Where nonferrous pipe is brazed, the brazingmaterials shall have a melting point in excess of 1000°F (538°C). Brazing alloys shall not contain morethan 0.05 percent phosphorus.

5.6.8.2 Tubing Joints.

Tubing joints shall be made with approved gas tubing fittings, be brazed with a material having a meltingpoint in excess of 1000°F (538°C), or be made by press-connect fittings complying with ANSI LC-4,Press-Connect Copper and Copper Alloy Fittings for Use in Fuel Gas Distribution Systems . Brazingalloys shall not contain more than 0.05 percent phosphorus.

5.6.8.3 Flared Joints.

Flared joints shall be used only in systems constructed from nonferrous pipe and tubing whereexperience or tests have demonstrated that the joint is suitable for the conditions and where provisionsare made in the design to prevent separation of the joints.

5.6.8.4 Metallic Pipe Fittings.

Metallic fittings shall comply with the following:

(1) Threaded fittings in sizes larger than 4 in. (100 mm) shall not be used

(2) Fittings used with steel or wrought-iron pipe shall be steel,

brass

(1) copper alloys ,

bronze,

(1) malleable iron, or cast iron.

(2) Fittings used with copper or

brass

(1) copper alloys pipe shall be

copper, brass, or bronze


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(1) copper or copper alloys .

(2) Fittings used with aluminum alloy pipe shall be of aluminum alloy.

(3) Cast-Iron Fittings. Cast-iron fittings shall comply with the following:

(4) Flanges shall be permitted.

(5) Bushings shall not be used.

(6) Fittings shall not be used in systems containing flammable gas–air mixtures.

(7) Fittings in sizes 4 in. (100 mm) and larger shall not be used indoors unless approvedby the authority having jurisdiction.

(8) Fittings in sizes 6 in. (150 mm) and larger shall not be used unless approved by theauthority having jurisdiction.

(9) Aluminum Alloy Fittings. Threads shall not form the joint seal.

(10) Zinc–Aluminum Alloy Fittings. Fittings shall not be used in systems containing flammablegas–air mixtures.

(11) Special Fittings. Fittings such as couplings, proprietary-type joints, saddle tees,gland-type compression fittings, and flared, flareless, or compression-type tubing fittingsshall be as follows:

(12) Used within the fitting manufacturer's pressure–temperature recommendations

(13) Used within the service conditions anticipated with respect to vibration, fatigue,thermal expansion, or contraction

(14) Acceptable to the authority having jurisdiction

(15) Pipe Fittings shall not be drilled and tapped.







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5.6.8.1* Pipe Joints.

Pipe joints shall be threaded, flanged, brazed, press connected or welded. Where nonferrous pipe isbrazed, the brazing materials shall have a melting point in excess of 1000°F (538°C). Brazing alloys shallnot contain more than 0.05 percent phosphorus.


Press connected joints are approved and a safe way to make repairs to existing fuel gas systems. Listing them gives well-defined information for approvals and design of fuel gas systems.





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Submittal Date: Fri Mar 22 13:32:32 EDT 2013

Committee Statement

CommitteeAction:

Rejected but held

Resolution: The committee recognizes that the LC 4 standard has been expanded to include press-connectfittings for metallic piping. However, the publication of LC 4 was too late in the NFPA 54 revisionprocess to allow for complete vetting of the subject. Therefore, the comment is held for the nextrevision cycle.





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5.6.8.4 Metallic Pipe Fittings.

Metallic fittings shall comply with the following:

(1) Threaded fittings in sizes larger than 4 in. (100 mm) shall not be used

(2) Fittings used with steel or wrought-iron pipe shall be steel, brass, bronze, malleable iron, or cast iron.

(3) Fittings used with copper or brass pipe shall be copper, brass, or bronze.

(4) Fittings used with aluminum alloy pipe shall be of aluminum alloy.

(5) Cast-Iron Fittings. Cast-iron fittings shall comply with the following:

(a) Flanges shall be permitted.

(b) Bushings shall not be used.

(c) Fittings shall not be used in systems containing flammable gas–air mixtures.

(d) Fittings in sizes 4 in. (100 mm) and larger shall not be used indoors unless approved by theauthority having jurisdiction.

(e) Fittings in sizes 6 in. (150 mm) and larger shall not be used unless approved by the authorityhaving jurisdiction.

(6) Aluminum Alloy Fittings. Threads shall not form the joint seal.

(7) Zinc–Aluminum Alloy Fittings. Fittings shall not be used in systems containing flammable gas–airmixtures.

(8) Special Fittings. Fittings such as couplings, proprietary-type joints, saddle tees, gland-typecompression fittings, and flared, flareless, or compression-type tubing fittings shall be as follows:

(a) Used within the fitting manufacturer's pressure–temperature recommendations

(b) Used within the service conditions anticipated with respect to vibration, fatigue, thermalexpansion, or contraction

(c) Acceptable to the authority having jurisdiction

(9) Pipe Fittings shall not be drilled and tapped.

(10)


No evidence was provided that such drilling and tapping has resulted in an unsafe situation. A broad prohibition on such activities without evidence would unfairly impact gas operators. Some gas utilities routinely drill into a customer pipe fitting downstream from utilities meter in order to provide a temporary service connection when replacing or working on a meter. This is especially common practice at facilities/operations that require no interruption of service.


Submitter Full Name: JAMES RANFONE

Organization: AMERICAN GAS ASSN

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Submittal Date: Tue Apr 30 11:56:16 EDT 2013


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Committee Statement

CommitteeAction:



Statement: Industry experience demonstrates successful operations for drilling and tapping as described. Therevision acknowledges that drilling and tapping outdoors in the field can be safely performed byqualified operators according to written procedures.


I, JAMES RANFONE, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyrightin this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intendthat I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or anothersimilar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority toenter into this copyright assignment.

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


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Public Comment No. 30-NFPA 54-2013 [ Section No. 5.6.10.1.3 ]

content xmlText

5.6.10.1.3

Non-ferrous Copper flanges shall be in accordance with ASME/ANSI B16 .24, Cast Copper Alloy PipeFlanges and Flanged Fittings: Classes 150, 300, 600. 900, 1500, and 2500. Other non-ferrous flangesshall have dimensions according to ASME/ANS B16.1, B16.4, or B16.5.


The standard ASME/ANSI B16.25 is applicable to copper flanges, not to aluminum flanges.




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Committee Statement

CommitteeAction:

Rejected

Resolution: The committee rejected the comment because it would result in permitting aluminum flanges insizes similar to those of steel flanges. The committee is concerned that the strength of aluminumflanges in such sizes may not be sufficient for the application. The committee notes that the code iscurrently silent on the specification for aluminum flanges.





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5.6.11.3

Full-face flange gaskets shall be used with all non-steel flanges and shall be permitted to be used withraised flaced flanges .


Using a raised faced gasket with a flat faced flange reduces the required surface area to provide enough sealing for leak tightness. However, using a flat faced gasket with a raise faced flange does not reduce the surface area for sealing.




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Committee Statement

CommitteeAction:

Rejected

Resolution: The committee rejected the comment because the code currently does not prohibit the use offull-face flange gaskets with raised face flanges. Therefore, the proposed language is not needed.





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5.8.3 Overpressure Protection.

Where the gas supply design pressure in piping systems located indoors exceeds 2 psi (14 kPa) and linepressure regulators are installed to reduce the serve appliances designed to operate with a gas supplypressure to of 14 in. w.c. (3.4 kPa) or less, all of the following shall apply:

(1) Regulators shall be provided with factory-installed overpressure protection devices.

(2) Overpressure protection devices shall limit the pressure downstream of the line pressure regulator to2 psi (14 kPa) in the event of failure of the line pressure regulator.


Remove "design', which add ambiguity to the requirement.The other language added claries that the requirement speaks to those appliance that are not rated for pressures higher than 14"WC. If it does, then this requirement applies to gas engines, boilers, and industrial equipment that are designed to handle pressure above 14"WC. The unintended consequence is that 2 PSI would be the maximum permitted pressure to the appliance. For gas engines, boilers, and industrial equipment, this would be design restrictive.




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Statement: Section 5.9 has for many years required the installation of overpressure protection devices in certainlimited applications. The previous edition text was applicable to regulators supplied and maintainedby the serving utility or LP gas supplier and which are properly governed by either 49 CFR Part 192or by NFPA 58. As a practical matter, installers working within the scope of this Code will have noknowledge of whether or not the supplied gas contains materials that could seriously interfere withthe operation of the system or whether or not the gas pressure in the street is 60 psi or less (two ofthe previously-applicable triggers for overpressure protection). Further, the previous edition textexempted from any overpressure protection any systems meeting all of the attributes of 5.9.1.3 (3).The Committee considers an exclusion of this breadth unacceptable. Accordingly, the revised texteliminates the requirements which were primarily applicable to utility service regulators (and thereforeoutside the scope of this Code) and replaces them with requirements applicable to within-scopeequipment such as line regulators. Exemptions were tightened so that overpressure protection is nowrequired on each system containing an appliance with a maximum inlet pressure of 14” wc which issupplied with gas at the point of delivery at a pressure greater than 2 psig, and on each systemcontaining higher-operating-pressure appliances which is supplied with gas at the point of delivery ata pressure greater than that for which the appliances are rated. By narrowing the previously-permitted exemptions, the revised text provides assurance that appliances with a maximum inletpressure of 14” wc will not be subjected to more than 2 psig even with a line regulator failure and


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extends similar overpressure protection to appliances designed to operate with maximum inletpressures greater than 14” wc.





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Public Comment No. 28-NFPA 54-2013 [ New Section after 5.9 ]

5.9 Overpressure Protection – Where required

5.9.1 Where the serving gas supplier delivers gas at a pressure greater than 2 psi for piping systemsserving appliances designed to operate with gas supply pressure of 14 in. wc or less, overpressureprotection devices shall be installed. Piping systems serving equipment designed to operate with supplypressures greater than 14 in. wc shall be equipped with overpressure protection devices as required by theapplicable equipment construction and/or installation codes and standards for the connected equipment.

5.9.2.1 Where piping systems are required to be equipped with overpressure protection devices byparagraph 5.9.1 and serving appliances designed to operate with a gas supply pressure of 14 in. wc orless, each overpressure protection device shall be adjusted to limit the gas pressure to each connectedappliance to 2 psi or less upon a wide-open failure of the primary line pressure regulator.

Where piping systems are required to be equipped with overpressure protection devices by paragraph 5.9.1and Piping systems serving equipment designed to operate with delivery/supply pressures greater than 14in. wc each overpressure protection device shall be adjusted to limit the gas pressure to each connectedappliance as required by the applicable equipment construction and/or installation codes and standards forthe connected equipment.



54_Carlisle.pdf Cover Sheet


Current language is not clear if requirement applies to the burner manifold pressure or the supply pressure. Proposal claries the pressure reference.Current proposal does not permit other types of equipment (gas engines, gas turbines, industrial furnaces, etc) to have operating pressures above 2 PSI.This public comment is based on Committee Input #59.




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CommitteeAction:



Statement: Section 5.9 has for many years required the installation of overpressure protection devices in certainlimited applications. The previous edition text was applicable to regulators supplied and maintainedby the serving utility or LP gas supplier and which are properly governed by either 49 CFR Part 192or by NFPA 58. As a practical matter, installers working within the scope of this Code will have noknowledge of whether or not the supplied gas contains materials that could seriously interfere withthe operation of the system or whether or not the gas pressure in the street is 60 psi or less (two ofthe previously-applicable triggers for overpressure protection). Further, the previous edition text


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exempted from any overpressure protection any systems meeting all of the attributes of 5.9.1.3 (3).The Committee considers an exclusion of this breadth unacceptable. Accordingly, the revised texteliminates the requirements which were primarily applicable to utility service regulators (and thereforeoutside the scope of this Code) and replaces them with requirements applicable to within-scopeequipment such as line regulators. Exemptions were tightened so that overpressure protection is nowrequired on each system containing an appliance with a maximum inlet pressure of 14” wc which issupplied with gas at the point of delivery at a pressure greater than 2 psig, and on each systemcontaining higher-operating-pressure appliances which is supplied with gas at the point of delivery ata pressure greater than that for which the appliances are rated. By narrowing the previously-permitted exemptions, the revised text provides assurance that appliances with a maximum inletpressure of 14” wc will not be subjected to more than 2 psig even with a line regulator failure andextends similar overpressure protection to appliances designed to operate with maximum inletpressures greater than 14” wc.





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Public Comment No. 35-NFPA 54-2013 [ New Section after 5.13 ]

TITLE OF NEW CONTENT

EFV Minimum Supply Pressure

New Section 5.13.1 & 5.13.2

Type your content here ... TITLE OF NEW CONTENT

5.13 Excess Flow Valve(s)

5.13.1 General. Where automatic excess flow valves are installed, they shall be listed for the applicationand shall be sized and installed in accordance with the manufacturers' instructions.

5.13.2 Minimum Supply Pressure. Where one or more excess flow valves are installed in a piping systemor appliance connection, the minimum pressure at the inlet of each appliance downstream from the excessflow valve or valves shall be 5.5 in. w.c. for natural gas and 11 in. w.c. for LP gas. The pressure shall bemeasured with all appliances downstream of the excess flow valve or valves operating at their full inputrate.


The code currently contains minimum coverage for the installation of excess flow valves (EFV). The current coverage requires the installer to follow manufacturer’s installation instructions for their selection and installation. Since an EFV will have a higher pressure loss than typically installed piping components, the code will need to help ensure that the piping system will have the required capacity to meet the inputs of the connected appliances. AGA is proposing a simplified approach to help ensure that gas piping systems incorporating an EFV are properly designed. The proposed approach allows the continued use of the code’s piping sizing tables without the need to add equivalent lengths to take into account the EFV’s pressure loss. This helps avoid confusion regarding sizing of piping.To address these installations, a minimum inlet pressure to the appliance would be specified. The proposal’s minimum inlet pressure is the minimum pressures specified by most appliance manufactures in their installation instructions. These minimum inlet pressures help ensure proper appliance operation.While the code currently requires that appliances be provided with sufficient pressure for their operation, this requirement does not anticipate low abnormal operating pressures that may be present on extremely low pressure delivery systems during a peak heating period.




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Committee Statement

CommitteeAction:

Rejected

Resolution: The language is not needed because 5.4.1 requires that the piping system be sized and installedto supply gas at the minimum pressure required by the appliance.


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Public Comment No. 54-NFPA 54-2013 [ Section No. 5.13 ]

5.13 Excess Flow Valve(s).

Where automatic excess flow valves are installed, they shall be listed and shall be sized and installed inaccordance with ANSI Z21.93/CSA 6.30 and the manufacturers' instructions.


This was a committee comment change which needed the publication of ANSI/ Z21.93/CSA 6.30 inorder to reference it into 5.13. The document is now published and avaliable for purchase and review and should be added to 5.13


Submitter Full Name: sidney cavanaugh

Organization: [ Not Specified ]Cavanaugh Consulting

Affilliation: Brass Craft

Street Address:

City:

State:

Zip:


Committee Statement



Statement: The standard for excess flow valves was issued in March 2013.


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

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


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Public Comment No. 55-NFPA 54-2013 [ Section No. 5.13 ]

5.13 Excess Flow Valve(s).

Where automatic excess flow valves meeting ANSI Z21.93/CSA 6.30 are installed, they shall be listed andshall be sized and installed in accordance with the manufacturers' instructions.


This was a committe comment/change which needed the publication of ANSI Z21.93 inroder in reference in section 5.13. The standard is now published and avaliable for purchase and review and should now bw added to section 5.13. We have submitted two options for committee to consider.


Submitter Full Name: sidney cavanaugh

Organization: [ Not Specified ]Cavanaugh Consulting

Affilliation: Brass Craft

Street Address:

City:

State:

Zip:


Committee Statement



Statement: The standard for excess flow valves was issued in March 2013.


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

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


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Public Comment No. 44-NFPA 54-2013 [ Section No. 7.1.3 [Excluding any Sub-Sections]

]

Gas piping in contact with earth or other material that could corrode the piping shall be protected againstcorrosion . When dissimilar metals are joined underground, an insulating coupling or fitting shall be used.Piping shall not be laid in contact with cinders. Uncoated threaded or socket welded joints shall not beused in contact with soil or where internal or external crevice corrosion is known to occur.


This Committee Input provides needed requirements for a minumum level of safety for buried steel piping is needed in the Code. The Code currently requires "protection in an approved manor" for buried pipe. The proposed change providesa specific, recognized method for corrosion protection of buried pipe.


Submitter Full Name: Theodore Lemoff

Organization: TLemoff Engineering

Street Address:

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Committee Statement

CommitteeAction:



Statement: Section 7.1.3 is revised to provide specific requirements for protection of underground metallic pipefrom corrosion. The new requirements call for cathodic protection and periodic inspection of thecathodic protection system to ensure that it is operating, of if it needs to be replaced. Thisrepresents the state of the art in corrosion protection of underground steel pipe.


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

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


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7.1.3.1.4

Risers other than anodeless risers shall be cathodically protected by means of a welded anode. The anodesize and type shall be approved.


Section 7.1.3.1 requires that risers be protected by coating making the use of an anode unnecessary. In addition, the installation of an unnecessary anode may increase corrosion of steel piping connected to the riser.

The revised requirements for coating in FR 41 address correction protection of steel piping raised by public input. The draft CI 57 requirements are unenforceable and present a very prescriptive method that may not be appropriate for some installations.




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Committee Statement

CommitteeAction:

Rejected

Resolution: The committee rejected the comment because corrosion protection of risers, other thananodeless risers, should be addressed in the code.





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7.1.3.1.4

Risers other than anodeless risers shall be cathodically protected by means of a welded anode. The anode size and type shall be approved.


It is not reasonable to require approval of the size and type of the anode. This is information that the AHJ will most proably not have. Either a corrosion engineer or the anode manufacturer's insrtuction should be followed.




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Committee Statement

CommitteeAction:



Statement: Section 7.1.3 is revised to provide specific requirements for protection of underground metallic pipefrom corrosion. The new requirements call for cathodic protection and periodic inspection of thecathodic protection system to ensure that it is operating, of if it needs to be replaced. Thisrepresents the state of the art in corrosion protection of underground steel pipe.





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7.1.5 Piping Through Foundation Wall.

Underground piping , where installed through the outer foundation or basement wall of a building, shall beencased in a protective sleeve or protected by an approved device or method. The space between the gaspiping and the sleeve and between the sleeve and the wall shall be sealed to prevent entry of gas andwater. shall be brought above finished ground level before entering a building and shall be installed inaccordance with Section 7.2.1.



Swiecicki_P_I_15-7_1_5.pdf Cover Sheet


This proposal will establish consistency between the National Fuel Gas Code and the International Fuel Gas Code. The International Fuel Gas Code was changed in 2009 to prohibit the penetration of gas piping through a foundation wall below ground level. The reasons for this are:1. Fuel gas tends to follow the path of least resistance, which often is the trench in which the gas piping is laid.2. Heaving soil may have an adverse effect on a caulked sleeve, causing it to loosen and permit any leaking gas to penetrate the building. By allowing gas piping to enter the building only above grade, the potential for leaking gas from a below-grade gas leak to enter the building by migrating through the entry of the piping void in the foundation wall will be eliminated.


Submitter Full Name: Bruce Swiecicki

Organization: National Propane Gas Association

Street Address:

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Committee Statement

CommitteeAction:

Rejected

Resolution: The proposed language would result in forcing the penetration to occur above-grade. In urbanareas, this would require additional protection against damage or tampering. In addition, there is apotential for an increased hazard for installations where appliances are installed in the basement.Any requirement to bring the gas piping in above-grade would result in additional fittings and jointswhere potential leaks could occur. While eliminating the potential for gas to migrate along the gasline, that is not the only potential path for gas to migrate into a building.


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

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


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Approve with revision as follows.

7.13.2 *

CSST.

CSST gas piping systems shall be bonded to the electrical service grounding electrode system.

7.13.2.1. The bonding jumper shall connect to a metallic pipe or fitting between the point ofdelivery and the first downstream CSST fitting.

7.13.2.2. The bonding jumper shall not be smaller than 6 AWG copper wire or equivalent.Gas piping systems that contain one or more segments of CSST shall be bonded inaccordance with this section.

7.13.2.3 The length of the jumper between the connection to the gas piping system and agrounding electrode system shall not exceed 75 ft. (22.9 m). Any additional electrodes shall bebonded to the electrical service grounding electrode system.

7.13.2.4 Where a gas piping manifold is installed, it shall also be bonded to the electricalservice grounding electrode system.


The Committee Input adds a new Section 7.13.2.4 that requires a second bonding of the gas piping manifold. AGA proposes deletion of that new section because the final report presented to the committee does not provide evidence that an extra bond at a manifold location would increase safety over a single bond.




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Committee Statement

CommitteeAction:



Statement: The committee reviewed and discussed the final research report provided by GTI. The final reportclearly indicates that bonding a CSST piping system to the building’s grounding electrode systemwith a 6 AWG copper wire will dramatically reduce the likelihood of perforation or failure of the CSSTin the event of an indirect lightning strike compared to CSST that is not so bonded. The GTI reportadditionally indicates through modeling and testing that a single 6 AWG copper wire effectivelymitigates the hazard of induced currents resulting from indirect lightning strikes. Therefore, additionalbonding locations on the same piping system are not required. The GTI report indicates that therewas no perforation of the CSST in modeled scenarios with a 6 AWG copper wire length of up to 164ft. The committee chose a conservative approach by selecting a value of 75 ft as a margin of safety.


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Paragraph 7.13.2 is further revised to specifically allow bonding to a lightning protection systemwhere one is installed as an option to the building ground electrode or electrical panel bond. Thisrecognizes an alternate bond location in some cases. The test protocol used by GTI (Gas TechnologyInstitute) and LTI (Lightning Technologies, Inc.) utilized the recommendations for attaching thebonding jumper to the CSST contained in existing text A.7.13.2. The test results confirmed theefficacy of the bonding, therefore the connection method is validated. In addition,new sections7.13.2.4 and 7.13.2.5 provide needed criteria for the installation of the bonding connection and thedevices used. The final research report indicated that the arc fault current test recommended bySEFTIM in their Phase II proposal was not performed. The committee has not been provided with anytest data or supporting documentation relating to this issue. The committee also notes that this issuewas not included in the original Standards Council Decision 10-2. It is not clear to the committee ifthis testing would be instructive on the indirect lightning-related damage concerns. The StandardsCouncil decision requested the consideration of alternate methods, such as separation from otherequipment. The committee did not consider separation as a viable mitigation technique because ofthe inability to control the condition and location of wiring and piping after the initial construction iscompleted. In conclusion, CSST, bonded in accordance with the requirements of NFPA 54, providesa reasonable level of safety for fuel gas piping systems. Please note that SR 20 addresses the annexmaterial related to 7.13.2.





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7.13.2 * CSST.

CSST gas piping systems shall be bonded to the electrical service grounding electrode system. Thebonding jumper shall connect to a metallic pipe or fitting between the point of delivery and the firstdownstream CSST fitting. The bonding jumper shall not be smaller than 6 AWG copper wire or equivalent.Gas piping systems that contain one or more segments of CSST shall be bonded in accordance with thissection. CSST with an arc-resistance jacket listed by an approvd agency for installaiton without he directbondidng, as prescribed in this section, shall be installed in accordance with section 7.13.1 and themanufacturer's isntallation instructions.



7.13.2.pdf Original Comment

CSST_Susceptibility_Curves.pptx CSST

LC_1-c_all_proposed_changes.pdf LC-1-c


Comment Related to PI 44The use of a CSST product with a protective, arc-resistant jacket is an alternate method of protection against electrical arcingdamage caused by high voltage transient events such as a nearby lightning strike. An arc-resistant jacket does not rely on directbonding to the grounding electrode system to provide a low-impedance pathway to reduce or eliminate damage from electricalarcing. Instead, the protective jacket acts as a resistor and is designed to locally absorb and dissipate the arcing energy over a shortlength of the jacket. The jacket, in essence, disrupts the focus of the arc and reduces the energy level below the threshold value thatcan cause a perforation of the tubing wall. This dynamic action is equally effective compared to the current CSST bonding methodregardless of the bonding conductor size or length. The protection against arcing is provided uniformly throughout the pipingsystem. Protection is not affected by close proximity to other metallic systems that may not be similarly bonded, and is notdependent on the quality of the grounding electrode or its connection to ground.Although arc-resistant CSST products are tested and listed in accordance with an ICC Listing Criteria (LC1024 or LC1027), theover-riding ANSI LC-l consensus standard is in the [mal stages of being updated to include new performance requirements for arcresistantjackets. Addendum C to ANSI LC-l (attached) includes performance tests to demonstrate the viability of these jackets toresist arcing damage, withstand exposure to extreme environmental conditions and to verify jacket toughness. The testing criteria arebased on existing test methods from other certifying organizations/methods which have undergone public vetting with no objections.The ANSI certification process is nearly complete and is expected before the end of 20 13.PowerCET was requested to re-run the same piping system simulations utilized in the GTI Phase II research project to compare theeffectiveness of the arc-resistant CSST against yellow CSST as well as copper tubing. All appropriate adjustments were made basedon the electrical properties of arc-resistant jacket and copper tubing. The results from these new simulations indicate that arcresistantCSST is far less likely to be damaged from a lightning induced arc compared to yellow CSST and copper tubing.


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Theattached figure depicts the arc-charge and duration curves for these materials, and supports approval of the proposal to permit thesearc-resistant CSST products as an alternative method to direct bonding.CSST with arc-resistant jacket has been commercially installed since 2004, and at the present time, three different (black-jacketed)products are commercially available. Currently, at least 12 states permit the installation of the arc-resistant CSST without the needfor additional bonding. Given that both conventional (yellow) and advanced (black) CSST products will continue to becommercially available, both methods of electrical protection of CSST systems should be recognized and permitted within the Code.Documents Provided:• Draft Addendum C to ANSI LC-l• PowerCET Arc Charge and Duration Curves


Submitter Full Name: Robert Torbin

Organization: Omega Flex Inc.

Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected

Resolution: The committee notes that the revised LC1 standard is currently out for public review, and thereforehas not been published as an ANSI standard. In addition, it was reported to the committee that thetest currently required in the revised LC1 draft is not the same test that has been performed as partof the project validating the efficacy of bonding methods currently required by NFPA 54. Therefore,there is not sufficient evidence that the "black-jacketed" product presents equivalent protection tobonding in accordance with the current code requirements.


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

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


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CSST Susceptibility Curves

Michael F. StringfellowChief Scientist

PowerCET Corporation

0.1

1

10

100

1000

0.00001 0.0001 0.001 0.01 0.1 1

Arc Ch

arge in

Cou

lombs

Duration of Arc in Seconds

Conventional CSST

Copper Tube (40mil)

Arc‐Resistant CSST

Part I: Construction

1.10 Installer Training

The manufacturer shall establish and maintain an installer training program and a database of installers who have completed the manufacturer's training requirements. An identification card shall be supplied to each installer who has completed the manufacturer's training requirements, and a record of the installer’s contact data shall be maintained in the database. The identification card shall include the following information:

CSST manufacturer’s name and telephone numberCSST product(s)/brand(s) covered by trainingUnique serial number for the identification card (recorded in database)Installer’s name and the date of training or card issuance (recorded in database), andStatement that the named installer has completed the manufacturer’s training program to install [insert manufacturer’s name or brand] CSST

RATIONALE: Training of installers is a manufacturer-based requirement, and therefore it transcends any other installer qualifications imposed by the country, state or local jurisdiction such as licensing, education or apprenticeship. CSST systems have unique features, including fitting attachments proprietary to each manufacturer, which are not interchangeable between brands. The requirement has been modified and moved to the body of the Standard and not in Exhibit B since training is required whether the installer is US-based or Canada-based. The training requirement was modified to create auditable action items for the certifying agency such as a database and a training program.

1.2 Materials

1.2.6For tubing which includes a nonmetallic coating or covering, the coating shall comply with the international color designation of yellow. A jacket or covering applied to the tubing shall be either yellow or black, and marked in a contrasting color.

RATIONALE: To recognize alternate color jackets that are currently available in the marketplace consistent with other commercial gas-piping products.

Part II: Performance

2.15 Arc Resistant Jacket or Covering System (Optional)

2.15.1 General

© CSA Group- 2 -

2.15.1.1 Unless otherwise specified, all testing shall be performed in accordance with the general requirements of ANSI LC-1 and as stipulated in Part II Performance.

2.15.1.2 Tubing which has an arc resistant jacket or covering system as an alternate direct-bonding means (henceforth referred to as the "jacket") shall comply with the following tests.

2.15.1.3 Unless otherwise specified, the jacket shall comply with the following tests with the tubing, jacket, and fitting(s) assembled as a final installation and in accordance with the manufacturer's instructions.

2.15.1.4 Testing shall be performed on samples of tubing sizes ½-inch and 1-inch in diameter. Each test sample shall be at least three feet in length or as specified within the Method of Test.

2.15.2 Resistance of Jacket Material To Extreme Environment(s)

2.15.2.1 Resistance of Jacket Assembly to Extreme Temperature Cycles

Test specimens of the jacket material shall be prepared (based on the fabrication technique used to apply the jacket) and subjected to exposure to low temperature in accordance and compliance with ASTM D746-07 for Brittleness Temperature of Plastics and Elastomers by Impact. The manufacturer shall present a test report from an accredited testing laboratory to the listing agency including a statement on the minimum embrittlement temperature.

2.15.2.2 Resistance of Jacket Assembly to Corrosion

The tubing, jacket and fitting assembly (assembled per the manufacturer’s instructions) shall be subjected to the Standard Practice for Operating Salt Spray (Fog) Apparatus, ASTM B117-97, for not less than 96 hours without evidence of pitting, flaking, cracking or signs of corrosive attack in accordance with Part 1.2.5, and then shall be subsequently subjected to and pass Part 2.15.3 Electrical Tests. Two samples of each size shall be prepared and subjected to the prescribed test. Products that do not incorporate a metallic layer or component as part of the jacket are not required to be tested to 2.15.2.2. The manufacturer shall present a test report from an accredited testing laboratory to the listing agency and deliver the test samples to the laboratory performing the Electrical Tests.

© CSA Group- 3 -

2.15.3 Electrical Tests

2.15.3.1 Robustness Against Arcing (Indirect Lightning)

Tubing, jacket and fitting assemblies shall withstand electrical arcing, in accordance with the following method of test without perforation of the tubing and without leakage in excess of that specified in Part 2.2, Leakage. The test samples subjected to the salt spray exposure (if applicable) in Part 2.15.2.2 Resistance of Jacket Assembly to Corrosion shall be used in the testing. Other samples shall be used if no samples are required to be subjected to salt spray exposure in Part 2.15.2.2. Testing shall be performed by an accredited lightning testing laboratory acceptable to the listing agency.

Method of Test

For arc robustness determination, a electrical waveform (Current vs. Time) shall be utilized. (NOTE: Additional testing intended to address a wider range of possible transient sources and behaviors may be considered, but this has not been included in the prescribed Method of Test.) The waveform is defined by its rise-time to peak current and fall-time to 50 percent of peak amplitude. The selected waveform is 10μs x1000μs.

Generator Calibration:

An electrical test generator and appropriate measurement equipment shall be assembled to generate the waveform under consideration and to record generator output. (See Figure 1 for schematic.) The generator assembly shall utilize an electrode of ¼ in diameter attached to the output of the generator (i.e. live terminal). The test sample is grounded to the generator with a minimum AWG 6 copper conductor or equivalently sized braided strap. The test sample shall be supported in such a manner to prevent arcing or conduction from the test sample to adjacent equipment.

A length of copper pipe is installed as the test sample, with a 1/8 in gap between the copper pipe and the generator electrode. The generator is charged to the desired level, and discharged through the electrode to the copper pipe (via an arc) and then to ground. Arc attachment to the tubing shall be verified. Arc attachment to nearby equipment or to end connections on the copper tubing invalidates this test run. The recorded generator output is verified against the desired waveform. Adjustments to the generator assembly are made and re-tested until the generator output matches the desired waveform output.

Testing:

The test sample is installed with the electrode placed over a straight portion of the sample, with a 1/8 in gap between the exterior of the jacket and the generator electrode. (Refer to Figure 1) The generator is charged to the desired level, and discharged through the electrode to the test assembly (via arc) and to ground. Arc attachment to

© CSA Group- 4 -

the tubing shall be verified. Arc attachment to nearby equipment or to end connections on the tubing invalidates this test run.

Figure 1 Experimental Set-Up for Arc Resistance Test

The recorded generator output is verified against the desired waveform. Peak current and coulombs transferred (the integral of the waveform) are recorded. The jacket is removed from the site of the arc termination allowing a visual inspection of the exposed tubing. The tubing must show no puncture of the stainless steel tubing.

The test assembly must withstand a minimum of 4.5 Coulombs without leakage as defined by Part 2.2 Leakage.

2.15.4 Resistance to Installation Damage

Tubing and jacket assemblies shall withstand damage from friction/wear in a simulated “drag-zone” installation without excessive damage to the jacket in accordance with the following method of test.

Method of Test

Three individual simulated joists/ studs (spaced 16-inches on-center) made from solid, dimensional lumber (2 x 6 min) are mounted in a framework as shown in Figure 2. The “drag-zone” apparatus can be table or floor mounted. A routing hole shall be drilled through each joist in a 3-in off-set pattern as shown in Figure 2. Each routing hole shall be ½-inch greater in diameter than the outside diameter of the jacketed tubing specimen. The routing holes shall be drilled with a standard hole-cutter/drill bit and no post-drilling cleaning or dressing of the holes shall be permitted. No metal fasteners

© CSA Group- 5 -

shall be installed within the drag zone. The test apparatus shall be solidly secured to the table/floor to prevent movement or shaking of the assembly during the pull tests.

Two test specimens of each size, each consisting of a 15-ft length of tubing, shall be prepared. Each test specimen shall be “snaked” through the three offset holes before starting the test. The length of tubing is then pulled, by hand, through the drag zone untilthe end of the test specimen exits the last member. The rate of pull should be approximately 1 to 2 feet per second.

Figure 2 Set-Up for Tubing Wear Test

Upon completion of the pull test, the tubing and jacket shall be inspected for physical damage. Any tearing or ripping of the jacket exposing the underlying stainless steel tubing indicates non-compliance with this requirement.

RATIONALE: Some CSST products have been developed that use a coating or covering system to provide an alternate means of direct-bonding. If such a coating is provided as part of the CSST system, the added tests address the durability and integrity of the coating. The performance requirements and acceptance criteria represent minimally acceptable values that have been developed by independent sources. The International Code Council Evaluation Services have developed such testing methods and listing criteria (LC1024 – Listing Criteria for CSST Utilizing a Protective Jacket) that are being used to list current products. The proposed test methods are similar to testing widely used in the lightning analysis industry and have been recommended by independent lightning experts.

Exhibit B: Items Unique to United States

© CSA Group- 6 -

B.1 The installation shall be done by a qualified installer, who has passed the manufacturer’s certification/training program.

RATIONALE: Training of installers is a manufacturer-based requirement, and therefore it transcends any other installer qualifications imposed by the country, state or local jurisdiction such as licensing, education or apprenticeship. CSST systems have unique features, including fitting attachments proprietary to each manufacturer, which are not interchangeable between brands. The requirement has been modified and moved to the body of the Standard and not in Exhibit B since training is required whether the installer is US-based or Canada-based. The training requirement was modified to create auditable action items for the certifying agency such as a database and a training program.

Public Comment No. 20-NFPA 54-2013 [ Sections 8.1.4.1, 8.1.4.2 ]

Sections 8.1.4.1, 8.1.4.2

8.1.4.1

Test pressure shall be measured with a manometer or with a pressure measuring device designed andcalibrated to read, record, or indicate a pressure loss due to leakage during the pressure test period. Thesource of pressure shall be isolated before the pressure tests are made. Mechanical gauges used tomeasure test pressures shall have a range such that the highest end of the scale is not greater than 5times the test pressure.

8.1.4.2

The test pressure to be used shall be no less than 1 1 ? 2 times the proposed maximum workingpressure, but not less than 3 psi (20 kPa), irrespective of design pressure. Where the test pressureexceeds 125 psi (862 kPa), the test pressure shall not exceed a value that produces a hoop stress in thepiping greater than 50 percent of the specified minimum yield strength of the pipe.

8.1.4.2.1

Low pressure gas piping systems and/or a section of piping, shall be retested where the existingdelivery pressure is increased above 2 psig.

8.1.4.2.2

Medium pressure gas piping systems shall be retested in accordance with section when the existingdelivery pressure is increased.


Larger commercial and industrial customers many times request the serving gas utilitiy to increase delivery pressures to their piping systems to accommodate additional equipement and increased demand. Increasing the line pressure is an economical alternative to prevent the need to re-size (increase) existing houselines and significant cost to owners. Currently the NFGC is slient regarnding this issue of what to do customers request an increase of pressure to existing gas houselines...guidance is needed.


Submitter Full Name: SYLVESTER CAUDLE

Organization: SOUTHERN CALIFORNIA GAS CO

Street Address:

City:

State:

Zip:

Submittal Date: Tue Mar 19 17:23:42 EDT 2013

Committee Statement

CommitteeAction:

Rejected but held

Resolution: The subject of pressure testing piping systems that have an increase in the intended operatingpressure was not considered during the first revision process. Therefore, the committee held thecomment for the next full revision cycle.


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

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


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9.1.24 * Existing Appliances.

Where building envelope components of existing buildings are replaced or altered, the existing applianceinstallations shall be inspected to verify compliance with the provisions of Section 9.3 and Chapter 12 . Where the appliance installations do not comply with Section 9.3 and Chapter 12, they shall be altered asnecessary to be in compliance with such.


There are multiple problems with this proposed language. First of all, it is in the wrong code. The people who would need to see this section won't be looking in the NFGC if they aren't doing work on fuel gas systems or appliances in the first place. This language would need to be in the building code and point to this code.

The requirements of the proposed section is also extremely restrictive. It would require appliance installations to be inspected and brought up to current code even if minimal work is done on the exterior of the home, because there is no minimum amount of work before this requirement applies. This could lead to a homeowner being required to have costly work done to update the appliance venting and adding combustion air openings when a few siding boards are replaced or an insert unit is installed in a single window.

Finally, since the term 'building envelope' is not defined, it could mean anything from the air/thermal barrier to the weather resistive barrier--which could include the roof over an unconditioned attic. This could lead to a homeowner being required to update the appliance venting and adding combustion air openings when the shingles are replaced.


Submitter Full Name: DAN BUUCK

Organization: NAHB

Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected

Resolution: The committee rejected the comment because the new requirement is needed guidance forweatherization programs.


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

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


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Where building envelope components of existing buildings are replaced an existing appliance is locatedwithin the conditioned space of an existing building envelope and where a building envelope componentis replaced or altered, the existing the appliance installations shall be inspected to verify compliance withthe provisions of Section 9.3 and Chapter 12. Where the appliance installations do not comply withSection 9.3 and Chapter 12, they shall be altered as necessary to be in compliance with such.

Exception: Roofing material replacements.


The proposed requirement may be too broad. For example, a simple reroofing project that would not impact combustion air supplies would unnecessarily trigger the combustion air and venting checks. The new revised text and exception would permit certain building envelope changes without triggering the verification.




Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:



Statement: The committee considered the requirement as worded in the First Draft to be overly broad. Forexample, a simple re-roofing project that would not impact combustion air supplies may have beeninterpreted to unnecessarily trigger the combustion air and venting checks. The Second Revisionclarifies that certain building envelope changes do not trigger the verification.





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Where building envelope components of existing buildings are replaced or altered, the existing applianceinstallations shall be inspected to verify compliance with the provisions of Section 9.3 and Chapter 12 . Where the appliance installations do not comply with Section 9.3 and Chapter 12, they shall be altered asnecessary to be in compliance with such.


While the intent of the change has merit, it is unenforceable. Changes to the building envelope components are not done be gas installers, and not permitted by a gas official. If new windows are installed in a home, how will the window installer know that the air for combustion must be checked and that the venting system may have to be modified.




Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected

Resolution: The committee rejected the comment because the new requirement is needed guidance forweatherization programs.





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9.6.1.1

Connectors and tubing addressed in 9.6.1 (2), 9.6.1 (3), 9.6.1 (4), 9.6.1 (5), and 9.6.1 (6) shallbe installed so as to be protected against physical and thermal damage. Aluminum alloy tubingand connectors shall be coated to protect against external corrosion where they are in contact withmasonry, plaster, or insulation or are subject to repeated wettings by such liquids as water (exceptrain water) water other than rainwater , detergents, or sewage.


The phrase "or insulation or are subject to repeated wettings by such liquids as water (except rain water), detergents, or sewage" is revised for clarity. I do not know what liquids other than water are antipated, and if they would adversely affect connectors and tubing. It is my understanding tha te use of parenthetical phrases is discouraged by the NFPA style manual.




Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:



Statement: The committee added a title to be consistent with the NFPA Manual of Style and clarified thelanguage to remove the word "except."





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9.6.1.1 Protection of Connectors.

Connectors and tubing addressed in 9.6.1 (2), 9.6.1 (3), 9.6.1 (4), 9.6.1 (5), and 9.6.1 (6) shall beinstalled so as to be protected against physical and thermal damage. Aluminum alloy tubing andconnectors shall be coated to protect against external corrosion where they are in contact with masonry,plaster, or insulation or are subject to repeated wettings by such liquids as water (except rain water),detergents, or sewage.


A title is added to the requirement, as other requiremnets under 9.6.1 have titles.




Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:








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9.6.1.1 Protection of Connectors.

Connectors and tubing addressed in 9.6.1 (2), 9.6.1 (3), 9.6.1 (4), 9.6.1 (5), and 9.6.1 (6) shall beinstalled so as to be protected against physical and thermal damage. Aluminum alloy tubing andconnectors shall be coated to protect against external corrosion where they are in contact with masonry,plaster, or insulation or are subject to repeated wettings by such liquids as water (except rain water),detergents, or sewage.


A title is added, as other subsections of 9.6.1 have titles.




Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:








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9.6.1.3 Commercial Cooking Appliances Appliance Commectprs .

Connectors used with Commercial cooking appliances that are moved for cleaning and sanitationpurposes shall be connected installed in accordance with the connector manufacturer’s installationinstructions using a listed appliance connector complying Such connectors shall be listed in accordancewith ANSI Z21.69/CSA 6.16, Connectors for Movable Gas Appliances. The commercial cooking applianceconnector installation shall be configured in accordance with the manufacturer’s installation instructions.


The proposed paragraph is editorially revised for clairty. The title is revised to cover the subject, which is connectors for commercial cooking appliances and not the commercial cooking appliances. The first sentence split into two sentenced, and is revised by moving "connector" to the begining of the sentence and the connector must be installed, and not connected to be consistent with the use of "installed" in other sections of the Code. The last sentence is no longer needed with the use of "installed" rather than "connected" or "configured".




Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Accepted


Statement: The proposed paragraph is editorially revised for clairty. The title is revised to cover the subject,which is connectors for commercial cooking appliances. The first sentence is split into twosentences. The last sentence is no longer needed with the use of "installed" rather than"connected" or "configured".





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9.6.3

Injection Laboratory Equipment Burners. Laboratory equipment burners (Bunsen ) burners used , Teclu,Meker, or similar) with inputs of 12,000 btu or less, used in laboratories and educational facilities shall bepermitted to be connected to the gas supply by an unlisted hose.



NFGC_Comment_9.6.3.pdf Original Comment


The connection method described in Section 9.6.1(7) leaves room for interpretation even though it cites Section 9.6.3. In-shot burners, used in some space heating appliances could be considered “ Injection burners.” This provision is not intended to allow unlisted hose to be used to connect gas-fired equipment to the gas supply. The suggested limit to the input capacity is an arbitrary value, but at some level of energy input , even in a laboratory, the fuel connection to the burner should be more substantial than a rubber hose. Without a limit burners with inputs in the tens or hundreds of thousands could be connected with a rubber hose. Bunsen is but one type of burner utilized in laboratories.

Related Item

First Revision No. 67-NFPA 54-2012 [New Section after 9.6.2]




Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected

Resolution: The committee rejected the comment because a 12,000 BTUH input is not substantiated. Theintent of the new paragraph is to cover the small, portable burners that are typically used ineducational facilities.





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9.6.8 Sediment Trap.

Where a sediment trap is not incorporated as a part of the appliance, a sediment trap shall be installeddownstream of the appliance shutoff valve as close to the inlet of the appliance as practical at the time ofappliance installation. The sediment trap shall be either a tee fitting with a capped nipple in the bottomoutlet as illustrated in Figure 9.6.8 or other device recognized as an effective sediment trap. Illuminatingappliances, gas ranges, clothes dryers, decorative appliances for installation in vented fireplaces, gasfireplaces, and outdoor grills shall outdoor cooking appliances shall not be required to be so equipped.

Figure 9.6.8 Method of Installing a Tee Fitting Sediment Trap.


Proposed changes revise the terms in this section to be consistent with their use in the code and its definitions.


Submitter Full Name: James Osterhaus

Organization: Railroad Commission of Texas

Street Address:

City:

State:

Zip:

Submittal Date: Fri Apr 26 14:00:01 EDT 2013

Committee Statement



Statement: The paragraph is revised editorially to reflect the use of defined terms.


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

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


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12.5.1


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The type of venting system to be used shall be in accordance with Table 12.5.1 .

Table 12.5.1 Type of Venting System to Be Used

Appliances Type of Venting SystemLocation of

Requirements

Listed Category I appliances Type B gas vent 12.7

Listed appliances equipped with draft hood Chimney 12.6

Appliances listed for use with Type B gas vent Single-wall metal pipe 12.8

Listed chimney liningsystem for gas venting

12.6.1.3

Special gas vent listed forthese appliances

12.5.4

Listed vented wall furnaces Type B-W gas vent 12.7, 10.27

Category II appliances Category III appliances

Category IV appliances

As specified or furnished by manufacturers of listed

Special gas vent listed for these appliances 12.5.

2, 12.5.

4

Incinerators - In accordance with NFPA 82

Appliancesthat can beconverted touse solidfuel

Chimney 12.6

Unlistedcombinationgas- andoil-burningappliances

-

Combinationgas- andsolidfuel–burningappliances

-

Applianceslisted foruse withchimneysonly

-

Unlistedappliances

-

Listedcombinationgas- andoil-burningappliances

Type L vent

Chimney

12.7

12.6

Decorativeappliance inventedfireplace

Chimney 10.6.2


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-

Special gas vent listed for these appliances 12.

3

5 .

5

4

Appliances with integral vents - 12.3.6


In the proposed version, NFPA 54 skirts its purpose and responsibility for providing clear guidance to appliance and venting manufacturers as well as code inforcement officials in regards to venting an ever growing portion of the residential heating and warm water preparation market. Responsibility as well as liability for "venting" is solely delegated to the appliance manufacturer. While appliance manufacturers do extensive performance testing on their equipment and in conjunction, some safety testing on the "plastic piping used for venting" NFPA 54, 12.5.2), many safety tests required for any other venting material or venting system are not performed. Installation intructions provided for plastic pipe used for venting can and do vary from one appliance manufacturer to the other. Any venting system listed to UL 1738, the established standard for "Venting Systems for Gas Burning Appliances" however, delivers a product to the appliance manufacturer, the trade and the end user that has been thoroughly safety tested, has vetted and approved installation instructions and is labelled for easy identification. The responsibility for delivering a safe and reliable venting system to the industry is placed with the venting manufacturer, where it belongs.In this context, 12.5.2 and 12.5.3 need to be elininated from the current proposed version of NFPA 54.


Submitter Full Name: Martin Wawrla

Organization: Centrotherm Eco Systems

Street Address:

City:

State:

Zip:


Committee Statement

Committee Action: Rejected

Resolution: The committee rejected the comment because (insert from PS 8)


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

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


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69 of 106 11/27/2013 3:41 PM

12.5.1


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Requirements





12.6.1.3


12.5.4




As specified or furnished by manufacturers of listed appliances

Listedcombustiongas vent

12.5.2, 12.5.4



Chimney 12.6


-


-


-

Unlistedappliances

-


Type L vent

Chimney

12.7

12.6

Decorativeappliance inventedfireplace

Chimney 10.6.2


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TSS_Pinnacle_Burnt_Pipe.JPG Discolored PVC due to heat

Hamilton_EVO_PVC_Warped.JPG Warped PVC due to flue gas heat


It is paramount for any equipment used in all types of construction to be designed, constructed, tested and listed for said use. Safety is at the crux of this request. Currently, venting of category IV appliances only requires basic operational testing of said venting material. Generally these materials being approved by the manufacturer are PVC, CPVC, Polypropylene and Stainless Steel. PVC and CPVC have never been designed nor tested as combustion gas vents. Furthermore, the largest manufacturers of PVC and CPVC specifically denote that their product has never been tested or designed as a combustion gas vent and vehemently discourage their use as such via official statements. Essentially, the current wording and structuring of sections 12.5.1 and 12.5.2 allow for this use of unlisted combustion gas vent material. Through the above proposed corrective action the committee can close a glaring loophole in the National Fuel Gas Code which can jeopardize the safety of any individuals within a contained structure in which a category IV appliance is running. We have safety standards for construction materials covering from residential, commercial, industrial, and institutional buildings. These standards have been designed and crafted to ensure that the integrity of products will not fail during all aspects of construction and use. Why, then, would we not apply the same safety precautions in testing, listing and use to venting of combustion gasses? It is incomprehensible to imagine the allowable use of a specific material as a combustion gas vent when the respective manufacturer of the material does not recommend, test or approve of its use as a combustion gas vent. If a device carrying odorless, toxic gasses does not need to be listed to a safety standard, then why have safety standards or codes at all?


Submitter Full Name: Adam Hamilton


Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected

Resolution: The committee rejected the comment because insufficient evidence was provided that the subjectis inadequately covered by the ANSI/CSA appliance standards. The appliance listing specifies theventing products and materials. In addition, the current code text does not prevent the use of listedplastic venting systems.


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

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


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73 of 106 11/27/2013 3:41 PM

12.5.1


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Requirements





12.6.1.3


12.5.4




As specified or furnished by manufacturers of listed appliances

Type ofVentingSystemshall belisted.

12.5.2, 12.5.4



Chimney 12.6


-


-


-

Unlistedappliances

-


Type L vent

Chimney

12.7

12.6


75 of 106 11/27/2013 3:41 PM


Currently, venting of category IV appliances only requires basic operational testing of said venting material. Generally these materials being approved by the manufacturer are PVC, CPVC, Polypropylene and Stainless Steel. PVC and CPVC have never been designed nor tested as combustion gas vents. Furthermore, the largest manufacturers of PVC and CPVC specifically denote that their product has never been tested or designed as a combustion gas vent and vehemently discourage their use as such via official statements.




Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected






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12.5.2 Plastic Piping.

Where plasticPlastic piping

isused

to vent an appliance, the appliance shall be listed forfor venting appliances listed for use with such venting materials

and the appliance manufacturer's installation instructions shall identify the specific plastic piping materialshall be listed as a special combustion gas vent .


Proposed change would avoid the use and failure of unlisted combustion gas vents. Safety standards need to be in place for accepatble materials to be used for combustion gas vents.




Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected






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Public Comment No. 32-NFPA 54-2013 [ Sections 12.5.2, 12.5.3 ]

Sections 12.5.2, 12.5.3

12.5.2 Plastic Piping.

Where plastic piping is used to vent an appliance, the appliance shall be listed for use with such ventingmaterials and the appliance manufacturer's installation instructions shall identify the specific plastic pipingmaterial.

12.5.3 Plastic Vent Joints.

Plastic pipe and fittings used to vent appliances shall be installed in accordance with the appliancemanufacturer's installation instructions. Where primer is required, it shall be of a contrasting color.


Same as my comments submitted with the proposed changes to 12.5.1


Submitter Full Name: Martin Wawrla


Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected

Resolution: Other changes to the plastic vent requirements were not made, therefore it is not appropriate todelete the text as requested.


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

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


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Public Comment No. 16-NFPA 54-2013 [ Section No. A.5.6 ]


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A.5.6


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Table A.5.6 is a list of piping materials and fittings that are allowed in the code.

Table A.5.6 Pipe, Tube, Fittings, and Joints for Natural Gas and Liquefied Petroleum Gas Applications

PipeFitting Types Joint Types Other Requirements

Material Standard

Metallic Pipe

Black Steel

MinimumSchedule 40

ASTM A106*

Steel

Malleable Iron Steel CastIron

ASME B16.1*

Brass

Bronze Copper Alloys

Special

Threaded

Flanged

5.6.5, 5.6.6, 5.6.7,5.6.8, 5.6.8.4, 7.13

Galvanized SteelMinimumSchedule 40

ASTM A53*

Wrought Iron

MinimumSchedule 40

Also known aslow iron orwrought steel

ASMEB36.10M*

CopperNoneSpecified

Cast Copper Alloy

Bronze Brass CopperAlloys

Special

None Specified5.6.2.3, 5.6.2.4, 5.6.5,5.6.7, 5.6.8, 5.6.8.2,5.6.8.4, 7.13

Copper Alloy

(Brass)

NoneSpecified

Aluminum ASTM B241*Aluminum

SpecialNone Specified

5.6.2.4, 5.6.2.5, 5.6.3,5.6.5, 5.6.6, 5.6.7,5.6.8, 5.6.8.4, 7.13

Metallic Tubing

Copper

ASTM B 88*

ASTM B280*

Cast Copper Alloy

Wrought Copper Pressfittings meeting

ANSI LC4* Forged CopperAlloy

Special

Brazed

Flanged/Brazed

Brazed

Mechanically

Pressed (Crimped)Flared

5.6.3, 5.6.3.2, 5.6.5,5.6.6, 5.6.8.1, 5.6.8.2,7.13

CSSTANSI LC 1 /CSA 6.26*

ANSI LC 1 / CSA 6.26*Manufacturer'sinstallationinstructions

5.6.5, 5.6.6, 7.2.8, 7.13,9.6.1(5)

Aluminum

ASTM B210*

ASTM B241*

Copper Alloy (Brass)

SpecialCompression

5.6.5, 5.6.6, 7.13,9.6.1(2), 9.6.1(8)

SteelASTM A254*

Special5.6.3, 5.6.5, 5.6.6,5.6.8.4, 7.13

Non-Metallic Pipe

Polyethylene (PE)ASTM D2513*

Polyethylene (PE) ASTMD 2513*

(Heat fusion)

Service head adaptersmeeting Category I ofASTM D 2513*

Connections to MetallicPipe meeting ASTM D2513*, ASTM F 1973*, orASTM F 2509*

Manufacturer's

instructionsCompression-type

mechanical jointsHeat Fusion

5.6.5, 5.6.6, 5.6.9, 7.1.7


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*Required standard. See Annex L for standard title.







Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:








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Public Comment No. 15-NFPA 54-2013 [ Section No. A.5.6.3.2 ]

A.5.6.3.2

Copper and brass copper alloys tubing and fittings (except tin-lined copper tubing) should not be used ifthe gas contains more than an average of 0.3 grains of hydrogen sulfide per 100 scf of gas (0.7 mg/100 L).







Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:








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Public Comment No. 41-NFPA 54-2013 [ Section No. A.7.1.3 ]

A.7.1 .3

For information on corrosion protection of underground pipe, see NACE RP 0169, Control of ExternalCorrosion on Underground or Submerged Metallic Piping Systems. Information on installation,maintenance, and corrosion protection might be available from the gas supplier.

Corrosion prevention


Reject.Reason: The revised requirements for coatings in FR 41 address correction protection of steel piping raised by public input. The draft CI 57 (companion CI to this CI) requirements are unenforceable and present a very prescriptive method that may not be appropriate for some installations. The new Annex A material on CI 57 requirements provides guidance regarding one engineering method that may not be appropriate for all such protection systems.




Street Address:

City:

State:

Zip:


Committee Statement



Statement: The NACE document is updated to reflect the current title.





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A.7.13.2

The required bonding connection may be made from the piping to the electrical service equipmentenclosure, to the grounded conductor at the electrical service, to the grounding electrode conductor (whereof sufficient size), or directly to the grounding electrode.

Listed clamps are manufactured to facilitate attachment of the bonding conductor to either a segment ofrigid pipe or to a CSST brass copper alloy fitting. Clamps should be installed so as to remain accessiblewhen building construction is complete.

Clamps should be suitable for the location where they will be installed.

Bonding conductors should be protected from physical damage and can be installed outdoors above gradeor below grade or can be installed indoors.







Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:








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A.9.1.24

Building envelope changes such as the replacement of windows and doors, crack sealing, and theinstallation of air barriers, will reduce the amount of infiltration air and could impact the amount ofcombustion air that is available for existing appliance installations. Proper vent sizing and configuration iscrucial to maintaining the required vent performance in structures that have reduced air infiltration.


If the comment to delete 9.1.24 is accepted, this annex text is not needed.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 46-NFPA 54-2013 [Section No. 9.1.24]




Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected

Resolution: The mandatory text was not removed from the 2015 edition, therefore the annex text is stillneeded.





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Public Comment No. 18-NFPA 54-2013 [ Section No. B.4.1 ]

B.4.1 The Longest Length Method.

This sizing method is conservative in its approach by applying the maximum operating conditions in thesystem as the norm for the system and by setting the length of pipe used to size any given part of thepiping system to the maximum value.

To determine the size of each section of gas piping in a system within the range of the capacity tables,proceed as follows (also see sample calculations included in this annex):

(1) Divide the piping system into appropriate segments consistent with the presence of tees, branch lines,and main runs. For each segment, determine the gas load (assuming all appliances operatesimultaneously) and its overall length. An allowance (in equivalent length of pipe) as determined fromTable B.3.2 should be considered for piping segments that include four or more fittings.

(2) Determine the gas demand of each appliance to be attached to the piping system. Where Table6.2(a) through Table 6.2(x) are to be used to select the piping size, calculate the gas demand interms of cubic feet per hour for each piping system outlet. Where Table 6.3(a) through Table 6.3(m)are to be used to select the piping size, calculate the gas demand in terms of thousands of Btu perhour for each piping system outlet.

(3) Where the piping system is for use with other than undiluted LP-Gases, determine the design systempressure, the allowable loss in pressure (pressure drop), and specific gravity of the gas to be used inthe piping system.

(4) Determine the length of piping from the point of delivery to the most remote outlet in thebuilding/piping system.

(5) In the appropriate capacity table, select the row showing the measured length or the next longerlength if the table does not give the exact length. This length is the only length used in determining thesize of any section of gas piping. If the gravity factor is to be applied, the values in the selected row ofthe table are multiplied by the appropriate multiplier from Table B.3.4.

(6) Use this horizontal row to locate ALL gas demand figures for this particular system of piping.

(7) Starting at the most remote outlet, find the gas demand for that outlet in the horizontal row justselected. If the exact figure of demand is not shown, choose the next larger figure left in the row.

(8) Opposite this demand figure, in the first row at the top, the correct size of gas piping will be found.

(9) Proceed in a similar manner for each outlet and each section of gas piping. For each section ofpiping, determine the total gas demand supplied by that section.

When a large number of piping components (such as elbows, tees, and valves) are installed in a pipe run,additional pressure loss can be accounted for by the use of equivalent lengths. Pressure loss across anypiping component can be equated to the pressure drop through a length of pipe. The equivalent length of acombination of only four elbows/tees can result in a jump to the next larger length row, resulting in asignificant reduction in capacity. The equivalent lengths in feet shown in Table B.3.2 have been computedon a basis that the inside diameter corresponds to that of Schedule 40 (standard weight) steel pipe, whichis close enough for most purposes involving other schedules of pipe. Where a more specific solution forequivalent length is desired, this can be made by multiplying the actual inside diameter of the pipe ininches by n/12, or the actual inside diameter in feet by n. N can be read from the table heading. Theequivalent length values can be used with reasonable accuracy for copper or brass copper alloy fittingsand bends, although the resistance per foot of copper or brass pipe is less than that of steel. For copper orbrass copper alloy valves, however, the equivalent length of pipe should be taken as 45 percent longerthan the values in the table, which are for steel pipe.




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Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:








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Public Comment No. 70-NFPA 54-2013 [ Section No. C.3 ]

C.3 Leak Check Not Using a Meter.

This test can be done using one of the following methods:

(1) For Any Gas System.?To an appropriate checkpoint, attach a manometer or pressure gauge betweenthe inlet to the piping system and the first regulator in the piping system, momentarily turn on the gassupply, and observe the gauging device for pressure drop with the gas supply shut off. No discernibledrop in pressure should occur during a period of 3 minutes.

(2) For Gas Systems Using Undiluted LP-Gas System Preparation for Propane.?A leak check performedon an LP-Gas system being placed back in service can be performed by using one of the followingmethods:

(a) By inserting Insert a pressure gauge between the container gas shutoff valve and thefirst-stage regulator or integral two-stage regulator in the system, admitting full containerpressure to the system and then closing the container shutoff valve. Enough gas should then bereleased from the system to lower the pressure gauge reading by 10 psi (69 kPa). The systemshould then be allowed to stand for 3 minutes without showing an increase or a decrease in thepressure gauge reading.

(b) Insert a gauge/regulator test assembly between the container gas shutoff valve and first-stageregulator or integral two-stage regulator in the system. If a gauge/regulator test assembly withan inches water column gauge is inserted, follow the test requirements in (c) below; if a gauge/regulator test assembly with a 30 psi gauge is inserted follow the test requirements in (d).

(c) For systems with an integral two-stage, one or more second-stage, or one or more line pressureregulators serving appliances that receive gas at pressures of 1?2 psi (3.5 kPa) or less, byinserting insert a water manometer or pressure inches water column gauge into the systemdownstream of the final system stage regulator, pressurizing the system with either fuel gas orair to a test pressure of 9 in. w.c. ± 1?2 in. w.c. (2.2 kPa ± 0.1 kPa), and observing the device fora pressure change. If fuel gas is used as a pressure source, it is necessary to pressurize thesystem to full operating pressure, close the container service valve, and then release enoughgas from the system through a range burner valve or other suitable means to drop the systempressure to 9 in. w.c. ± 1?2 in. w.c. (2.2 kPa ± 0.1 kPa). This ensures that all regulators in thesystem upstream of the test point are unlocked and that a leak anywhere in the system iscommunicated to the gauging device. The gauging device should indicate no loss or gain ofpressure for a period of 3 minutes.

(d) By inserting a When testing a system that has a first-stage regulator, or an integral two-stageregulator, insert a 30 psi (207 kPa) pressure gauge on the downstream side of the first-stageregulator or at the intermediate pressure tap of an integral two-stage regulator , admitting normaloperating pressure to the system and then closing the container valve. Enough pressure gasshould be released from the system to lower the pressure gauge reading by 5 a minimum of 2psi (34 13 .5 8 kPa) so that the first-stage regulator is unlocked . The system should be allowedto stand for 3 minutes without showing an increase or a decrease in pressure gauge reading.

(e) Insert a gauge/regulator test assembly on the downstream side of the first stage regulator or atthe intermediate pressure tap of an integral two stage regulator. If a gauge/regulator testassembly, with an inches water column gauge is inserted, follow the test requirements in(c)above; if a gauge/regulator test assembly with a 30 psi gauge is inserted follow the testrequirements in (d) above.



Signed_PI_70_PI_14_Annex_C.pdf Cover Sheet



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In C.3 (2) (b) and (e), the proposal incorporates language to cover leak checking of systems utilizing a gauge/regulator test assembly with a low pressure regulator and an inches water column gauge or a test assembly with a high pressure regulator and a 30 psi gauge as part of the test assembly. The proposal refers the reader to the type of test that should be conducted when utilizing whichever type of test assembly is installed.

The addition of gauge/regulator test assemblies in C.3(2)(b) and (e) is to recognize new tools that are available and being used by bobtail drivers and service personnel. The gauge/regulator test assembly incorporates a pressure regulator that is part of the test assembly and is at the inlet to the pressure gauge. The regulator controls the pressure to the gauge when the tank service valve is opened to pressurize the system. With the system pressurized, the service valve is closed and gas pressure is released from the test assembly, dropping the gauge reading and unlocking the test assembly regulator as well as any regulators upstream of the test connection. After this is accomplished, the test gauge will now read the system pressure, allowing the leak check to be conducted. In C.3 (2) (c), there are systems that utilize a number of second-stage regulators supplied from one first-stage regulator and 2 psi systems may use a number of line pressure regulators supplied from one first-stage and a 2 psi regulator. The requirement in the test protocol is to insure regulators upstream of the selected checkpoint are unlocked. If there are piping systems with regulators in parallel within the piping system and there is a leak in the parallel line, the new provisions would insure that the parallel regulator would not lockup and the leak would be detected. If there is no leak in the parallel line, the parallel regulator would lockup as expected and that is acceptable. This change specifically addresses the need for a clarification of the testing required when there is more than one second stage regulator and the procedure to ensure the regulators are unlocked during the test.

Paragraph C.3 (2) (d) adds testing information for 5 psi first-stage regulators which are utilized in many of the northern States where container pressures can drop to 10 psi. The 2 psi minimum pressure reduction will insure that the first stage regulator, 5 or 10 psi outlet setting is unlocked when the leak check is performed.


Submitter Full Name: Bruce Swiecicki

Organization: National Propane Gas Association

Affilliation: NPGA Technology, Standards and Safety Committee

Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Accepted


Statement: In C.3 (2) (b) and (e), the revision incorporates language to cover leak checking of systems utilizing agauge/regulator test assembly with a low pressure regulator and an inches water column gauge or atest assembly incorporating a high pressure regulator and a 30 psi gauge. The revised text refers thereader to the type of test that should be conducted when utilizing whichever type of test assembly isinstalled. The addition of gauge/regulator test assemblies in C.3(2)(b) and (e) recognizes new toolsthat are available and being used by bobtail drivers and service personnel. The gauge/regulator testassembly incorporates a pressure regulator at the inlet to the pressure gauge. The regulator controlsthe pressure to the gauge when the tank service valve is opened to pressurize the system. With thesystem pressurized, the service valve is closed and gas pressure is released from the test assembly,dropping the gauge reading and unlocking the test assembly regulator as well as any regulatorsupstream of the test connection. After this is accomplished, the test gauge reads the systempressure, allowing the leak check to be conducted. In C.3 (2) (c), there are systems that utilize anumber of second-stage regulators supplied from one first-stage regulator. Two psi systems may usea number of line pressure regulators supplied from one first-stage and a 2 psi regulator. Therequirement in the test protocol is to ensure that regulators upstream of the selected checkpoint areunlocked. If there are piping systems with regulators in parallel within the piping system and there is a


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leak in the parallel line, the revised test method ensures that the parallel regulator would not lock upand the leak would be detected. If there is no leak in the parallel line, the parallel regulator would lockup as expected and that is acceptable. This change specifically addresses the need for a clarificationof the testing required when there is more than one second stage regulator and the procedure toensure the regulators are unlocked during the test. Paragraph C.3 (2) (d) adds testing information for5 psi first-stage regulators which are utilized in many of the northern States where containerpressures can drop to 10 psi. The 2 psi minimum pressure reduction will insure that the first stageregulator, 5 or 10 psi outlet setting is unlocked when the leak check is performed.


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

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


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Public Comment No. 56-NFPA 54-2013 [ New Section after G.1 ]

(Revised Annex G.5.2 per Committee Input 55)

(3) Spillage Test. Verify that all appliances located within the same room are in their standby mode andready for operation. Follow lighting instructions for each appliance as necessary. Test for spillage at thedraft hood relief opening as follows:

a. After 52 minutes of main burner operation check for spillage using smoke.



Comment_Form_NFPA54_pwf5.docx Original - Public Comment Submission


-Revision to the new annex material G.5.2 per the attachment in Committee Input 55-

My understanding is that the 5 minute spillage test is based on a cold flue. In an evaluation of an existing appliance such as a water heater it is unlikely that the flue will be cold. Additionally, it is likely that such appliances will often have on-times of less than 5 minutes in a cycle. Field experience suggests that appliances that spill after 2 minutes are likely to spill after 5 minutes. The 2 minute requirement is therefore more consistent with existing appliance applications and saves time without substantially impacting the failure rate.

Related Item



Submitter Full Name: PAUL FRANCISCO


Street Address:

City:

State:

Zip:

Submittal Date: Tue May 07 13:53:01 EDT 2013

Committee Statement

CommitteeAction:

Rejected

Resolution: The 5 minute time period has proven to be an acceptable and manageable amount of time for manyyears and this has been referenced and copied in many documents. Changing this procedurewould likely create conflict and confusion. No technical justification was provided to substantiatereducing the wait time to a 2-minute time period.


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I, PAUL FRANCISCO, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyrightin this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intendthat I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or anothersimilar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority toenter into this copyright assignment.

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


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(Revise proposed Annex G.5.2 from Committee Input 55)

(1) Preparing for Inspection. Close all building doors and windows and all doors between the space inwhich the appliance is located and other spaces of the building that can be closed. Close all doors to roomsthat contain only supply outlets and no return or exhaust inlets. Turn on any clothes dryer. Turn on anyexhaust fans, such as range hoods and bathroom exhausts, so they will operate at maximum speed. Donot operate a summer exhaust fan. Close fireplace dampers and any fireplace doors.



Comment_Form_NFPA54_pwf4.docx Original Public Comment Submission


- Revise proposed Annex G.5.2 per Committee Input 55 -

Closing rooms that have only supply registers or supply ventilation outlets has the potential to depressurize the rest of the building. This step is a quick means of evaluating the impact of potentially common room configurations (such as all bedroom doors being closed) on building pressure without requiring assessment of the impact of each and every door in the building.

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Rejected

Resolution: This process is intended for use as a guide. Modifications may be necessary based on the type ofconstruction, site conditions, an individual’s knowledge and experience, etc. While the proposalmay add some efficiency to the process, the substantiation contains no supporting technicalinformation.


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(1) Preparing for Inspection. Close all building doors and windows and all exterior doors between thespace in which the appliance is located and other spaces of the building that can be closed. Turn on anyclothes dryer. Turn on any exhaust fans, such as range hoods and bathroom exhausts, so they will operateat maximum speed. Do not operate a summer exhaust fan. Close fireplace dampers and any fireplacedoors.





- Revise proposed Annex G.5.2 from Committee Input 55-

Many people are in the practice of closing and opening interior doors as part of the combustion safety assessment process. This portion of the preparation for inspection is specifically meaning to refer to exterior doors, so adding the word “exterior” will clarify to people that this step is specifically focused on exterior doors.



Public Comment No. 57-NFPA 54-2013 [New Section after G.1]

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Statement: Annex G has been expanded and rewritten to provide comprehensive guidance on procedures tofollow when inspecting gas appliances, particularly before and after weatherizing a home. Inaddition, Annex G has been rewritten to reflect modern appliances and installation practices and has


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been updated to include more inspection details (including actionable CO and gas leakmeasurements/levels) and to cover additional appliances.





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(6) If, after completing the spillage test it is believed that air handler operation can cause excessivedepressurization, the owner should be notified that the ducting and/or return grilles in the space containingthe appliance must be sealed and, if necessary, additional fully-ducted return air should be provided.





If there is excessive depressurization due to operation of the air handler then it is not an issue of bringing in more combustion air per Section 9.3 of the NFGC but rather a duct problem that must be corrected. This change provides appropriate guidance.

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(1) Preparing for Inspection. Close all building doors and windows and all doors between space in whichthe appliance is located and other spaces of the building that can be closed. Turn on any clothes dryer. Turn on any exhaust fans, such as range hoods and bathroom exhausts, so they will operate at maximumspeed. Do not operate a summer exhaust fan. Close fireplace dampers and any fireplace doors. Openthe door between the space in which the appliance is located and the rest of the building. If thecombustion appliance zone is depressurized due to opening the door leave it open, otherwise close it.





It is possible for exhaust fans in other spaces of the building to cause excessive depressurization only when the door to the space in which the appliance is located is open. An example would be a large kitchen exhaust in a home in which the combustion appliance is located in a basement, and in which the door between the first floor and the basement is tight-fitting. When the door is closed the kitchen exhaust may not be able to pull much air from the basement, but when it is open it is then able to pull excessive air from the basement and cause spillage. This must be evaluated in order to cover the range of common causes of spillage. This must be done separately from turning on all fans which exhaust air because the position of this door may cause either negative or positive pressure impacts.



Public Comment No. 57-NFPA 54-2013 [New Section after G.1] (1) Preparing for Inspection


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Resolution: SR-23-NFPA 54-2013 PC 58: The committee agrees that the word “exterior” is needed forclarification but will locate it between “all” and “building” in the first sentence. The word “interior” isalso added for clarification to the first between “all” and “doors”. PC 59, 60, and 61: The committee


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agrees that the appliance installation should be evaluated to determine if spillage occurs underseveral other conditions. An additional spillage test was added to the revised Annex G under a newG.5.2 (4).






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(1) Preparing for Inspection. Close all building doors and windows and all doors between the space inwhich the appliance is located and other spaces of the building that can be closed. Turn on any clothesdryer. Turn on any exhaust fans, such as range hoods and bathroom exhausts, so they will operate atmaximum speed. Do not operate a summer exhaust fan. Close fireplace dampers and any fireplacedoors. Turn on the air handler fan. If the space in which the appliance is located is depressurized due toair handler operation leave it on, otherwise turn it off.





Air handler fan operation can cause significant depressurization, especially in the case of return grilles (which may have been added after the appliance was installed, such as for the addition of central air-conditioning) or other return leaks in the space. This must be evaluated in order to cover the range of common causes of spillage. This must be done separately from turning on all fans which exhaust air because air handlers may cause either negative or positive pressure impacts.






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Public Comment No. 42-NFPA 54-2013 [ Section No. G.1 ]


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G.1 General.

The following procedure is intended as a guide to aid in determining that an appliance is properly installedand is in a safe condition for continuing use.

This procedure is intended for central furnace and boiler installations, and might not be applicable to allinstallations.

This procedure should be performed prior to any attempt to modify the appliance or the installation.

If it is determined a condition that could result in unsafe operation exists, shut off the appliance and advisethe owner of the unsafe condition.

The following steps should be followed in making the safety inspection:

(1) Conduct a test for gas leakage.

(2) Visually inspect the venting system for proper size and horizontal pitch, and determine that there isno blockage, restriction, leakage, corrosion, or other deficiencies that could cause an unsafecondition.

(3) Shut off all gas to the appliance, and shut off any other fuel gas–burning appliance within the sameroom. Use the shutoff valve in the supply line to each appliance.

(4) Inspect burners and crossovers for blockage and corrosion.

(5) Furnace Installations: Inspect the heat exchanger for cracks, openings, or excessive corrosion.

(6) Boiler Installations: Inspect for evidence of water or combustion product leaks.

(7) Close all building doors and windows and all doors between the space in which the appliance islocated and other spaces of the building that can be closed. Turn on any clothes dryers. Turn on anyexhaust fans, such as range hoods and bathroom exhausts, so they operate at maximum speed. Donot operate a summer exhaust fan. Close fireplace dampers. If, after completing Steps 8 through 13,it is believed sufficient combustion air is not available, refer to Section 9.3 of this code.

(8) Place the appliance being inspected in operation. Follow the lighting instructions. Adjust thethermostat so the appliance operates continuously.

(9) Determine that the pilot, where provided, is burning properly and that the main burner ignition issatisfactory by interrupting and re-establishing the electrical supply to the appliance in anyconvenient manner. If the appliance is equipped with a continuous pilot, test all pilot safety devices todetermine whether it is operating properly by extinguishing the pilot when the main burner is off anddetermining, after 3 minutes, that the main burner gas does not flow upon a call for heat. If theappliance is not provided with a pilot, test for proper operation of the ignition system in accordancewith the appliance manufacturer’s lighting and operating instructions.

(10) Visually determine that the main burner gas is burning properly (i.e., no floating, lifting, or flashback).Adjust the primary air shutters as required. If the appliance is equipped with high and low flamecontrols or flame modulation, check for proper main burner operation at low flame.

(11) Test for spillage at the draft hood relief opening after 5 minutes of main burner operation. Use theflame of a match or candle or smoke.

(12) Turn on all other fuel gas–burning appliances within the same room so they operate at their fullinputs. Follow lighting instructions for each appliance.

(13) Repeat Steps 10 and 11 on the appliance being inspected.

(14) Return doors, windows, exhaust fans, fireplace dampers, and any other fuel gas–burning applianceto their previous conditions of use.

(15) Furnace Installations: Check both the limit control and the fan control for proper operation. Limitcontrol operation can be checked by blocking the circulating air inlet or temporarily disconnecting theelectrical supply to the blower motor and determining that the limit control acts to shut off the mainburner gas.

(16) Boiler Installations: Verify that the water pumps are in operating condition. Test low-water cutoffs,automatic feed controls, pressure and temperature limit controls, and relief valves in accordance withthe manufacturer’s recommendations to determine that they are in operating condition.



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AGA_Annex_G_Revisions_2013.docAdditional editorial revisions to Revised Annex G April 30, 2013


AGA supports the proposed revisions to Public Input and Committee Input to Annex G and includes some additional editorial comments.




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