Technical Committee on Vehicular Alternative Fuel Systems

Technical Committee on Vehicular Alternative Fuel Systems

Date: April 14, 2017 To: Technical Committee on Vehicular Alternative Fuel Systems From: Eric Nette, Staff Liaison/Engineer Re: Agenda Package – NFPA 52 F2018 First Draft Meeting –May 2-4, 2017

Enclosed is the agenda package for the May 2-4, 2017 meeting for the NFPA 52 First Draft Meeting. Please ensure that you have reviewed the public input and the other agenda items in advance to prepare for discussion. The agenda and public input will be posted on the document information pages (www.nfpa.org/52next). Some items to have available during the meeting include:

Agenda package with public input

A copy of NFPA 52 (visit the NFPA 52 Document information pages for your free committee copy)

Any previous copies of the technical committees standard

A laptop

Optional items that are sometimes useful include:

Review of NFPA’s Process, www.nfpa.org/regs If you have any questions or comments, please feel free to reach me at (617) 984-7434 or by e-mail at [email protected]. I look forward to our meeting to begin the revision cycle!

http://www.nfpa.org/52next

NFPA 52 F2018 First Draft Meeting May 2-4, 2017

Hyatt House Charlotte/Center City http://nfpa.adobeconnect.com/nette/

8:00 a.m. to 5:00 p.m. (Eastern Time Zone)

1. Meeting opening, introduction and attendance

2. Approval of Second Draft Meeting Minutes of March 10-12, 2015 (Attachment A.

March 10-12, 2015 Meeting Minutes).

3. Chair's remarks, Stephen Abernathy

4. Staff Liaison update:

a. F2018 Schedule (Attachment B. F2018 Revision Cycle)

b. Committee Membership Update (Attachment C. VAF-AAA Membership)

c. Standards Process Review (Attachment D. NFPA Process – Quick Reference

Guide)

5. Old/New Business

a. Public Input for NFPA 52 (Attachment E. NFPA 52 - F2018 Public Input) and

development of First Revisions (Attachment D. NFPA Process Quick

Reference Guide)

6. Other business

7. Date/Location of Next Meeting. (Second Draft Meeting between January 1, 2018 and

May 17, 2018)

8. Adjournment (May 4)

Attachments:

A. March 10-12, 2015 Meeting Minutes

B. F2018 – Revision Cycle

C. VAF-AAA Committee Membership

D. NFPA Process – Quick Reference Guide

E. NFPA 52 - F2018 Public Input

Address List No PhoneVehicular Alternative Fuel Systems VAF-AAA

Janna E. Shapiro04/14/2017

VAF-AAAStephen V. AbernathyChairPiedmont Natural GasPO Box 16087Greenville, SC 29606

U 10/23/2013VAF-AAA

Ronald C. AdcockPrincipalMarsh Risk Consulting2325 East Camelback Road, Suite 600Phoenix, AZ 85016

I 1/1/1993

VAF-AAAJim AmesPrincipalAmeswest Technical ServicesOwner265 W 2000 SPerry, UT 84302

IM 08/03/2016VAF-AAA

Michael BattaglliaPrincipalCNG-ONE, LLC5837 Akron Cleveland RoadHudson, OH 44236-2009

IM 08/11/2014

VAF-AAADan BowersonPrincipalNGVAmericaDirector of Technology and Development23650 MarshallDearborne, MI 48124

M 12/08/2015VAF-AAA

Julie CairnsPrincipalCSA Group8501 East Pleasant Valley RoadCleveland, OH 44131-5516

RT 12/08/2015

VAF-AAAMatt T. CreedonPrincipalPacific Gas & Electric Company361 The AlamedaSan Anselmo, CA 94960-1230

U 08/03/2016VAF-AAA

Donna I. DennyPrincipalWestport Innovations Inc.1750 West 75th Avenue, Apt. 101Vancouver, BC V6P6G2 Canada

M 04/08/2015

VAF-AAADenis C. K. DingPrincipalClean Energy Fuels Corporation4675 MacArthur Court, Suite 800Newport Beach, CA 92660-1895

M 08/11/2014VAF-AAA

Thomas J. ForsythePrincipalJENSEN HUGHES2950 Buskirk AvenueSuite 225Walnut Creek, CA 94597-8862

SE 10/1/1994

VAF-AAAAlan D. HatfieldPrincipalBraemar Engineering13000 Hunters Creek RoadCollege Station, TX 77845

SE 08/11/2014VAF-AAA

John JordanPrincipalAgility Fuel SystemsPO Box 1177Cook, MN 55723

M 08/03/2016

VAF-AAAQuon Y. KwanPrincipalUS Department of TransportationFederal Motor Carrier Safety Administration1200 New Jersey Avenue, SERoom W68-305Washington, DC 20590US Department of Transportation

E 10/29/2012VAF-AAA

Reid B. LarsonPrincipalChart Industries407 7th Street North WestNew Prague, MN 56071

M 08/03/2016

1



VAF-AAARick LongPrincipalPetroleum Equipment InstitutePO Box 2380Tulsa, OK 74101

IM 11/30/2016VAF-AAA

Michael W. MackeyPrincipalGP Strategies1918 Don Lee PlaceEscondido, CA 92029Alternate: James P. Lewis

SE 9/30/2004

VAF-AAAPaul E. MayPrincipalBechtel Marine Propulsion Corporation3217 New England RoadWest Mifflin, PA 15122-3140


Timothy E. MeyersPrincipalUS Coast GuardOffice of Design & Engineering Standards2100 2nd Street SW, Stop 7126Washington, DC 20593Alternate: Andrew Gibbons

E 8/9/2011

VAF-AAAGeorge C. MitchellPrincipalNational Renewable Energy Laboratory15013 Denver West ParkwayRSF 403Golden, CO 80401-3111

U 08/03/2016VAF-AAA

Randy MosesPrincipalWayne Fueling Systems LLC1000 East Walnut StreetHeritage Campus, Suite 404Perkasie, PA 18944

M 10/23/2013

VAF-AAANancy C. PehrsonPrincipalCenterPoint Energy, Inc.700 West Linden AvenuePO Box 1165Minneapolis, MN 55440

U 1/1/1991VAF-AAA

April Dawn RichardsonPrincipalRailroad Commission of Texas1701 North Congress Avenue PO Box 12967Austin, TX 78711

E 11/30/2016

VAF-AAAJerrold SamethPrincipalCompressed Gas Association, Inc.290 DeMott AvenueClifton, NJ 07011-3749Compressed Gas AssociationAlternate: Richard A. Craig

M 07/29/2013VAF-AAA

Joel E. SipePrincipalExponent, Inc.2720 Harrison StreetOakland, CA 94612

SE 08/11/2014

VAF-AAAGlen E. SmithPrincipalArgus Consulting, Inc.6363 College Boulevard, Suite 600Overland Park, KS 66211-1882American Railway Engineering & Maintenance-of-WayAssn.


E. Michael SteelePrincipalSteele Consulting5855 Stratmore AvenueCypress, CA 90630-4623Society of Automotive Engineers

M 03/21/2006

VAF-AAAKent WhitingPrincipalBlackPak Inc.1933 Davis StreetSan Leandro, CA 94577

M 08/03/2016

2



VAF-AAATed WilliamsPrincipalAmerican Gas Assocication400 North Capitol Street, NWWashington, DC 22204American Gas Association

U 08/09/2012VAF-AAA

Richard A. CraigAlternateCompressed Gas Association14501 George Carter Way, Suite 103Chantilly, VA 20151Compressed Gas AssociationPrincipal: Jerrold Sameth

M 8/9/2011

VAF-AAAAndrew GibbonsAlternateUS Coast GuardCommandant (CG-Eng-3)2100 Second Street, SWWashington, DC 20593-7126Principal: Timothy E. Meyers

E 03/07/2013VAF-AAA

James P. LewisAlternateJim Lewis LNG Expertise206 South Masonic StreetBellvillle, TX 77418Principal: Michael W. Mackey

SE 1/1/1995

VAF-AAAJanna E. ShapiroStaff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169-7471

08/04/2015

3

Attachment A:

March 10-12, 2015

Meeting Minutes

of 2

TECHNICAL COMMITTEE ON VEHICULAR ALTERNATIVE FUEL SYSTEMS

Minutes of Meeting – NFPA 52 Second Draft Meeting

March 10th to 12th, 2015

Las Vegas, Nevada

Members Present Alternate Present

Nancy Pehrson – chair Yes

Stephen Abernathy Yes

Ronald Adcock Yes

Jim Ames Yes

Michael Battagllia No

Dan Bowerson Yes

Ronald Cloyd Yes

Denis Ding Yes

Thomas Forsythe No

Alan Hatfield Yes

Tara Henriksen No

Doug Horne By phone John Dimmick Yes

Quon Kwan Yes

J. Roger Lackore Yes

Michael Mackey Yes James Lewis

Paul May By phone

Tim Meyers By phone Andrew Gibbons

Gregory Milewski No

Randy Moses Yes

Knut Nerheim No

Robert Petsinger Yes

Robert Renkes Yes

Jerrold Sameth Yes Richard Craig

Joel Sipe No

Glen Smith Yes

E. Michael Steele No Virginia Sage

Steven Tucky No

Ted Williams No

of 2

Susan Bershad – NFPA Yes

John Jordan – Guest – Agility Fuel Systems

Yes

Mitch Bernstien – Guest Yes

Donna Denny – Guest –Westport Innovations

Yes

Mark Sipe –Guest – Tulsa Fire Marshall

Yes

George Mitchell – Guest‐ NREL

Yes

John Gonzales – Guest ‐ NREL

Yes

Jesse Strickland ‐ Guest By phone

Bob Boyd ‐Guest By phone

Kent Whiting – Guest By phone

Julie Cairns ‐ CSA By phone 1.0 Meeting was called to order at 8:00 AM on March 10th, by Nancy Pehrson, chair. 2.0 Meeting and web conference attendees were self‐introduced and their attendance recorded

(see above for attendance list) 3.0 Minutes from the First Draft meeting were reviewed and approved. 4.0 NFPA staff liaison, Susan Bershad, gave a review of the second draft process, committee

membership and committee composition. 5.0 Bob Petsinger gave a brief report on SAE J1616 6.0 The committee reviewed and acted on 96 public comments received on the first draft,

creating a total of 55 second revisions. 7.0 The committee reviewed the draft of the reorganized and restructured document. The

reorganized document from the first draft meeting was updated to include the first revisions and distributed to the technical committee for review and comment in the fall of 2014. Based on the review at the meeting, several changes were made to the structure of the first draft. Chapter 8, Equipment, was divided into two separate chapter, Facility Equipment and Automotive Equipment. Chapter 11 , Fueling, was divided into CNG Fueling, CNG Residential Fueling, and LNG Fueling.

8.0 The committee feels that additional work needs to be done on the reorganization and restructuring of the document. It was clear that any substantial further reorganization work could not be done at this point without slipping revision cycle. The committee decided to stay on the current revision cycle and request Standards Council to enter into an expedited revision cycle in order to continue the work.

9.0 The next meeting of the committee will be a pre‐first draft meeting. The purpose of this meeting would be to continue work on the reorganization. Staff recommended that this be held in the fall of 2015 at NFPA headquarters in Quincy. If the document remains on a three year cycle, this meeting could be held in the spring of 2016.

Attachment B:

F2018 Revision Cycle

NFPA 52 Revision Cycle KEY DATES

Fall 2018

NFPA 52 F2018 [VAF-AAA]

Important Dates For the Cycle:

Public Input Closing January 5, 2017 (DONE)

Posting of First Draft September 7, 2017

Public Comment Closing November 16, 2017

Posting of Second Draft August 2, 2018

Notice of Intent to Make Motion (NITMAM) August 30, 2018

Issuance of Consent Standard November 5, 2018 (published bit later)

NFPA Annual Meeting with CAMs June 20, 2018

Issuance of Standard – with CAMs August 7, 2019 (published bit later)

Attachment C:

VAF-AAA Committee

Membership

Percentage SummaryVehicular Alternative Fuel SystemsVAF-AAA

Class Voting Number Percent

04/14/2017

E 3 11%

I 1 4%

IM 3 11%

M 9 32%

RT 1 4%

SE 6 21%

U 5 18%

28Total Voting Number

Attachment D:

NFPA Process – Quick

Reference Guide

New Process – Quick Reference Guide For additional information on the Regulations visit: www.nfpa.org/Regs

There are only three actions a TC can take at the First Draft (ROP)

meeting: 1. Resolve a Public Input (no change to the document) 2. Create a First Revision (change to the document) 3. Create Committee Input

Resolve Public Input (no change to the document)

TC must provide a response (Committee Statement/CS) to ALL Public Input (proposal).

CS for not doing what is suggested

Sample Motion: “I make a motion to resolve PI#_ with the following committee statement__.” Approval by meeting vote (simple majority). Not subject to Ballot.

Create a First Revision (change to the document)

TC must create a First Revision (FR) for each change they wish to make to the document, either using Public Input for the basis of the change or not using a Public Input for the basis. One or more Public Input can be considered for the FR.

All Public Input requires a response

TC can use a Public Input for basis i. Sample Motion: “I make a motion to revise section __ using PI#_ as the

basis for change.” Approval by meeting vote (simple majority) and final approval through ballot.

TC develops revision without a Public Input for basis i. Sample Motion: “I make a motion to revise section __ as follows___.”

Approval by meeting vote (simple majority) and final approval through ballot.

First Revisions require a committee statement

Committee Input

TC may create a Committee Input (CI). This replaces the old system “rejected” Committee Proposals. CIs will get printed in the report but will not be balloted or shown as a change in the draft. CIs are used to solicit public comments and/or as a placeholder for the comment stage.

i. Sample Motion: “I make a motion to create a CI with a proposed revision to section__ as follows___.” Approval by meeting vote (simple majority). Not subject to ballot.

Requires a committee statement to explain the intent of making a CI.

http://www.nfpa.org/Regs

Comparison to Previous Process:

PREVIOUS ACTIONS CURRENT PROCESS ACTIONS SAMPLE MOTION

Accept or any variation of Accept

(APA, APR, APP) on a public

proposal

1) Committee generates a First

Revision and Substantiation (CS)

for change

2) Committee provides response (CS)

to each PI that is associated with the

revision

1) “I make a motion to revise section __ using PI#_ as the basis for change.”

2) “ I make a motion to resolve PIs#_ through ## with the following statement__”

Rejected Public Proposal Committee provides response (CS)

to PI

“I make a motion to resolve

PI#_ with the following

committee statement__.”

Accepted Committee Proposal Committee generates a First Revision

and Substantiation (CS) for change

“I make a motion to revise

section __ as follows___.”

Committee generates a

statement for reason for change.

Rejected Committee Proposal Committee generates a Committee

Input (CI) and reason (CS) for

proposed change

“I make a motion to create a CI

with a proposed revision to

section__ as follows___.”

Committee generates a

statement for reason for CI.

Notes:

1) All meeting actions require a favorable vote of a simple majority of the members present. 2) All First Revisions will be contained in the ballot and will require a 2/3 affirmative vote to

confirm the meeting action. 3) Only the First Revisions will be balloted. PIs and CIs will be contained in the report but will

not be balloted. 4) Comments may be submitted on all PIs, FRs and CIs

Term Comparison between Current and Old:

CURRENT TERM OLD TERM

Input Stage ROP Stage

Public Input (PI) Proposal

First Draft Meeting ROP Meeting

Committee Input Committee Proposal that Fail

Ballot

Committee Statement

(CS) Committee Statement

First Revision (FR) Committee Proposal or Accepted

Public Proposal

First Draft Report ROP

First Draft ROP Draft

Comment Stage ROC Stage

Public Comment Public Comment

Second Draft Meeting ROC Meeting

Committee Comment Committee Comment that Fail

Ballot

Committee Action Committee Action

Second Revision Committee Comment or Accepted

Public Comment

Second Draft Report ROC

Second Draft ROC Draft

Note: The highlighted terms are the ones that will be most applicable at the First Draft Meeting.

Attachment E:

NFPA 52 – F2018 Public

Input

Public Input No. 150-NFPA 52-2016 [ Global Input ]

Upon review of the current revision of the NFPA 52 standard, BNSF Railway would like toprovide comment and request clarification on the applicability of certain sections andparagraphs of this standard to the refueling of LNG fuel tenders supporting railwaylocomotives. We would respectfully request to be in included in future discussionsaround the revisions of this standard and are in the process of applying for a position onthe NFPA 52 committee under the category of "User".

Statement of Problem and Substantiation for Public Input

Upon review of the current revision of the NFPA 52 standard, BNSF Railway would like to provide comment and request clarification on the applicability of certain sections and paragraphs of this standard to the refueling of LNG fuel tenders supporting railway locomotives. We would respectfully request to be in included in future discussions around the revisions of this standard and are in the process of applying for a position on the NFPA 52 committee under the category of "User".

Submitter Information Verification

Submitter Full Name: Joshua Soles

Organization: BNSF Railway

Street Address:

City:

State:

Zip:

Submittal Date: Thu Dec 22 14:34:24 EST 2016

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

1 of 273 4/18/2017 11:12 AM


Ceate a separate chapter for a CNG vehicle (all CNG components) and anotherfor an LNG vehicle (which includes both the CNG fuel system and LNG fuelsystem requirements).


NFPA 52 historically has relied on the CNG fuel system chapters, that were written for a CNG vehicle, to apply also to the CNG portion of an LNG vehicle. However, the wording doesn’t generally work for the LNG vehicle which is designed and operates quite differently than a CNG vehicle. It also does not always address components for vented gas (LNG vapor). The wording especially doesn’t work for Westport HDPI vehicles that pressurize LNG via an LNG pump then vaporize and pass high CNG pressures into the engine. Westport has attempted to propose through public comment new wording for all pressurized CNG component requirements to suit also an LNG vehicle, however it is difficult and cumbersome . Alternatively, Westport proposes that a more eloquent, efficient and perhaps accurate solution is to create a separate chapter for a CNG vehicle (all CNG components) and another for an LNG vehicle (which includes both the CNG fuel system and LNG fuel system requirements). That way the requirements can be more specifically tuned to the application.


Submitter Full Name: Donna Denny

Organization: Westport Innovations Inc.

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Submittal Date: Wed Jan 04 16:42:16 EST 2017



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Search the code for “pressure relief device” and “PRD” and ensure that it is consistentlyused.


The text as written out is not consistently used: • The definition of a “pressure relief device” in section 3 Definitions clearly identifies it as being different and separate from a “pressure relief valve”. • The text as used in various places in the document indicates any type of “fitting or component that relieves pressure” – ie to include both a PRD and a PRV.

Committee should choose and then be consistent throughout the document.

Note that this inconsistency likely rises from the fact that the NFPA 52-2013 definition of a PRD included all types (reclosing, burst disk, etc.) but NFPA 52-2016 definitions broke this into a separate definition for a PRD (one time, vents container contents) and for a PRV (reclosing).




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3 of 273 4/18/2017 11:12 AM


Update terminology throughout the code for the fuel tank to “Fuel SupplyContainer”


Inconsistent use of terminology for the fuel tank is used throughout the document.• CNG vehicle: is referred to as “Fuel Supply Container”• LNG vehicle: is referred to as “Vehicle Fuel Container”.

Per definition.3.3.10.4 Fuel Supply Container. A container mounted on a vehicle to store LNG or CNG as the fuel supply to the vehicle.

Examples noted:14.3.2.1 (1) – uses “Vehicle fuel containers” even though the clause pertains to both CNG and LNG fuel systems.14.5.3.8 – uses “Vehicular Fuel Container Pressure Gauges”14.5.3 – uses “Vehicular Fuel Containers”15.4.4 uses “Vehicular Fuel Containers”




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Add injector requirements to the code


Currently injectors do not have specific requirements in the code. Past correspondence between Westport and the NFPA 52 committee have confirmed that until this gap is filled the injector should be analyzed as an “automatic valve” which is not accurate. If the committee agrees to include specific injector requirements Westport offers to create a first draft for circulation to the members for comments and revisions.




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1 . Revise 11.3.2.13.9 to read as follows:

11.3.2.13.9* During the transfer of CNG to or from CNG bulk transport vehicles, thehand or emergency brake of the vehicle shall be set and chock blocks used to preventrolling of the vehicle.

11.3.2.13.9.1 Personnel filling CNG bulk transport cylinders or vehicles shall beinstructed and trained in accordance with

DOT hazardous materials regulations.

2. Revise 13.3.2.19.2 (G) and (H) to read as follows:

(G) Where containers in the dike area are constructed or protected to prevent failurefrom spilled LNG and fire in the dike, the minimum holding of the dike shall be thevolume of the largest container in the dike [59A: 13.8.3(1)].

(H) Where containers in the dike area are not constructed or protected to preventfailure from spilled LNG and fire in the dike, the minimum holding of the dike shall beequal to the total volume of the containers in the dike area. [59A: 13.8.2(3)].

Additional Proposed Changes

File Name Description Approved

TIA_52_16_2.pdf NFPA TIA 16-2 Log No. 1205


Note: This public Input originates from Tentative Interim Amendment No. 16-2 Log 1205 issued by the Standards Council on April 6, 2016 and per the NFPA Regs., needs to be reconsidered by the Technical Committee for the next edition of the Document.

Substantiation.Item 1. This change is needed to clarify the intent of the clause. This requirement is only applicable to vehicles or cylinders used in the bulk transport of natural gas. Other types of cargo vehicles may utilize natural gas as a fuel source in their operation, and filling these types of vehicles does not require DOT Hazardous Materials Training.Item 2. These changes are necessary to provide consistency with NFPA 59A regarding the requirementsfor the holding capacity of the dike. The language is extracted from NFPA 59A.

Emergency Nature. During the second draft stage, the reorganization of NFPA 52 resulted in errors in a number of second revisions. Some of the revisions that were voted on during the second draft meeting were not carried over during the editorial process, and therefore the revisions that were balloted were not the same as what the committee had actually voted on. The proposed text corrects this error by including the language the committee agreed upon as a second revision.



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Submitter Full Name: TC On VAF-AAA

Organization: NFPA TC on Vehicular Gaseous Fuel Systems Code

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Submittal Date: Thu Aug 11 09:46:52 EDT 2016



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Chapter 11 Reserved

Reserved

(See Attached Public Comment No. 64)



Public_Comment_64_-_Hold.pdf NFPA 64_PC#64


Note: This Public Input appeared as "Reject but Hold" in Public Comment No. 64 of the F2015 Second Draft Report for NFPA 52 and per the Regs. at 4.4.8.3.1.

Re: Section 11.X.2 – Marine Vessel Transfer reference to NFPA 30A (from draft reorganization text submitted underPublic Input No. 111-NFPA 52-2013 [ Chapter 11 ]):

Sections under 11.X.2 (Marine Vessel Transfer) referencing NFPA 30A for Marine Service Stations, Fueling Systems, storage tanks should be more specific with regard to the sections of NFPA 30A that apply and consideration should be given to establishing a section for LNG fueling facilities supplying LNG to commercial vessels.

NFPA 30A states that the code does not apply to motor fuel dispensing facilities where only liquefied petroleum gas (LP-Gas), liquefied natural gas (LNG), or compressed natural gas (CNG) is dispensed as motor fuel. Additionally, in discussing storage of liquids, the volumes permitted appear to be vastly different than what is allowed in NFPA 52. Also, the marine fueling section in NFPA 30A (Chapter 11) is limited to vessels 300GT and less. In this context, it may be necessary to distinguish between facilities intended to fuel commercial vessels (without a tonnage limitation), and non-commercial vessels. LNG facilities intended to supply commercial vessels should align more with NFPA 59A whereas non-commercial marine fueling facilities should align with NFPA 30A


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Public Comment No. 64-NFPA 52-2014 [ Chapter 11 ]

Chapter 11 Reserved

Reserved

Statement of Problem and Substantiation for Public Comment

Re: Section 11.X.2 – Marine Vessel Transfer reference to NFPA 30A (from draft reorganization text submitted under Public Input No. 111-NFPA 52-2013 [ Chapter 11 ]):

Sections under 11.X.2 (Marine Vessel Transfer) referencing NFPA 30A for Marine Service Stations, Fueling Systems, storage tanks should be more specific with regard to the sections of NFPA 30A that apply and consideration should be given to establishing a section for LNG fueling facilities supplying LNG to commercial vessels.

NFPA 30A states that the code does not apply to motor fuel dispensing facilities where only liquefied petroleum gas (LP-Gas), liquefied natural gas (LNG), or compressed natural gas (CNG) is dispensed as motor fuel. Additionally, in discussing storage of liquids, the volumes permitted appear to be vastly different than what is allowed in NFPA 52. Also, the marine fueling section in NFPA 30A (Chapter 11) is limited to vessels 300GT and less. In this context, it may be necessary to distinguish between facilities intended to fuel commercial vessels (without a tonnage limitation), and non-commercial vessels. LNG facilities intended to supply commercial vessels should align more with NFPA 59A whereas non-commercial marine fueling facilities should align with NFPA 30A.

Related Item

Public Input No. 111-NFPA 52-2013 [Chapter 11]


Submitter Full Name: Timothy Meyers

Organization: US Coast Guard

Street Address:

City:

State:

Zip:

Submittal Date: Thu Nov 13 18:12:55 EST 2014

Committee Statement

CommitteeAction:

Rejected but held

Resolution: This is new material that will be held until the next cycle. Note that the marine sections are beingproposed to be reserved until the next revision cycle pending harmonization with new internationalstandards that are being developed for ships using gases and other low-flashpoint fuels.

Copyright Assignment

I, Timothy Meyers, 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 I acquireno rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyrightassignment.

By checking this box I affirm that I am Timothy Meyers, 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

National Fire Protection Association Report http://submittalsarchive.nfpa.org/TerraViewWeb/FormLaunch?id=/Terra...

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jdepew

Sticky Note

attachment to PI 29


8.1.3.2 Storage within RFA's Shall be in accordance with DSA NGV 5.1.

(See Attached Public Comment)






Original Rationale:This proposal is part of a series of proposals which will harmonize NFPA 52 with the new NGV 5.1 standard for residential fueling appliances.

Gas containment needed in the performance of a technology should be allowed as long as it can be safely integrated into a listed RFA and located properly at a residential occupancy. Section 7.5 of NFPA 52 already provides guidance on the safe installation of containers. Based on the language in 8.2.3, Section 7.5 already applies to an RFA and should be able to be complied with in an RFA design.

An RFA incorporating containers with the potential to store enough gas to reach a certain % of LFL limits in a small garage space should not be allowed indoors, however this should not prevent the compression and/or dispensing components from separately being located indoors, provided safeguards can be put in place to prevent theinadvertent transfer of sufficiently large amounts of gas from the outdoor containers to the indoors and reach a certain% of LFL limits.

CSA 5.1 seed document states “The volume of gas contained by the RFA package shall not exceed 0.254 m3 (9 ft3)at standard conditions of 101.3 kPa at 15 ºC (30 in Hg and 60ºF).”

The NGV 5.1 technical subcommittee is proposing to limit the potential amount of gas that could be released into the atmosphere in the event of a catastrophic failure. 0.254/30 cubic meters (small garage size)=0.8% which is less than1%. 1% is 25% of LFL for natural gas. Storage of natural gas integral to the RFA falls within the jurisdiction of NGV5.1. If storage is external to the RFA, then it is outside the NGV 5.1 scope of the listing documents and coverage would fall back to NFPA.

Additional comment:Approve as submitted. NGV 5.1 has reviewed all comments received as a result of industry / public review. The document will be submitted to the Technical committee for approval during November 2014. The standard will be published during December 2014/January 2015. Specific details of storage is contained in NGV 5.1 are shown below.



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Gas Retention Limits for all RFAs: Indoor Mounted Unit Limits:The volume of gas contained by the RFA package for indoor installation shall not exceed 0.254 m3 (9 ft3) at standard conditions of 101.3 kPa at 15 ºC (30 in Hg and 60ºF).

Outdoor Storage Limits:The RFA package for outdoor installation may contain a volume of gas not exceed a total storage of 0.073 m3 (2.6 ft3) water volume. This will translate to approximately 6 GGE at 3600 psi. A single storage container shall not exceed 0.042 m3 (1.5 ft.3) water volume.These limits will apply unless substantiated by the manufacture through appropriate safety hazard analysis (i.e.: FMEA).and6.17 GAS CONTAINMENT6.16 GAS CONTAINMENT6.16.1Blowdown system — an integral component system of the RFA designed to reduce the delivery side pressure (up to and including the fuelling probe and the space between the vehicle receptacle and check valve) from operating level to 517 kPa (75 psig) or less at the end of every fuelling cycle.Note: This allows for safe and easy disconnection of the refuelling hose from the vehicle by the RFA user. The system may also depressurize the compressor to allow easier starting. The system includes means to contain the expanded volume of high pressure gas necessary to achieve the pressure reduction.6.16.2

Gas containment system – a volume integral to the RFA to hold gas during the compression and/or delivery functions of the RFA.

6.16.3The volume of gas contained by the RFA package for indoor installation shall not exceed 0.254 m3 (9 ft3) at standard conditions of 101.3 kPa at 15 ºC (30 in Hg and 60ºF).

6.16.4The volume of gas stored by the VFA for outdoor use can contain no more than a cumulative 750 scf (approximately 6GGE) of gas, unless the manufacturer can provide the technical justification that a larger volume can safely be contained, and shall not contain gas at pressure above the VFA’s outlet service pressure

6.16.5RFAs that have gas storage systems, shall have no single container, with capacity more than 42.5 liters (1.5 cubic ft)water volume.

6.16.6Any container that has a capacity greater than 42.5 L (1.5 ft3) and a pressure greater than 103 kPa (15 psig) shall comply with the requirements of ASME Boiler and Pressure Vessle Code Section VIII,( CSA B51).

6.16.7Cylinders used in an RFA shall comply, by design with one of the following, as applicable:

a) U.S. Department of Transportation (DOT) or Transport Canada (TC) regulations, exemptions, or



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c) U.S. Federal Motor Vehicle Safety Standard, 49 CFR, 571.304, Compressed Natural Gas Fuel ContainerIntegrity.Inspection requirements for any cylinder shall be per the applicable cylinder design standard.6.16.8DOT, TC, and ANSI/IAS NGV2 cylinders shall not be subjected to pressure in excess of 125 percent of the marked service pressure even if, on cooling, the pressure settles to the marked service pressure.

6.16.9Fuel containers within the RFA shall not have a settled pressure above the service pressure that is stamped on the container and displayed on a label near the filling connection, corrected for the ambient temperature at the time of filling.

6.16.10A RFA with gas storage for outdoor use only shall employ:

a) Separate automatically operated normally closed valves for each container that will isolate the contained gas if the emergency shutdown system is engaged or power is lost

b) A manually operated container valve shall be provided for each DOT, ASME or TC storage cylinder.

c) Thermal induced pressure relief protection at a temperature greater than 200 degrees F or a pressure no greater than 30% less than the component’s burst pressure

d) Pressure vessels operating at their service pressure shall have a thermal pressure release device or pressure relief valve set to no greater than 125% service pressure

e) A resettable overpressure protection device shall be installed in the fuel delivery system to prevent over pressurization of the vehicle.

6.16.11During outdoor fueling operations, the point of transfer which is the point where the fueling connection is made:

a) Shall have a hose length such that the fill nozzle can be at least 6 ft (2 m) from any important building, mobile home, public sidewalk, highway, street, or road

b) Shall have a hose length such that the fill nozzle can be at least 3 ft (1 m) from the RFA.

c) The Installation Instructions shall make mention of the above requirements

6.16.12Outdoor mounted units:a) Shall be installed above groundb) Shall be firmly affixed so as to prevent movementc) Shall not be below electric power lines or exposed by their failured) Shall be a minimum of 1ft away from adjoining flammable structure if there is a 2 hr fire wall



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e) The 2 hr fire wall can be an integrated part of the RFAf) In the absence of a 2 hour fire wall the unit shall be no less than three feet away from adjoining structure g) Shall be a minimum of 3 ft. from adjoining property that can be built upon, or from any source of ignition h) Shall be not less than 10 ft (3.0 m) from the nearest public street or sidewalk linei) Shall be at least 50 ft (15 m) from the nearest rail of any railroad main track.j) Shall have a clear space of at least 3 ft (1 m) provided for maintenance accessk) Shall be protected from potential impact from moving vehicles by installing at minimum 3” diameter, 3ft deep baluster(s) along the side of the RFA which could be impactedl) Shall have the following safety placards:m) Outside of RFA - Turn off the vehicle engine while fuelingn) The inside of access doors - “WARNING — NO SMOKING — FLAMMABLE GAS.”

6.16.12The RFA shall be provided with passive means, active means, or a combination thereof, to dilute an abnormal internal releases of gas below 25% of the LFL

a) For indoor mounted RFA, the gas shall be routed outdoors

b) For outdoor mounted RFA, the gas shall be routed up and away from the VFA and as reasonable from normally trafficked areas.

c) The validation of the ability to maintain below 25% of the LFL may be demonstrated by computational fluid dynamic analysis, tracer gas demonstration, similar methods, or the demonstration of employing other mitigation strategies.

6.16.13The RFV shall be able to detect via direct measurement or predictive analysis the potential for abrupt severing of the vehicle supply hose or downstream line*

If this condition is so detected then the RFV shall close the Vehicle Fill valve, RFV’s Source Supply valve and anyRFV internal electrically operated isolation valves

NOTE: *This mitigation technique is in addition to engagement of the break-away devise.

6.16.14At minimum, with the detection of gas leakage, mitigation strategies need to:

a) Initiate a passive means to dilute the gas concentrationb) Close the Source Supply valve to preclude the introduction of additional gasc) Close any container gas Supply Valve for isolation of contained gas greater than 9 cu ft. at standard conditions d) Close the RFV Vehicle Fill Valve to isolate the vehicle fuel hose from the RFVe) The RFV will indicate the reason for the shut-down f) Manual reset will be required by the userg) If the RFV detects gas again within the span of 72 hours the unit shall:1) Implement the exhaust fan high flow setting2) Alert the user3) Close all valves4) RFV shall automatically remove power to all circuits other than the exhaust fan5) Require service personnel to reset



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For outdoor mounted RFV with contained gas, a fire detection methodology must be employed a)Detection of fire shall cause the RFV, at a minimum, to:1) Close all valves to isolate the RFV from the supply source, and vehicle2) Close all internal electrically operated valves to isolate sub-systems3) Give RFV external indication that the unit has detected a fire.

6.16.16For outdoor mounted RFV, there shall be no greater than 6 GGE of gas contained while the RFV is in dormant or operational mode

a) There shall be no greater than 3 GGE per single containerb) All individual containment systems shall employ isolation valves for:

1) System non-operational dormant modes2) Emergency isolation operations3) Manually operated isolation valve for maintenance purposes

c) All containers shall have the means of releasing gas as due to a rise in temperature from an external fire source, via the use of a thermal pressure release device

6.16.17Electrical bonding shall require:a) The RFV be grounded per b) Outdoor mounted RFV will additionally require grounding via



Organization: NFPA

Street Address:

City:

State:

Zip:




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Public Comment No. 81-NFPA 52-2014 [ New Section after 8.1.3 ]

8.1.3.2 Storage within RFA’s shall be in accordance with CSA NGV 5.1.


Original Rationale:This proposal is part of a series of proposals which will harmonize NFPA 52 with the new NGV 5.1 standard for residential fueling appliances.

Gas containment needed in the performance of a technology should be allowed as long as it can be safely integrated into a listed RFA and located properly at a residential occupancy. Section 7.5 of NFPA 52 already provides guidance on the safe installation of containers. Based on the language in 8.2.3, Section 7.5 already applies to an RFA and should be able to be complied with in an RFA design.

An RFA incorporating containers with the potential to store enough gas to reach a certain % of LFL limits in a small garage space should not be allowed indoors, however this should not prevent the compression and/or dispensing components from separately being located indoors, provided safeguards can be put in place to prevent the inadvertent transfer of sufficiently large amounts of gas from the outdoor containers to the indoors and reach a certain % of LFL limits.

CSA 5.1 seed document states “The volume of gas contained by the RFA package shall not exceed 0.254 m3 (9 ft3) at standard conditions of 101.3 kPa at 15 ºC (30 in Hg and 60ºF).”

The NGV 5.1 technical subcommittee is proposing to limit the potential amount of gas that could be released into the atmosphere in the event of a catastrophic failure. 0.254/30 cubic meters (small garage size)=0.8% which is less than 1%. 1% is 25% of LFL for natural gas. Storage of natural gas integral to the RFA falls within the jurisdiction of NGV 5.1. If storage is external to the RFA, then it is outside the NGV 5.1 scope of the listing documents and coverage would fall back to NFPA.

Additional comment:Approve as submitted. NGV 5.1 has reviewed all comments received as a result of industry / public review. The document will be submitted to the Technical committee for approval during November 2014. The standard will be published during December 2014/January 2015. Specific details of storage is contained in NGV 5.1 are shown below.

4.10Gas Retention Limits for all RFAs:Indoor Mounted Unit Limits:The volume of gas contained by the RFA package for indoor installation shall not exceed 0.254 m3 (9 ft3) at standard conditions of 101.3 kPa at 15 ºC (30 in Hg and 60ºF).

Outdoor Storage Limits:The RFA package for outdoor installation may contain a volume of gas not exceed a total storage of 0.073 m3 (2.6 ft3) water volume. This will translate to approximately 6 GGE at 3600 psi. A single storage container shall not exceed 0.042 m3 (1.5 ft.3) water volume. These limits will apply unless substantiated by the manufacture through appropriate safety hazard analysis (i.e.: FMEA). and6.17 GAS CONTAINMENT6.16 GAS CONTAINMENT6.16.1 Blowdown system — an integral component system of the RFA designed to reduce the delivery side pressure (up to and including the fuelling probe and the space between the vehicle receptacle and check valve) from operating level to 517 kPa (75 psig) or less at the end of every fuelling cycle.Note: This allows for safe and easy disconnection of the refuelling hose from the vehicle by the RFA user. The system may also depressurize the compressor to allow easier starting. The system includes means to contain the expanded volume of high pressure gas necessary to achieve the pressure reduction.6.16.2

National Fire Protection Association Report http://submittalsarchive.nfpa.org/TerraViewWeb/ContentFetcher?comme...

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jdepew

Sticky Note

attachment to PI 30

Gas containment system – a volume integral to the RFA to hold gas during the compression and/or delivery functions of the RFA.

6.16.3 The volume of gas contained by the RFA package for indoor installation shall not exceed 0.254 m3 (9 ft3) at standard conditions of 101.3 kPa at 15 ºC (30 in Hg and 60ºF).

6.16.4The volume of gas stored by the VFA for outdoor use can contain no more than a cumulative 750 scf (approximately 6 GGE) of gas, unless the manufacturer can provide the technical justification that a larger volume can safely be contained, and shall not contain gas at pressure above the VFA’s outlet service pressure

6.16.5RFAs that have gas storage systems, shall have no single container, with capacity more than 42.5 liters (1.5 cubic ft) water volume.

6.16.6Any container that has a capacity greater than 42.5 L (1.5 ft3) and a pressure greater than 103 kPa (15 psig) shall comply with the requirements of ASME Boiler and Pressure Vessle Code Section VIII,( CSA B51).

6.16.7Cylinders used in an RFA shall comply, by design with one of the following, as applicable:

a) U.S. Department of Transportation (DOT) or Transport Canada (TC) regulations, exemptions, or special permits, b) ANSI NGV2, Compressed Natural Gas Vehicle (NGV) Fuel Containers, specifically for CNG service, orc) U.S. Federal Motor Vehicle Safety Standard, 49 CFR, 571.304, Compressed Natural Gas Fuel Container Integrity.Inspection requirements for any cylinder shall be per the applicable cylinder design standard.6.16.8 DOT, TC, and ANSI/IAS NGV2 cylinders shall not be subjected to pressure in excess of 125 percent of the marked service pressure even if, on cooling, the pressure settles to the marked service pressure.

6.16.9Fuel containers within the RFA shall not have a settled pressure above the service pressure that is stamped on the container and displayed on a label near the filling connection, corrected for the ambient temperature at the time of filling.

6.16.10A RFA with gas storage for outdoor use only shall employ:

a) Separate automatically operated normally closed valves for each container that will isolate the contained gas if the emergency shutdown system is engaged or power is lost

b) A manually operated container valve shall be provided for each DOT, ASME or TC storage cylinder.

c) Thermal induced pressure relief protection at a temperature greater than 200 degrees F or a pressure no greater than 30% less than the component’s burst pressure

d) Pressure vessels operating at their service pressure shall have a thermal pressure release device or pressure relief valve set to no greater than 125% service pressure

e) A resettable overpressure protection device shall be installed in the fuel delivery system to prevent over pressurization of the vehicle.

6.16.11During outdoor fueling operations, the point of transfer which is the point where the fueling connection is made:

a) Shall have a hose length such that the fill nozzle can be at least 6 ft (2 m) from any important building, mobile home, public sidewalk, highway, street, or road

b) Shall have a hose length such that the fill nozzle can be at least 3 ft (1 m) from the RFA.


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c) The Installation Instructions shall make mention of the above requirements

6.16.12Outdoor mounted units:a) Shall be installed above groundb) Shall be firmly affixed so as to prevent movementc) Shall not be below electric power lines or exposed by their failured) Shall be a minimum of 1ft away from adjoining flammable structure if there is a 2 hr fire wall between the RFA and adjoining structuree) The 2 hr fire wall can be an integrated part of the RFAf) In the absence of a 2 hour fire wall the unit shall be no less than three feet away from adjoining structureg) Shall be a minimum of 3 ft. from adjoining property that can be built upon, or from any source of ignitionh) Shall be not less than 10 ft (3.0 m) from the nearest public street or sidewalk linei) Shall be at least 50 ft (15 m) from the nearest rail of any railroad main track.j) Shall have a clear space of at least 3 ft (1 m) provided for maintenance accessk) Shall be protected from potential impact from moving vehicles by installing at minimum 3” diameter, 3ft deep baluster(s) along the side of the RFA which could be impactedl) Shall have the following safety placards:m) Outside of RFA - Turn off the vehicle engine while fueling n) The inside of access doors - “WARNING — NO SMOKING — FLAMMABLE GAS.”

6.16.12The RFA shall be provided with passive means, active means, or a combination thereof, to dilute an abnormal internal releases of gas below 25% of the LFL

a) For indoor mounted RFA, the gas shall be routed outdoors

b) For outdoor mounted RFA, the gas shall be routed up and away from the VFA and as reasonable from normally trafficked areas.

c) The validation of the ability to maintain below 25% of the LFL may be demonstrated by computational fluid dynamic analysis, tracer gas demonstration, similar methods, or the demonstration of employing other mitigation strategies.

6.16.13The RFV shall be able to detect via direct measurement or predictive analysis the potential for abrupt severing of the vehicle supply hose or downstream line*

If this condition is so detected then the RFV shall close the Vehicle Fill valve, RFV’s Source Supply valve and any RFV internal electrically operated isolation valves

NOTE: *This mitigation technique is in addition to engagement of the break-away devise.

6.16.14At minimum, with the detection of gas leakage, mitigation strategies need to:

a) Initiate a passive means to dilute the gas concentrationb) Close the Source Supply valve to preclude the introduction of additional gasc) Close any container gas Supply Valve for isolation of contained gas greater than 9 cu ft. at standard conditionsd) Close the RFV Vehicle Fill Valve to isolate the vehicle fuel hose from the RFVe) The RFV will indicate the reason for the shut-downf) Manual reset will be required by the userg) If the RFV detects gas again within the span of 72 hours the unit shall:1) Implement the exhaust fan high flow setting 2) Alert the user3) Close all valves4) RFV shall automatically remove power to all circuits other than the exhaust fan5) Require service personnel to reset


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6.16.15For outdoor mounted RFV with contained gas, a fire detection methodology must be employed

a) Detection of fire shall cause the RFV, at a minimum, to:

1) Close all valves to isolate the RFV from the supply source, and vehicle2) Close all internal electrically operated valves to isolate sub-systems3) Give RFV external indication that the unit has detected a fire.

6.16.16For outdoor mounted RFV, there shall be no greater than 6 GGE of gas contained while the RFV is in dormant or operational mode

a) There shall be no greater than 3 GGE per single containerb) All individual containment systems shall employ isolation valves for:

1) System non-operational dormant modes2) Emergency isolation operations3) Manually operated isolation valve for maintenance purposes

c) All containers shall have the means of releasing gas as due to a rise in temperature from an external fire source, via the use of a thermal pressure release device

6.16.17Electrical bonding shall require:a) The RFV be grounded per ________b) Outdoor mounted RFV will additionally require grounding via_____

Related Item

Public Input No. 71-NFPA 52-2013 [New Section after 8.1.3]


Submitter Full Name: JULIE CAIRNS

Organization: CSA GROUP

Affilliation: On behalf of CSA Group NGV 5.1 Technical Subcommittee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 14 13:10:41 EST 2014

Committee Statement

CommitteeAction:

Rejected but held

Resolution: The committee is holding this until the next revision cycle. NGV 5.1 is does not contain sufficientguidance on decommissioning of residential systems.


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Public Input No. 169-NFPA 52-2017 [ Section No. 1.1.1 ]

1.1.1

This code shall apply to the design, installation, operation, and maintenance of compressednatural gas (CNG) and liquefied natural gas (LNG) engine fuel systems on vehicles of all typesand for fueling vehicle (dispensing) systems and facilities and associated storage, including thefollowing:

(1) Original equipment manufacturers (OEMs)

(2) Final-stage vehicle integrator/manufacturer (FSVIM)

(3) Vehicle fueling (dispensing) systems

This code shall apply to LNG and CNG facilities with LNG storage in ASME containers of 70,000gal (265 m3) or less


This clause and 1.1.2 are nearly identical. The only difference is indicated in the new text, which is text pulled from 1.1.2.

1.1.2 can now be deleted

(see submitted comments for 1.1.2)




Street Address:

City:

State:

Zip:




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1.1.2

This code shall apply to the design, installation, operation, and maintenance of liquefied naturalgas (LNG) engine fuel systems on vehicles of all types, to their associated fueling (dispensing)facilities, and to LNG to CNG facilities with LNG storage in ASME containers of 70,000 gal

(265 m 3 ) or less.

Delete all


This clause and 1.1.1 are nearly identical. The slight difference was added to 1.1.1 (see comments for 1.1.1). Therefore this clause can now be deleted.




Street Address:

City:

State:

Zip:




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1.1.3

This code shall not apply to those aspects of vehicles and fuel supply containers that arecovered by federal motor vehicle safety standards (FMVSSs).

Delete entire clause or at least discuss best way to modify "those aspects...covered by"since this is not clear language.



CCR_and_Texas_Regulations.pdfCalifornia and Texas Regulations requiring NFPA 52 compliance


“those aspects covered by” is not clear language.

NFPA 52 cannot dictate what the legal authorities require. There are regulations that require compliance to NFPA 52 (Texas and California) – see attachment - and this clause creates a circular reference which blocks those applications from full compliance.




Street Address:

City:

State:

Zip:




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California Code of Regulations: 13 CCR § 930 Scope This article applies to liquefied petroleum gas and compressed or liquefied natural gas systems approved by the Air Resources Board for propulsion of motor vehicles with a gross vehicle weight rating of 6,000 pounds or less manufactured after January 1, 1966, and all vehicles regardless of gross vehicle weight rating manufactured after January 1, 1969. This article does not apply to any motor vehicle with a diesel engine that has been converted to the use of gaseous fuel before January 1, 1973. 1. CNG: 13 CCR § 934.1

Fuel Systems using compressed natural gas (CNG) and installed after April 1, 1994, shall comply with the National Fire Protection Association (NFPA) Standard 52 (NFPA 52) “Compressed Natural Gas Vehicular Fuel Systems Code,” or NFPA 52 “Vehicular Fuel Systems Code,” in effect at the time of installation

2. LNG : 13 CCR §935 (a) (1) All liquefied natural gas (LNG) fuel systems installed after January 1, 2000, shall comply with [NFPA 52]… Texas Regulation: Texas has written their own requirements. The OEM does not need to follow them if they comply with NFPA 52 and FMVSS.

1. CNG:

2. LNG:

//

Public Input No. 36-NFPA 52-2016 [ Section No. 1.4 [Excluding any

Sub-Sections] ]

Advancements Special site conditions, advancements in technology and improvements insystem design and equipment shall be permitted to result in equipment fabrication methods,component design requirements, and installation and operating practices that differ from thosespecified in this code.


Allow qualified persons and professional engineers to present alternate safety design approach that is more appropriate for the location due to special site conditions.


Submitter Full Name: Denis Ding

Organization: Clean Energy Fuels Corporation

Street Address:

City:

State:

Zip:

Submittal Date: Wed Oct 26 12:51:16 EDT 2016



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1.4.2

Such deviations shall be permitted where if an investigation of all factors is available for reviewby the authority having jurisdiction has seen evidence that a special investigation of all factorshas been made and . The conclusion of this investigation must be that , based on soundexperience and engineering judgment, has concluded that the proposed deviations meet theintent of this code.


The responsibility of the designer/manufacturer is to complete the investigation and provide evidence that the deviations meet the code. They are not responsible for the actions of the authorities and cannot dictate that the authorities see it.




Street Address:

City:

State:

Zip:




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2.3.4 ASTM Publications.

ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA19428-2959.

ASTM A47/A47M, Standard Specification for Ferritic Malleable Iron Castings, 1999 ( 2014) .

ASTM A395/A395M, Standard Specification for Ferritic Ductile Iron Pressure-RetainingCastings for Use at Elevated Temperatures, 1999 ( 2014) .

ASTM A536, Standard Specification for Ductile Iron Castings, 1984 ( 2014) .

ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials,2014 2016 .

ASTM E136, Standard Test Method for Behavior of Materials in a Vertical Tube at 750°C,2012 2016a .

ASTM E2652, Standard Test Method for Behavior of Materials in a Tube Furnace with aCone-shaped Airflow Stabilizer, at 750°C, 2012 2016 .


date updates


Submitter Full Name: Marcelo Hirschler

Organization: GBH International

Street Address:

City:

State:

Zip:




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2.3.6 CSA Group Publications.

CSA Group, 8501 East Pleasant Valley Road, Cleveland, OH 44131.

CSA EXP 2.1, Best practice for defueling, decommissioning, and disposal of compressednatural gas vehicle fuel containers, 2016

ANSI/CSA NGV 1, Standard for Compressed Natural Gas Vehicle (NGV) Fueling ConnectionDevices, 2006 (reaffirmed 2012).

ANSI NGV 2, Compressed Natural Gas Vehicle (NGV) Fuel Containers, 2007 2016 .

ANSI NGV 3.1/CSA 12.3, Fuel System Components for Compressed Natural Gas PoweredVehicles, 2014.

ANSI/IAS NGV 4.4/CSA 12.54, Breakaway Devices for Natural Gas Dispensing Hoses andSystems, 1999 (reaffirmed 2009).

ANSI/CSA NGV 5.1, Residential fueling appliances, 2016

CSA/ANSI NGV 5.2/12.6, Vehicle fueling appliances, 2017

CSA NGV 6.1, Compressed Natural Gas (CNG) fuel storage and delivery systems for roadvehicles

ANSI/CSA PRD 1, Pressure Relief Devices for Natural Gas Vehicle (NGV) Fuel Containers,2013.

CSA 12.54, Breakaway Devices for Dispensing Systems, 1999 (reaffirmed 2009).


Update section for proposed and existing references to CSA documents


Submitter FullName:

Julie Cairns

Organization: CSA Group

Affilliation:

CSA Group NGV 6.1 Compressed Natural Gas (CNG) FuelSystems Technical Subcommittee, B109 Natural Gas forVehicles Installation Code Technical Subcommittee and the CSAGroup NGV 5.2 Compressed Natural Gas (CNG) VehicleFueling Appliances Technical Subcommittee

StreetAddress:

City:

State:

Zip:



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2.3.11 UL Publications.

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

ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Building Materials,2010 2008, revised 2013 .

ANSI/UL 969, Standard for Marking and Labeling Systems, 2014.


Updating correct reference dates.


Submitter Full Name: Kelly Nicolello

Organization: UL LLC

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Submittal Date: Tue Jan 03 10:38:56 EST 2017



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Public Input No. 194-NFPA 52-2017 [ New Section after 2.4 ]

Chapter 3 General

3.1 ASME Compliance.

3.1.1 Pressure vessels shall be manufactured, inspected, marked, and tested in accordancewith ASME Boiler and Pressure Vessel Code, Section VIII or Section X.

3.1.2 Adherence to applicable ASME Boiler and Pressure Vessel Code case interpretationsand addenda shall be considered as compliant with the ASME Boiler and Pressure VesselCode.

3.1.3 Pressure vessels manufactured to the requirements of the ASME Boiler and PressureVessel Code shall be registered with the National Board of Boiler and Pressure Vessel Inspectors, if required by the authority having jurisdiction

3.1.4 The repair or alteration of an ASME pressure vessel shall comply with the requirementsof NB-23, National Board Inspection Code, or by methods acceptable to the authority havingjurisdiction.

3.1.5 Other welding or brazing shall be permitted only on saddle plates, lugs, or bracketsattached to the pressure vessel by the pressure vessel manufacturer.

3.1.6 The exchange or interchange of pressure vessel appurtenances intended for the samepurpose shall not be considered a repair or alteration.


“ASME containers” are referenced immediately in the scope of the standard and throughout the document. Pressure vessel requirements are found throughout the document (Chapter 10, 11, 13, 14).

These requirements are currently found in 14.4.2.1.6 and 14.5.3.3.1 however a separate comment has recommended they be moved from these clauses to a “higher” more general level in the document. Currently there is no “general” chapter at the beginning of the standard so proposing that one be added . Without a general chapter that includes these pressure vessel requirements these requirements will need to be copied into every chapter that references pressure vessels and/or ASME compliant containers (essentially every chapter).

Modifications made: - Registration with the National Board of Boiler and Pressure Vessel Inspectors is not a requirement of DOT/TC. It is however a requirement for stationary tanks that fall under different safety authorities/jurisdictions.- Vehicle fuel tanks do not fall under the National Board Inspection Code but rather under transportation codes. Particularly, LNG fuel tanks (14.5.3.3.1.2 and 14.5.3.3.1.3) are highly specialized and their repair and alteration should be managed by the OEM.




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Public Input No. 37-NFPA 52-2016 [ Section No. 3.3.3.2 ]

3.3.3.2 Indoor Area.

An area that is within a building or structure having overhead cover, other than a structurequalifying as “weather protection.” (See also 3.3.3.3, Outdoor Area.) [55, 2016] and (See also9.3, CNG Supplemental Requirements.)


Reference another location that address indoor vs outdoor location definition.




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Public Input No. 173-NFPA 52-2017 [ Section No. 3.3.10 [Excluding any

Sub-Sections] ]

A pressure vessel, cylinder, For storing CNG or LNG. For CNG vehicles it is a cylinder orcylinder(s) permanently manifolded together used to store CNG or LNG .


1) The definitions of cylinder and pressure vessel already state that they are containers so unnecessary to include them in this definition

2) Current wording creates inaccuracies as noted below

Inaccuracy: 14.4.2.1.5 requires cylinders to be designed to FMVSS and NGV 2. However, the original 3.3.10 definition, along with the other definitions in the standard, effectively allow the CNG fuel supply container to be designed to either ASME or NGV 2/FMVSS.

Reason for the inaccuracy:Original definitions:3.3.10 Container. A pressure vessel, cylinder, or cylinder(s) permanently manifolded together used to store CNG or LNG 3.3.10.4 Fuel Supply Container. A container mounted on a vehicle to store LNG or CNG as the fuel supply to the vehicle.3.3.16 Cylinder. A container constructed, inspected, and maintained in accordance with DOT and Transport Canada regulations or ANSI NGV 2, Compressed Natural Gas Vehicle (NGV) Fuel Containers.3.3.51 Pressure Vessel. A container or other component designed in accordance with the ASME Boiler and Pressure Vessel Code.

Per original definitions:•The fuel supply container can either be a pressure vessel or a cylinder: • A “pressure vessel” is specifically defined as a container that meets ASME • The cylinder is specifically defined as a container that is compliant to NGV 2 or FMVSS

3) Do not need to specify “pressure vessel” in the container definition since container requirements themselves specify the pressure vessel requirement explicitly (14.5.3.1 and Chapter 16) 14.5 LNG Supplemental Requirements14.5.3 Vehicular Fuel Containers.14.5.3.1 Design. Containers shall be designed, fabricated, tested, and marked (or stamped) in accordance with the regulations of DOT Specification 4L or the “Rules for the Construction of Unfired Pressure Vessels,” in ASME Boiler and Pressure Vessel Code, applicable at the date of manufacture.16.1* Application. This chapter provides requirements for the installation, design, fabrication, and siting of LNG containers… that are designed and constructed in accordance with ASME Boiler and Pressure Vessel Code.




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Public Input No. 112-NFPA 52-2016 [ New Section after 3.3.13 ]

Contiguous Building Volume .

The freely-communicating volume of a building into which a release of flammable gas or vapormight accumulate from a single leak source and represent a flammability hazard.


This is a new definition that would be used in the new Chapter on VFA coverage for limitations on onboard storage of VFAs for indoor installation. While ‘building’ is already defined in NFPA 52, the additional definition is needed to describe the building volume that is relevant for consideration of potential flammable concentration development in the event of a release into the building from a VFA. ‘Contiguous’ is used to relate building volumes that are interconnected and into which a release might develop flammable concentrations from a single leak source (i.e., from a VFA). The term ‘freely-communicating’ is used in the National Fuel Gas Code (NFPA 54/ANSI Z223.1) for indoor air availability for combustion in combustion appliances. While it might be used as a replacement for ‘contiguous’ since it’s used in other NFPA standards, its fundamentally-different use for consideration of flammable concentration development would justify using another term to capture the same volume-dependent requirements.

Existing Sections 3.3.13 through 3.3.69 need to be renumbered.


Submitter FullName:

Julie Cairns


Affilliation:CSA Group NGV 5.2 Compressed Natural Gas (CNG) VehicleFueling Appliances Technical Subcommittee

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Submittal Date: Mon Dec 12 14:53:54 EST 2016



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Two options. See justification for discussion on options.

Option 1: Best option

3.3.16 Cylinder.

A CNG container constructed, inspected, and maintained in accordance with DOT the lawsand Transport Canada regulations or regulations in the area of jurisdiction.

Option 2: less preferred option

Cylinder . A CNG container constructed, inspected, and maintained in accordance with thelaws and regulations in the area of jurisdiction. When used for fuel storage on a CNG vehiclethe container must also meet ANSI NGV 2, Compressed Natural Gas Vehicle (NGV) FuelContainers .


Discussion required on best definition for Cylinder. Cylinder is used throughout the code for various applications, including stationary however this clause as written is only accurate for transport cylinders.

Delete specific reference to DOT and TC – these agencies do not regulate stationary cylinders. Also, current text as written requires every cylinder to meet the regulations of both countries regardless of whether the cylinder is destined for only one of the markets (either the US OR Canada)

First recommended text (“Best option”): • will work for any type of cylinder. • removes fuel supply container requirements since they are specified elsewhere (14.4.2.1.5.1), making them unnecessary in a definition.

Second (“less preferred”) option: :• retains supply container requirements, though not necessary (per argument above)

Examples of stationary cylinders, referenced in NFPA 52Current definition does not work since these cylinders are under different regulations:

8.4.1.3 Pressure Relief Devices. Compression equipment shall have pressure relief valves that limit each stage pressure to the maximum allowable working pressure for the compression cylinder and piping associated with that stage of compression.

Chapter 9 – Outdoor Storage9.1 Scope. This chapter shall apply to the outdoor storage of vehicular gas fuel systems in portable and stationary cylinders, containers….

Chapter 10-Indoor Storage10.1 Scope. This chapter shall apply to the indoor storage of vehicular gas fuel systems in portable and stationary cylinders, containers….

11.3.2.12.2 Compression equipment shall have pressure relief valves that limit each stage pressure to



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3.3.17.1 Emergency Shutdown Device (ESD).

A device that closes all operations within bring the operations to a fail-safe condition within thefueling facility from either local or remote locations.


Clarify that not all operation needs to close upon ESD. Some of the operation (safety system, fail-open valves) will need to stay open to keep the system safe.




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3.3.48.4 Service Pressure.

The settled pressure of the CNG fuel container at a uniform gas temperature of 21°C (70°F) andfull gas content. It is the pressure for which the container has been constructed under normalconditions.


The 2nd sentence is misleading and confusing.




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3.3.48.6 Working Pressure.

The maximum pressure that a vehicle component can be expected to experience in actualservice. The For a CNG vehicle the working pressure only applies to components that aredownstream of the first stage of pressure reduction..


Original language doesn’t work for LNG vehicles. Language is revised to also work for LNG vehicles.




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3.3.54 Residential Fueling Appliance (RFA).

A self-contained CNG vehicle fueling appliance (VFA), ( see 3.3.66 , Vehicle FuelingAppliance), designed, listed or approved, and intended to be installed as one system primarilyintended for residential (home) use.


The current definition suggests that RFAs are a subset of VFAs and needs to be separated as mutually-exclusive categories of equipment to align with later proposed treatment of these categories under Chapter 12 (RFAs) and a new “Chapter 13” covering non-residential fueling appliances delineated as VFAs. This separation will also facilitate clearer delineation of residential and non-residential appliances and coverages under the ICC codes. As a category, VFAs represent a broader array of designs and installation options, justifying these appliances as a more generic type of appliance, hence the emphasis on “vehicle” appliances, and not by default “non-residential” appliances.

Related Public Inputs for This Document

Related Input Relationship



Submitter FullName:

Julie Cairns



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3.3.66 Vehicle Fueling Appliance (VFA).

A listed self-contained appliance manufactured and certified for refueling CNG vehicles at fleetand public dispensing operations and that compresses natural gas and dispenses the naturalgas to a vehicle's engine fueling system.


Removed term “self-contained” to allow for systems to be installed with alternate dispensers. “Self-contained” still applies to RFA, but a VFA used in non-residential installation may be allowed with separate dispensing unit.


Submitter FullName:

Julie Cairns


Affilliation:CSA Group NGV 5.1 Home Fueling Appliance TechnicalSubcommittee

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4.5.1.7

Control systems that are used as part of the fire protection system at the LNG plant shall beinspected and tested in accordance with the applicable fire codes and standards and conform tothe following criteria:

(1) Monitoring equipment shall be maintained in accordance with NFPA 72 and NFPA 1221.

(2) Fire protection water systems, if required, shall be maintained in accordance withNFPA 13, NFPA 14, NFPA 15, NFPA 20, NFPA 22, NFPA 24, and NFPA 25.

(3) Portable or wheeled fire extinguishers suitable for gas fires, preferably of the dry-chemicaltype, shall be available at strategic locations, as determined in accordance withChapter 13, within an LNG facility and on tank vehicles, and shall be maintained inaccordance with NFPA 10.

(4) Fixed fire extinguishers and other fire-control systems that are installed shall bemaintained in accordance with NFPA 11, NFPA 12, NFPA 12A, NFPA 16, and NFPA 17.[59A:13.18.4.5(C)]


Recommend deletion of unenforceable text.


Submitter Full Name: Jennifer Boyle

Organization: FEMA

Affilliation: FEMA

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Sub-Sections] ]

LNG, LCNG, CNG, and other gaseous/cryogenic installations shall be permitted to use alternatesite distances, operating requirements, and equipment locations with validation by a qualifiedengineer person (s) with proven expertise in mechanical systems, electrical systems, gaseousstorage systems, cryogenic storage systems, fire protection, and gas detection.


Qualified Person is defined in Ch 3. Qualified Engineer is not defined.



Public Input No. 42-NFPA 52-2016 [Section No. 5.1.1.1.3]





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Public Input No. 41-NFPA 52-2016 [ Section No. 5.1.1.1.1 ]

5.1.1.1.1

The validation shall at a minimum include the should include some of the following:

(1) Process safety analysis and hazard and operability studies (HAZOPS)

(2) Mitigating fire protection measures such as suppression systems

(3) Aboveground or belowground systems or vaults for the containers

(4) Fire and gas detection systems designed to interface with an emergency shutdown device(ESD)

(5) Ventilation and other facility features

(6) Drainage and impounding for the individual site as administered by a qualifiedengineer person (s) with proven expertise in these fields


The listed requirements should be a recommended items not required items. Some of the item listed, such as, Fire detection system is not a code requirement. The actual validation items should be determined by the Qualified Person.








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5.1.1.1.3

The validation shall be conducted by a qualified engineer person (s) with proven expertise in thespecific fueling and supporting equipment being installed.





Public Input No. 40-NFPA 52-2016 [Section No. 5.1.1[Excluding any Sub-Sections]]

Same Comment

Public Input No. 41-NFPA 52-2016 [Section No. 5.1.1.1.1]Portion of SameComment





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5.1.1.1.3

The validation shall be conducted by a qualified engineer person (s) with proven expertise in thespecific fueling and supporting equipment being installed.






Public Input No. 40-NFPA 52-2016 [Section No. 5.1.1 [Excluding anySub-Sections]]





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5.2.1.1.7 Vehicle Fueling Appliances in Nonresidential Occupancies.

5.2.1.1.7.1

VFAs shall not be installed within 10 ft (3.0 m) of any flammable gas or liquid storage.


All VFA requirements coverage is proposed to be consolidated in new Chapter 13 covering VFAs





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Julie Cairns



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5.3.2.6

An operating, portable, flammable-gas detector shall be readily available to qualified person(s) .


Gas detector should be used by Qualified Person only.




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5.3.3.1

LNG tanks and their associated equipment shall not be located where exposed to or beprotected against failure of overhead electric power lines operating over 600 volts.



site_pic_2.jpg


Code should allow station designer to engineer solution to protect against different field conditions, including power lines.



Public Input No. 57-NFPA 52-2016 [Section No. 9.3.1.2]




Public Input No. 78-NFPA 52-2016 [Section No. 11.3.2.12.8.2]




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jdepew

Sticky Note

attachment to PI 45

Public Input No. 46-NFPA 52-2016 [ Sections 5.3.6.1, 5.3.6.2 ]

Sections 5.3.6.1, 5.3.6.2

5.3.6.1

Fired equipment shall be located in accordance with Table 11 Table 13 .3.2.14 25 .1 from anyimpounding area or container drainage system.

5.3.6.2

Buildings and rooms used for storage or dispensing shall be classified in accordance with Table11 Table 13 .3.2.14 25 .1 for installations of electrical equipment.


Wrong reference Table.




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Public Input No. 28-NFPA 52-2016 [ New Section after 6.3.1.2 ]

All natural gas vehicles shall be equipped with a pressure gauge or pressure managment systemthat will warn the vehicle operator if the fuel system pressure exceeds 125 percent of the servicepressure.






NFPA 52 -2013 Section 6.12.4 requires that remedial action must be taken in the event that the fuel system pressure exceeds 125 precent of the service pressure. At this time there is no requirement that a method to measure this pressure should be installed on the vehicle. Without a pressure measurement device on the vehicle to warn the operator of an overpressure condition the continued safe operation of the vehicle is compromised. The existing document covers installation of pressure gauges in section 6.7 but does not require that they be installed. The proposal expands the measurement devise beyond a simple gauge to allow other measurements options that may beused in a pressure management system. It also sets a requirement that a warning (either visible or audible) be given to the operator.



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Public Comment No. 9-NFPA 52-2014 [ New Section after 6.7.1 ]

TITLE OF NEW CONTENT

All natural gas vehicles shall be equipted with a pressure guage or pressure managment system that will warnthe vehicle operator if the fuel system pressure exceeds 125 precent of the service pressure.


NFPA 52 -2013 Section 6.12.4 requires that remedial action must be taken in the event that the fuel system pressure exceeds 125 precent of the service pressure. At this time there is no requirement that a method to measure this pressure should be installed on the vehicle. Without a pressure measurement device on the vehicle to warn the operator of an overpressure condition the continued safe operation of the vehicle is compromised. The existing document covers installation of pressure gauges in section 6.7 but does not require that they be installed. The proposal expands the measurement devise beyond a simple gauge to allow other measurements options that may be used in a pressure management system. It also sets a requirement that a warning (either visible or audible) be given to the operator.

Related Item

Public Input No. 193-NFPA 52-2013 [Section No. 6.12.4]



Submitter Full Name: Douglas Horne

Organization: DBHorne LLC

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Submittal Date: Thu Oct 16 09:15:24 EDT 2014

Committee Statement

CommitteeAction:

Rejected but held

Resolution: The committee feels that this is a new requirement that should be addressed during the next revisioncycle. The committee is concerned about the implementation of this requirement in a vehicle and howthe operator would be notified that the pressure is exceeded.


I, Douglas Horne, 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 I acquireno rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivativeform is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyrightassignment.

By checking this box I affirm that I am Douglas Horne, and I agree to be legally bound by the above Copyright Assignment and the terms andconditions 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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jdepew

Sticky Note

attachment to PI 28

Public Input No. 50-NFPA 52-2016 [ Section No. 7.2 [Excluding any

Sub-Sections] ]

Natural gas composition dispensed to vehicles shall vehicles should comply with 7.2.1 through7.2.4.


Fuel Quality is not controlled at the station level but at gas supply. There are other jurisdiction controlling gas quality, such as, FERC, and could be contradicting 52. It is very difficult for AHJ to enforce.








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7.2.1

The dispensed natural gas shall gas should consist of the following:

(1) Hydrogen sulfide and soluble sulfides, 1 gr/100 scf (23 mg/m3), maximum

(2) Carbon dioxide, 3.0 volume percent, maximum

(3) Oxygen, 1.0 volume percent, maximum

(4) Hydrogen, 2.0 volume percent, maximum


Gas Quality should be a recommendation not a code requirement.



Public Input No. 50-NFPA 52-2016 [Section No. 7.2 [Excluding anySub-Sections]]





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7.2.2

Water — the pressure dew point of the natural gas shall gas should be at least 20°F below thelowest anticipated temperature in which the vehicle will operate and at the pressure of a fullcontainer with a uniform gas temperature equal to the lowest anticipated vehicle operatingtemperature.


Gas Quality should be a recommendation not a code requirement.




Public Input No. 50-NFPA 52-2016 [Section No. 7.2 [Excluding anySub-Sections]]




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8.3.2.1*

The following subsystems or components associated with storage and dispensing of CNG andLNG as an engine fuel in fleet and public dispensing operations shall be listed or approved:

(1) Pressure relief devices, including pressure relief valves

(2) Pressure gauges

(3) Pressure regulators

(4) Valves

(5) Hose and hose connections

(6) Vehicle fueling connections (nozzle and receptacle)

(7) Engine fuel systems

(8) Electrical equipment related to storage or dispensing systems

(9) Gas detection equipment and alarms

(10) Fire protection and suppression equipment

(11) Vehicle fueling appliances (VFAs)

(12) Residential fueling appliances (RFAs)


To ensure that residential fueling appliances will be listed to the new CSA Group NGV 5.1, Residential Fueling Appliance standard.


Submitter FullName:

Julie Cairns



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8.3.3.2 Pressure Gauges

8.3.3.2.1 A pressure gauge, if provided, shall be capable of reading at least 1.2 times themaximum allowable working pressure for the dispensing station


Moved from 14.4.2.3




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8.3.3.1 Pressure Regulators.

8.3.3.1.1

Regulators shall be designed, installed, or protected so that their operation is not affected byfreezing rain, sleet, snow, ice, mud, insects, or debris.

8.3.3.1.2

Regulator protection of 8.3.3.1.1 shall be permitted to be integral with the regulator.

8.3.3.1.3

A pressure regulator inlet and each chamber shall be designed for its operating pressurewith a pressure safety factor of at least four times the operating pressure of the dispensingstation.


Moved text from 14.4.2.4




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8.3.3.5.1 Dispensing station hose, metallic hose, flexible metal hose, tubing, and theirconnections shall be designed or selected for the most severe pressures andtemperatures under normal operating conditions with a burst pressure of at least fourtimes the maximum allowable working pressure.

8.3.3.5.2 Prior to use, hose assemblies shall be tested by the OEM or its designatedrepresentative at a pressure of at least twice the maximum allowable working pressure(MAWP).


Moved from 14.4.2.8.2 and 14.4.2.8.2.1 since Chapter 14 is vehicle rather than dispensing station equipment requirements.




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8.3.3.6.1 Shut Off Valves

Shutoff valves for dispensing stations shall have a rated maximum allowable working pressurenot less than the rated operating pressure of the system and shall be capable of withstanding a hydrostatic test of at least four times the rated operating pressure withoutrupture.


Moved from 14.4.2.6.1.1




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8.4.1.4.2

Control circuits that shut down shall remain down until manually activated or reset after a safeshutdown condition is performed restored .


Original text is confusing.




Public Input No. 80-NFPA 52-2016 [New Section after 11.3.2.12.12]




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8.4.2.1.2

A vehicle fuel storage supply container shall not be charged in excess of the quantity of fuelthat would result in a gas pressure equal to service pressure at a uniform temperature of 70°F(21°C). Under no circumstances shall the vehicle fuel storage cylinder container be subjectedto pressure in excess of 1.25 times the service pressure.


Consistency.


Note that a separate global comment has also been submitted to address the many cases of inconsistent terminology used throughout the code.




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8.4.2.2.2

The dispenser shall dispenser should be designed to detect any malfunction that fills thevehicle fuel container in excess of the limits specified, or causes the relief valve required in11.3.2.3 to open. If a malfunction is detected, the following shall occur:

(1) The dispenser shall disable itself until it is repaired, calibrated, or serviced.

(2) The If traceable, the vehicle operator or fueling technician shall be notified that thevehicle has been overfilled.

(3) After any such malfunction, the dispenser shall be repaired and calibrated in accordancewith 4.5.1.1 before continued operation.


The requirement is not practical and could be confusing to AHJ.




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8.4.2.3.3

The set pressure of the overpressure protection device shall not exceed 125 percentexceed 138 percent of the service pressure of the fueling nozzle it supplies.


The current language limits the vehicle pressure to only around 113 percent due to lifting allowance for pressure relief device. Changing the 125 percent to 138 percent will actually allow the vehicle tank pressure to receive a temp compensated fill up to 125 percent of the service pressure. This change is similar to section 10.3.1.4.2.2 of NFPA 2, the hydrogen technology code.




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Submittal Date: Fri Dec 09 11:54:14 EST 2016



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Public Input No. 56-NFPA 52-2016 [ New Section after 8.4.2.5.1(B) ]

8.4.2.5.1 (C)

When the electric power is cut off (black out condition), the systems that shut down shall remainoff until manually activated or reset after a safe condition is confirmed.

8.4.2.5.1 (D)

When the electric power is interrupted (brown out condition) or the station is equipped withbackup power, the system that shut down should be allowed to reset after power is restored.


The code is not addressing brown out and station with generators.



Public Input No. 55-NFPA 52-2016 [Section No. 8.4.2.5.1(B)]




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Public Input No. 55-NFPA 52-2016 [ Section No. 8.4.2.5.1(B) ]

(B)

Control circuits shall be arranged so that, when an emergency shutdown device is activated orelectric power is cut off, the systems that shut down shall remain off until manually activated orreset after a safe condition is restored confirmed .


Need to be flexible to consider brown out and station with generators.



Public Input No. 56-NFPA 52-2016 [New Section after 8.4.2.5.1(B)]




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9.2 PRVs

9.2.1 Pressure relief valves (PRVs) shall not be fitted with lifting devices.

(A) The adjustment, if external, shall be provided with a means for sealing the adjustment toprevent tampering.

(B) If at any time it is necessary to break such a seal, the valve shall be removed from serviceuntil it has been reset and sealed.

(C) Adjustments shall be made only by the manufacturer or other companies having competentpersonnel and facilities for the repair, adjustment, and testing of such valves.

(D) The organization making such adjustments shall attach a permanent tag with the setting,capacity, and date.

9.2.2 PRVs protecting ASME pressure vessels shall be repaired, adjusted, and tested inaccordance with NB-23, National Board Inspection Code.

9.2.3 *PRVs shall be maintained in safe operating condition.

9.2.4 Installation of PRVs. PRVs shall have vent lines to convey escaping gas upward toprevent impinging on buildings, other equipment, or areas open to the public (e.g., sidewalks).

9.2.5 A PRV shall be installed in each section of piping or tubing in which CNG can be isolatedbetween shutoff valves so as to relieve the trapped fuel pressure to a safe atmosphere.

9.2.6 The PRV shall not have a setting greater than the maximum allowable working pressureof the line it protects.


The PRV requirements are copied from 10.3.1.6 (indoor storage) but are applicable also to this section in Chapter 9 (Outdoor Storage) since it is applicable to all PRVs, regardless whether indoor or outdoor storage.

9.2.1: This requirement in NFPA 52-2013 was transferred over to two different places in NFPA 52-2016, 10.3.1.6.1 (indoor storage) and 14.4.2.2.2.2. In a separate submitted comment Westport also suggests it be added to 14.5.3.4 which is the PRV requirements of the LNG system.




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60 of 273 4/18/2017 11:12 AM



61 of 273 4/18/2017 11:12 AM


9.2.1

Pressure vessels complying with 14.4.2.1.6 used for stationary storage without temperaturecompensation of the storage operating pressure shall be protected with one or more spring-loaded pressure relief valves in accordance with the ASME Boiler and Pressure Vessel Code.


Moved from 14.4.2.2.2 since the requirements are specific to stationary storage.

The language should not reference 14.4.2.1.5 (cylinders) but rather 14.4.2.1.6 (pressure vessels).

A separate comment has been submitted recommending that 14.4.2.1.6 (pressure vessels) be moved into a higher level "general" Chapter. In this case the reference in this clause will change from 14.4.2.1.6 to the applicable new "general" clause.




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62 of 273 4/18/2017 11:12 AM


9.3.1.2

Compression, storage, and dispensing equipment located outdoors shall not be beneath or beprotected against electric power lines or where exposed by their failure.


Code should allow station designer to address site conditions.











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63 of 273 4/18/2017 11:12 AM


9.3.1.4














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64 of 273 4/18/2017 11:12 AM


9.3.2.1.2

In areas subject to flooding, each container(s) shall be anchored to prevent floating.


Clarification.




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65 of 273 4/18/2017 11:12 AM


9.3.6.1.4

A bend in piping or tubing shall be prohibited where such a bend weakens the pipe or tubingbeyond its design operating condition .


Clarification.







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66 of 273 4/18/2017 11:12 AM


9.3.7.1 Power Lines.

Compression, storage, and dispensing equipment located outdoors shall not be beneath electricpower lines or be protected against where exposed by their failure.












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67 of 273 4/18/2017 11:12 AM


9.3.7.2.1 Installation of PRVs.

PRVs shall have PRD vents or vent lines to convey escaping gas to the outdoors and thenupward to prevent impinging on buildings, other equipment, or areas open to the public (e.g.,sidewalks).


"PRD vents" is not appropriate language for PRVs.




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68 of 273 4/18/2017 11:12 AM




Clarification required. Why are the requirements not the same as the equivalent section in“Indoor Storage” (10.3.1.6.4 to 10.3.1.6.6)? Isn’t the outdoor storage missing the requirementsof 10.3.1.6.5 and 10.3.1.6.6?


Clarification required. Why are the requirements not the same as the equivalent section in “Indoor Storage” (10.3.1.6.4 to 10.3.1.6.6)? Isn’t the outdoor storage missing the requirements of 10.3.1.6.5 and 10.3.1.6.6?




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69 of 273 4/18/2017 11:12 AM


9.4.3.2.1

LNG tanks and their associated equipment shall not be located or be protected against whereexposed to or failure of overhead electric power lines operating over 600 volts.












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70 of 273 4/18/2017 11:12 AM


10.3.1.2

Pressure vessels complying with 14.4.2.1.6 used for stationary storage without temperaturecompensation of the storage operating pressure shall be protected with one or more spring-loaded pressure relief valves in accordance with the ASME Boiler and Pressure Vessel Code.


Moved from 14.4.2.2.2 since this clause is specific to stationary storage. Reference updated since 14.4.2.1.5 is incorrect but instead should be 14.4.2.1.6.

Also note that a separate submitted recommendation suggests that 14.4.2.1.6 (pressure vessels) should be moved into a higher level "general" Chapter at the beginning of the code. In this case the reference in this clause will change from 14.4.2.1.6 to the applicable new "general" clause.




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71 of 273 4/18/2017 11:12 AM


10.3.1.2.1

Storage shall be limited to not more than 10 36 ,000 scf (283 m 1,019 m 3) of natural gas ineach building or room.


Propose to increase indoor storage limit to a 3-pack.




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72 of 273 4/18/2017 11:12 AM


10.3.1.6.1

Pressure relief valves (PRVs) for CNG service shall not be fitted with lifting devices.



(C) Adjustments shall be made only by the manufacturer or other companies havingcompetent personnel and facilities for the repair, adjustment, and testing of such valves.



This requirement in NFPA 52-2013 was transferred over to two different places in NFPA 52-2016, clause 10.3.1.6.1 and 14.4.2.2.2.2. The original requirement in NFPA 52-2013 was identically copied to 14.4.2.2.2.2 but is missing the A-D requirements in 10.3.1.6.1.




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73 of 273 4/18/2017 11:12 AM





"PRD vents" is not appropriate language for PRVs.




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74 of 273 4/18/2017 11:12 AM


10.3.1.6.5

A PRV shall be installed in each section of piping or tubing in which CNG can be isolatedbetween shutoff valves so as to relieve the trapped fuel pressure to a safe atmosphere.


Not practical and way beyond ASME requirement.




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75 of 273 4/18/2017 11:12 AM


10.3.1.7.1

Shutoff valves shall have a rated service pressure not less than the rated service pressure ofthe entire system line and shall be capable of withstanding a hydrostatic test of at least fourtimes the rated service pressure without rupture.


Lower pressure system valves should not be rated to the service pressure of the entire system.




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76 of 273 4/18/2017 11:12 AM


10.3.1.7.2

Access to the emergency manual shutoff valves shall not require the use of any key or tool.


Some valves needed to be lock-opened, such as the valve between the PRV and storage vessel.




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77 of 273 4/18/2017 11:12 AM

Public Input No. 114-NFPA 52-2016 [ Section No. 11.1 ]

11.1 Application.

This chapter applies to the design, construction, installation, and operation of containers,pressure vessels, compression equipment, buildings and structures, and associated equipmentused for storage and dispensing of CNG as an engine fuel in fleet and public dispensingoperations other than residential fueling appliances (RFAs) and non-residential fuelingappliances or “vehicle fueling appliances” (VFAs) . Coverage of RFAs and VFAs is providedunder Chapters 12 and 13 of this Standard, respectively.


This text is added for clarification that appliance-related CNG fueling is covered under the current Chapter 12 text for RFAs and the reorganization of VFA coverage under a newly-proposed Chapter 13 where VFA coverage is consolidated.





Submitter FullName:

Julie Cairns



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78 of 273 4/18/2017 11:12 AM


11.3.1.1

Where systems are served by a gas utility, the gas utility shall be notified of all of this CNGinstallations installation .


Clarification.




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79 of 273 4/18/2017 11:12 AM


11.3.1.3

Control devices The system shall be installed designed so that internal or external icing orhydrate formation does not cause vehicle or fueling station malfunction.


The entire system should be designed to prevent malfunction due to icing and hydrate, not just the control devices.




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80 of 273 4/18/2017 11:12 AM


11.3.2.1 Installation of Containers, Cylinders, and Tanks.

11.3.2.1.1

Installation of indoor tanks shall meet the requirements of Chapter 10.

11.3.2.1.2

Installation of outdoor tanks shall meet the requirements of Chapter 9.


The requirements under this title all refer only to tanks




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81 of 273 4/18/2017 11:12 AM


11.3.2.2.3

Pressure relief valves venting system shall be fitted with rain caps designed to protect againstthe elements .


Should provide station designer to choose protection approach due to site conditions.




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82 of 273 4/18/2017 11:12 AM


11.3.2.2.4

If approved, lockable full port block valves shall be permitted to be installed between the reliefvalves and the storage vessel or fueling transfer system.


This valve need to be lockable and only service by Qualified Person.




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83 of 273 4/18/2017 11:12 AM


11.3.2.2.5

The block valves shall be locked open under normal operating condition .


Clarification.




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84 of 273 4/18/2017 11:12 AM

Public Input No. 72-NFPA 52-2016 [ Section No. 11.3.2.3 [Excluding any

Sub-Sections] ]

A pressure relief valve other than a rupture disc shall be installed in the fueling transfer systemto prevent pressures in excess of vehicle pressure to exceed 125 percent of the vehicle servicepressure from being supplied to the vehicle .


The protection should be focused on the vehicle, not the supplied system.




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85 of 273 4/18/2017 11:12 AM

Public Input No. 73-NFPA 52-2016 [ Section No. 11.3.2.6.1.4 ]

11.3.2.6.1.4

Threaded pipe and fittings shall not be used underground except when installed inside an opentrench .


Clarification.




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86 of 273 4/18/2017 11:12 AM


11.3.2.7.6

A bend in piping or tubing shall be prohibited where such a bend weakens the pipe or tubingbeyond its design application .


Clarification.







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87 of 273 4/18/2017 11:12 AM


Sub-Sections] ]

The use of hose in an installation shall be limited to installation should be minimized, exceptthe following:

(1) Vehicle fueling hose

(2) Inlet connection to compression equipment

(3) Section of metallic hose not exceeding 36 in. (910 mm) in length in a pipeline to provideflexibility where necessary


Hoses are being used in many part of the station, including oil/lubrication system, pilot air or gas system. Code should just recommend minimizing usage, not limiting usage.




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88 of 273 4/18/2017 11:12 AM

Public Input No. 76-NFPA 52-2016 [ Sections 11.3.2.9.5, 11.3.2.9.6 ]

Sections 11.3.2.9.5, 11.3.2.9.6

11.3.2.9.5

The valve in

11.3.2.9.

4 shall be located downstream of the backflow check valve specified in 11.3.2.9.

6

.

11.3.2.9.6

The fill line on a storage container shall be equipped with a backflow check valve to preventdischarge of natural gas from the container in case of the rupture of the line, hose, fittings, orother equipment upstream of the storage containers.


Most CNG storage have bi-directional fill/draw line, this code sections could be confusing to AHJ.







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89 of 273 4/18/2017 11:12 AM


11.3.2.12.4

Control circuits that shut down shall remain down until manually activated or reset after a safeshutdown condition is performed confirmed .






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90 of 273 4/18/2017 11:12 AM


11.3.2.12.8.2












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91 of 273 4/18/2017 11:12 AM

Public Input No. 80-NFPA 52-2016 [ New Section after 11.3.2.12.12 ]

11.3.2.12.13

Control circuits shall be arranged so that when electric power is cut off (black out condition),system that shut down remain off until manually activated or reset after a safe condition isconfirmed.

11.3.2.12.14

Control circuits shall be arranged so that when electric power is interrupted (brown outcondition) or if the system is equipped with backup power, the system can be reset to resumeoperation.


Should address brown out and stations with generator differently.








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92 of 273 4/18/2017 11:12 AM


11.3.2.12.12

Control circuits shall be arranged so that, when an emergency shutdown device is activated orelectric power is cut off , systems that shut down remain off until manually activated or resetafter a safe condition is restored confirmed .


Address brown out and stations with generator.



Public Input No. 80-NFPA 52-2016 [New Section after 11.3.2.12.12]





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93 of 273 4/18/2017 11:12 AM


11.3.2.13.2

Under no circumstances shall the vehicle fuel storage cylinder container be subjected topressure in excess of 1.25 times the service pressure.


Consistency. Container was used in 11.3.2.13.1 and is appropriate based on the definition of 3.3.10.4




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94 of 273 4/18/2017 11:12 AM


11.3.2.13.3

DOT, TC, and or ANSI/NGV2 cylinders shall be charged in accordance with DOT , or TC ,and ANSI NGV 2 regulations. regulations or ANSI NGV2, as applicable.

Clarification required. Is a TC cylinder allowed?


Clarification required. Is a TC cylinder allowed? Note that 14.4.2.1.5.1 has removed any mention of TC and only allows NGV 2 plus DOT cylinders.

Changed "and" to "or" - DOT and NGV 2 may not have identical charging requirements.

ANSI NGV 2 is not a regulation




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95 of 273 4/18/2017 11:12 AM

Public Input No. 81-NFPA 52-2016 [ Section No. 11.3.2.13.6 [Excluding any

Sub-Sections] ]

The dispenser shall dispenser should be designed to detect any malfunction that fills thevehicle fuel container in excess of the limits specified, or causes the relief valve required in11.3.2.3 to open. If a malfunction is detected, it shall perform the following:

(1) Disable itself until repaired, calibrated, or serviced

(2) Notify If possible, notify the vehicle operator or fueling technician that the vehicle hasbeen overfilled


No practical solutions at this time, but put as recommendation.




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96 of 273 4/18/2017 11:12 AM

Public Input No. 82-NFPA 52-2016 [ Section No. 11.3.2.13.6.1(A) ]

(A)

The If the system is equipped with defueling equipment and it is safe to do so, the excess fuelshall be removed from the vehicle, by qualified person(s) only .


Defueling has many potential hazards, should only be done by qualified person.




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97 of 273 4/18/2017 11:12 AM


Sub-Sections] ]

Fixed electrical equipment and wiring within areas specified in Table 11.3.2.14.1 shall complywith Table 11.3.2.14.1 and be installed in accordance with NFPA 70.

Table 11.3.2.14.1 Electrical Installations

Location

Division

or Zone

Extent of

Classified Area

Containers (other than mounted fuel supplycontainers)

2Within 10 ft (3 m) ofcontainer

Area containing compression

Compression and ancillary equipment 2 Up to 15 ft (4.6 m) from equipment

Dispensing equipment outdoors 1 Inside the dispenser enclosure gas compartment

Outdoors 2 From 0 to 5 ft (0 to 1.5 m) from the

dispenser

dispenserenclosure gas compartment

Indoors 1Inside the dispenser gas compartmentenclosure

Indoors 2Entire room, with adequate ventilation (see7.4.3)

Discharge from relief valves or vent

Outdoors 15 ft (1.5 m) in all directions from the pointsource

Outdoors 2Beyond 5 ft (1.5 m) but within 15 ft (4.6 m) inall directions from point of discharge

Valves, flanges of screwed fittings None Unclassified

Discharge from relief valves within 15degrees of the line of discharge

1 15 ft (4.6 m)


Clarifying the div 1 area inside the dispenser is with the gas compartment.




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98 of 273 4/18/2017 11:12 AM

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99 of 273 4/18/2017 11:12 AM


11.3.2.16.2

The fill line on a storage container shall be equipped with a backflow check valve to preventdischarge of natural gas from the container in case of the rupture of the line, hose, fittings, orother equipment upstream of the storage containers.


Most CNG storage system has bi-direction fill line, this requirement could be confusing to AHJ.



Public Input No. 76-NFPA 52-2016 [Sections 11.3.2.9.5, 11.3.2.9.6]




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100 of 273 4/18/2017 11:12 AM


11.3.2.16.8

Control circuits shall be arranged so that, when an electric power cutoff (black out condition),systems that shut down remain off until manually activated or reset after a safe condition isconfirmed.

11.3.2.16.9

Control circuits shall be arranged so that, when an electric power interruption (brown outcondition) or system is equipped with backup power, systems that shut down should be allowedto reset and resume operation.


Need to address brown out and station with generator differently.




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101 of 273 4/18/2017 11:12 AM


11.3.2.16.7

Control circuits shall be arranged so that, when an emergency shutdown device is activated orelectric power is cut off, systems that shut down remain off until manually activated or resetafter a safe condition is restored confirmed .






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102 of 273 4/18/2017 11:12 AM


11.3.2.16.9

A self-closing valve shall be provided on the inlet of the compressor that shuts off the gassupply to the compressor when one of the following occurs:

(1) An emergency shutdown device is activated.

(2) A power failure occurs.

(3) The power to the compressor is switched to the OFF position.


Clarification.




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103 of 273 4/18/2017 11:12 AM

Public Input No. 115-NFPA 52-2016 [ Section No. 11.3.3.1.1 ] 11.3.3.1.1 Vehicle Refueling Appliances in Nonresidential Occupancies with Systems Other than Listed VFAs. 11.3.3.1.1.1 VFAs shall Vehicle refueling systems shall not exceed a gas flow of 10 scf/min (0.28 SCM/min).

11.3.3.1.1.2 VFAs shall be listed. 11.3.3.1.1.3 The installation of VFAs shall be exempt from the requirements of Sections 4.2, 5.2.1.1.1 through 5.2.1.1.5, 9.3.1 and 9.3.2, 10.3.1.1 through 10.3.1.5, 11.3.1, 11.3.2.2, 11.3.2.4, 11.3.2.6, 11.3.2.10, 11.3.2.11, 11.3.2.13 through 11.3.2.17, 11.3.6.2.2, 14.4.2.2 through 14.4.2.6, 14.4.2.8. 11.3.3.1.1.4 VFAs shall be Vehicle refueling systems shall be permitted to be used to fill stationary containers at vehicle fueling locations. (A) The method of connecting the VFA vehicle refueling system to such storage shall comply with the provisions of Chapters 5, 8, and 7 and shall be approved. (B) The provisions of 11.3.3.1.1.3 shall apply to the VFA vehicle refueling system where connected to stationary containers at vehicle fueling locations. (A) The requirements of 12.1.2 and 12.1. 11.3.3.1.1.5 The installation of VFAs shall comply with the requirements of Chapter 12. 3 shall not apply to the installation of VFAs. (B)

Gas detectors shall be installed in proximit to the vehicle refueling system and shall be located in accordance with good engineering practice. 11.3.3.1.1.64 VFAs shall Vehicle refueling systems shall not be installed within 10 ft (3.0 m) of any other flammable gas or liquid storage. (A) Storage in the vehicle fuel supply container shall not be subject to 11.3.3.1.1.6. 11.3.3.1.1.75 Where installed indoors in public assembly and educational occupancies, a VFA vehicle refueling system shall be located in a portion of the occupancy where NFPA 101 or the local building code permits the installation of hazardous equipment. (A) Where the VFA vehicle refueling system is located outdoors, the dispensing point shall be permitted to be located indoors without the need for a separate room.

Statement of Problem and Substantiation for Public Input Coverage of listed VFAs is proposed for relocation to a new Chapter 13, “Vehicle Fueling Appliances.” All requirements specific to VFAs is proposed to be moved to that chapter. Retained requirements that would be applicable for unlisted, field-assembled CNG “vehicle refueling systems” are retained. Requirements that are applicable to both listed VFAs and unlisted vehicle refueling systems are repeated in both locations (i.e., in this chapter and in the new Chapter 13.

Related Public Inputs for This Document Related Input Relationship

Public Input No. 121-NFPA 52-2016 [New Section after 12.12.4] Related to new Chapter


Submitter Full Name:

Julie Cairns


Affilliation: CSA Group NGV 5.2 Compressed Natural Gas (CNG) Vehicle Fueling Appliances Technical Subcommittee

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

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


11.3.3.2.1.2

The actuation of the gas detection system shall shut down the compressor and stop the flow ofgas into the structure .


Clarification.




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106 of 273 4/18/2017 11:12 AM

Public Input No. 116-NFPA 52-2016 [ Chapter 12 [Title Only] ]

Residential CNG Fueling Appliances


This change would clarify that Chapter 12 covers only listed residential fueling appliances (RFAs), which is the substance of the chapter coverage currently. Other means of residential fueling would not be covered by NFPA 52 and, by default, prohibited under the Standard.


Submitter FullName:

Julie Cairns



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107 of 273 4/18/2017 11:12 AM


12.1.1

This chapter applies to the design, construction, installation, and operation of a residentialfueling appliances (RFA) listed to CSA/ANS NGV 5 .1 or its equivalent.


This additional specification of RFAs to NGV 5.1 provides direct traceability to its requirements of listing, “or its equivalent” as would be assessed by the AHJ.


Submitter FullName:

Julie Cairns



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108 of 273 4/18/2017 11:12 AM


12.1.3

Storage of CNG of natural gas CNG shall be prohibited

, other than amounts allowed within an RFA listed to ANSI NGV 5 . 1 .

12.1.3.1

CNG shall be permitted to be stored in the vehicle fuel supply container.


NGV 5.1 allows storage within the RFA. During the 2.5 year review by the CSA technical subcommittee for the NGV 5.1 standard, a team of 8 scientists from across the industry reviewed all prior analyses, FMEAs, and anecdotal evidence. They concluded, that minimal storage of natural gas is safe for public use and additionally can demonstrate that the small quantities of natural gas are safer than the other allowed petroleum based fuels that are allowed storage. The team, in order to rest assure the public was safe too added measures and reduced the quantity of gas storage to the value expressed.


Submitter FullName:

Julie Cairns



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109 of 273 4/18/2017 11:12 AM

Public Input No. 32-NFPA 52-2016 [ Section No. 12.1.3 [Excluding any Sub-Sections] ] Storage of CNG shall be prohibited. The Residential Fueling Appliances (RFAs) standard, ANSI/CSA NGV 5.1-2016, allows RFAs with a storage system.

The NFPA52 should be harmonized with the NGV 5.1 by allowing this feature and adopting the same specifications. The following recommended specifications are extracted from the NGV 5.1-2016:

4.9 Gas retention limits for all RFAs:

Outdoor mounted unit limits:

The total volume of gas contained by the RFA package for outdoor installation shall not exceed 750 SCF (21 SCM). Any single storage container shall not exceed 433 SCF (12.3 SCM). The RFA shall be marked in accordance with Clause 7.2.2.

6.20.4

RFAs that have gas storage systems shall have no single container with capacity more than 433 SCF (12.3 SCM).

6.20.5

Any container that has a capacity greater than 42.5 L (1.50 ft3) and a pressure greater than 103 kPa (14.9 psi) shall comply with the requirements of ASME Boiler and Pressure Vessel Code Sections VIII or X,(CSA B51, Part 3).

6.20.8

Fuel containers within the RFA shall not have a settled pressure above the service pressure that is stamped on the container and displayed on a label near the filling connection, corrected for the ambient temperature at the time of filling.

6.20.9

A RFA with gas storage for outdoor use only shall employ:

a) separate automatically operated normally closed valves for each container that will isolate the

contained gas if the emergency shutdown system is engaged or power is lost;

b) a manually operated container valve shall be provided for each storage container;

c) an overpressure protective device as required by the container code of construction shall be

provided for each group of connected containers or single container; and

d) a resettable overpressure protection device shall be installed in the fuel delivery system to prevent

over pressurization of the vehicle.

6.20.13

For outdoor mounted RFA with contained gas, a fire detection methodology must be employed.

Detection of fire or rise in heat shall cause the RFA, at a minimum, to:

a) close all valves to isolate the RFA from the supply source, and vehicle;

b) close all internal electrically operated valves to isolate sub-systems; and

c) give RFA external indication that the unit has detected a fire or rise in heat.

6.20.14

For outdoor mounted RFA, there shall be no greater than 6 GGE of gas contained while the RFA is in dormant or operational mode.

a) There shall be no greater than 3 GGE per single container.

b) All individual containment systems shall employ isolation valves for:

i) system non-operational dormant modes;

ii) emergency isolation operations; and

iii) manually operated isolation valve for maintenance purposes.

c) All containers shall have the means of releasing gas as due to a rise in temperature from an external fire source, via the use of a thermal pressure release device.

7.2.2

Each appliance shall bear a label of Class IIIA marking material located so as to be visible at the time of installation. The label shall exhibit the following statements:

A RFA for outdoor installation only shall bear the following statement: “For outdoor installation only.”

The Residential Fueling Appliances (RFAs) standard, ANSI/CSA NGV 5.1-2016, allows RFAs with a storage system.

The NFPA52 should be harmonized with the NGV 5.1 by allowing this feature and adopting the same specifications. The following recommended specifications are extracted from the NGV 5.1-2016:

4.9 Gas retention limits for all RFAs:

Outdoor mounted unit limits:

The total volume of gas contained by the RFA package for outdoor installation shall not exceed 750 SCF (21 SCM). Any single storage container shall not exceed 433 SCF (12.3 SCM). The RFA shall be marked in accordance with Clause 7.2.2.

6.20.4

RFAs that have gas storage systems shall have no single container with capacity more than 433 SCF (12.3 SCM).

6.20.5

Any container that has a capacity greater than 42.5 L (1.50 ft3) and a pressure greater than 103 kPa (14.9 psi) shall comply with the requirements of ASME Boiler and Pressure Vessel Code Sections VIII or X,(CSA B51, Part 3).

6.20.8

Fuel containers within the RFA shall not have a settled pressure above the service pressure that is stamped on the container and displayed on a label near the filling connection, corrected for the ambient temperature at the time of filling.

6.20.9

A RFA with gas storage for outdoor use only shall employ:

a) separate automatically operated normally closed valves for each container that will isolate the

contained gas if the emergency shutdown system is engaged or power is lost;

b) a manually operated container valve shall be provided for each storage container;

c) an overpressure protective device as required by the container code of construction shall be

provided for each group of connected containers or single container; and

d) a resettable overpressure protection device shall be installed in the fuel delivery system to prevent

over pressurization of the vehicle.

6.20.13

For outdoor mounted RFA with contained gas, a fire detection methodology must be employed.

Detection of fire or rise in heat shall cause the RFA, at a minimum, to:

a) close all valves to isolate the RFA from the supply source, and vehicle;

b) close all internal electrically operated valves to isolate sub-systems; and

c) give RFA external indication that the unit has detected a fire or rise in heat.

6.20.14

For outdoor mounted RFA, there shall be no greater than 6 GGE of gas contained while the RFA is in dormant or operational mode.

a) There shall be no greater than 3 GGE per single container.

b) All individual containment systems shall employ isolation valves for:

i) system non-operational dormant modes;

ii) emergency isolation operations; and

iii) manually operated isolation valve for maintenance purposes.

c) All containers shall have the means of releasing gas as due to a rise in temperature from an external fire source, via the use of a thermal pressure release device.

7.2.2

Each appliance shall bear a label of Class IIIA marking material located so as to be visible at the time of installation. The label shall exhibit the following statements:

A RFA for outdoor installation only shall bear the following statement: “For outdoor installation only.”

Statement of Problem and Substantiation for Public Input The Residential Fueling Appliances (RFAs) standard, ANSI/CSA NGV 5.1-2016, allows RFAs with a storage system. The NFPA52 should be harmonized with the NGV 5.1 by allowing this feature and adopting the same specifications.


Submitter Full Name: Mario Pirraglia

Organization: SAFE North America

Street Address:

City:

State:

Zip:

Submittal Date: Wed Sep 07 14:02:47 EDT 2016


12.3.6

In a residential installation, RFAs shall not be installed in series or shall not be manifoldedtogether on the discharge side.


This change is needed since installation of RFAs in non-residential settings would not be prohibited by NFPA 52, and a new proposed section (12.4.1.3) would provide specific guidance for installation of RFAs in non-residential occupancies.


Submitter FullName:

Julie Cairns



Street Address:

City:

State:

Zip:




115 of 273 4/18/2017 11:12 AM


12.3.8 RFAs shall not be installed within 10 ft (3.0 m) of any other flammable gas or liquid storage.


This requirement, previously in Chapter 5 for VFAs only, is proposed for RFAs as well. The word ‘other’ is added to clarify that the separation distance is applicable to flammable gas and liquids not being handled by the appliance.


Submitter FullName:

Julie Cairns



Street Address:

City:

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Zip:




116 of 273 4/18/2017 11:12 AM


12.4.1.3

An appliance listed to CSA/ANSI NGV 5.1 (RFA) may also be installed in a nonresidentialsetting and according to its manufacturer installation instructions. An RFA installed in anon-residential setting shall be exempt from the requirements of Sections 4.2, 5.2.1.1.1 through5.2.1.1.5, 9.3.1 and 9.3.2, 10.3.1.1 through 10.3.1.5, 11.3.1, 11.3.2.2, 11.3.2.4, 11.3.2.6,11.3.2.10, 11.3.2.11, 11.3.2.13 through 11.3.2.17, 11.3.6.2.2, 14.4.2.2 through 14.4.2.6, 14.4.2.8.


This coverage of exemptions applies to non-residential installations of RFAs and mirrors the exemptions already provided for VFAs. As such, it accompanies other proposals and default interpretation of NFPA 52 that allow RFA installation in non-residential occupancies, subject to requirements that parallel VFA requirements, where appropriate.


Submitter FullName:

Julie Cairns



Street Address:

City:

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Zip:




117 of 273 4/18/2017 11:12 AM


12.8.1

All piping and hose from the outlet of the compressor shall be supplied as part of the RFA.


Details of the piping and hose are covered in the CSA NGV 5.1 – 2106 listing standard and are part of the overall certification of the appliance. NGV 5.1 also requires that the installation of piping and hoses must be done to manufacturers written instructions,


Submitter FullName:

Julie Cairns



Street Address:

City:

State:

Zip:




118 of 273 4/18/2017 11:12 AM


12.8.3

The use of hose in an installation shall be restricted to the following:

(1) A fueling hose limited to a maximum length of 25 ft (7.6 m) and supported above thefloor/ground level or otherwise protected from mechanical damage from abrasion andbeing driven over by a vehicle

(2) A maximum of 3 ft (1 m) in length where used to prevent abrasion damage resulting fromvibration on the inlet or outlet, or both


Details of the RFA hose(s) are covered in the CSA NGV 5.1 – 2106 listing standard and are part of the overall certification of the appliance. NGV 5.1 also requires that the installation of piping and hoses must be done to manufacturers written instructions.


Submitter FullName:

Julie Cairns



Street Address:

City:

State:

Zip:




119 of 273 4/18/2017 11:12 AM


12.8.4

Transfer systems shall be capable of depressurizing to facilitate disconnection.


This subject is covered in the CSA NGV 5.1 – 2106 listing standard and are part of the overall certification of the appliance.


Submitter FullName:

Julie Cairns



Street Address:

City:

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120 of 273 4/18/2017 11:12 AM


12.10 Installation of Emergency Shutdown Equipment.

12.10.1

An RFA shall be equipped with emergency manual shutdown of the gas supply and electricpower.

12.10.1.1

The emergency electrical switch shall be at least 5 ft (1.5 m) from the RFA and in view of theRFA.

12.10.1.2

An RFA equipped with a flexible cord terminated with a grounding-type attachment plug shallbe deemed to be equivalent to the emergency switch.

12.10.2

Breakaway protection shall be provided in a manner so that, in the event of a pullaway, naturalgas ceases to flow.

12.10.3

The breakaway devices shall be compatible with ANSI/IAS NGV 4.4, Breakaway Devices forNatural Gas Dispensing Hoses and Systems , and CSA 12.54, Breakaway Devices forDispensing Systems .

12.10.4

A breakaway device shall be installed at every dispensing point.

12.10.5

The breakaway device in 12.10.4 shall be arranged to separate using a force not greater than150 lb (68 kg) when applied in any horizontal direction.


Installation of Emergency Shutdown Equipment is covered in the CSA NGV 5.1 – 2106 listing standard and is part of the overall certification of the appliance.


Submitter FullName:

Julie Cairns



Street Address:

City:

State:



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122 of 273 4/18/2017 11:12 AM


Chapter 13

Non-Residential CNG Fueling Appliances



Chapter_13_Proposal_-12-14-2016.docx

New - Chapter 13 Non-Residential CNG Fueling Appliances


This new chapter (and subsequent renumbering of the current succeeding chapters beginning with “Chapter 13 LNG Fueling”) includes reorganization of VFA coverage from the current Chapter 11, provides additional coverage that is consistent (where appropriate) with RFA coverage in Chapter 12, and provides some additional requirements associated with VFA designs.



Public Input No. 111-NFPA 52-2016 [Section No. 3.3.54] Related to new Chapter

Public Input No. 113-NFPA 52-2016 [Section No. 5.2.1.1.7] Related to new Chapter

Public Input No. 114-NFPA 52-2016 [Section No. 11.1] Related to new Chapter

Public Input No. 115-NFPA 52-2016 [Section No. 11.3.3.1.1] Related to new Chapter


Submitter FullName:

Julie Cairns



Street Address:

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State:

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Candidate New NFPA 52 “Chapter 13” Covering VFAs and Accompanying NFPA 52 Section Changes

Link to chapter 13 proposal 3.3.54 5.2.1.1.7 5.2.1.1.7.1 11.1 11.3.3.1.1

jdepew

Sticky Note

attachment to PI 121


Chapter 13 Non‐Residential CNG Fueling Appliances

Rationale: This new chapter (and subsequent renumbering of the current succeeding chapters

beginning with “Chapter 13 LNG Fueling”) includes reorganization of VFA coverage

from the current Chapter 11, provides additional coverage that is consistent (where

appropriate) with RFA coverage in Chapter 12, and provides some additional

requirements associated with VFA designs.

13.1.1 This chapter applies to the installation and operation of a vehicle fueling appliance (VFA)

listed to CSA/ANSI NGV 5.2/12.6 or its equivalent and to RFAs installed at non‐residential

occupancies.

Rationale: This scoping statement is drafted to be consistent with Section 12.1.1., which covers

listed RFAs but omits old text covering “design and construction” since these issues

are specifically covered by CSA/ANSI NGV 5.2/12.6

13.1.2 VFAs shall not exceed the following flow rates:

A. For VFAs listed for indoor installation or indoor fueling, inlet flow rates shall not exceed 5.0 SCF/min (8.5 SCFH).

B. For VFAs listed for outdoor installation and outdoor fueling, inlet flow rates shall not exceed 10 SCF/min (0.28 SCM/min).

Rationale: Inlet flow rate restrictions are consistent with CSA/ANSI NGV 5.2/12.6 for

indoor and outdoor installation and use. The values for flow rate have not changed since they are based upon NFPA 52 previous editions and since the original flow rate justification team, which developed the NGV 5.1 flow rate limitations, also concluded to retain these flow rates. Sources: “NGV 5.1 Flow Rate Working Group Report,” and “NGV 5.2 Storage Justification Document (ref. reqd.).”

13.1.3 VFAs shall be listed to CSA/ANSI NGV 5.2/12.6 or its equivalent and installed in accordance with their listing and installation instructions. Alternatively, RFAs listed to CSA/ANSI NGV 5.1 or its equivalent may be installed at non‐residential occupancies. Rationale: Listing is an essential requirement for technical requirements for design,

construction, and installation where mandatory installation instructions apply. CSA NGV 5.2/12.6 is currently the only relevant standard for VFAs, but the language does not prohibit recognition of “equivalent” listings as determined by the AHJ. Basic installation requirements refer to the installation instructions including mandatory instructions required as part of their listing.


13.1.4 System components not part of a listed VFA shall comply with the appropriate provisions in Chapter 8 and 11. Rationale: This language is pulled from current 12.2.1 for RFAs and has been changed to VFA

because it is important to give an AHJ this guidance for how to assess components outside the purview of the listing standard for the VFA.

13.1.5 The installation of VFAs listed to CSA/ANSI NGV 5.2/12.6 which do not contain more than 9.0 SCF (0.25 SCM) of gas shall be exempt from the requirements of Sections 4.2, 5.2.1.1.1 through 5.2.1.1.5, 9.3.1 and 9.3.2, 10.3.1.1 through 10.3.1.5, 11.3.1, 11.3.2.2, 11.3.2.4, 11.3.2.6, 11.3.2.10, 11.3.2.11, 11.3.2.13 through 11.3.2.17, 11.3.6.2.2, 14.4.2.2 through 14.4.2.6, 14.4.2.8. Rationale: These exemptions are pulled over verbatim to the new chapter from 11.3.3.1.1.3

and apply to VFA’s with internal storage that does not exceed the NGV 5.1 limits of 9.0 SCF.

13.1.6 The installation of VFAs listed to CSA/ANSI NGV 5.2 which contain more than 9.0 SCF (0.25 SCM) of gas shall be exempt from the requirements of Sections 4.2, 11.3.1, 11.3.2.2, 11.3.2.4, 11.3.2.6, 11.3.2.10, 11.3.2.11, 11.3.2.13 through 11.3.2.17, 11.3.6.2.2, 14.4.2.2 through 14.4.2.6, 14.4.2.8. Rationale: These exemptions are pulled over verbatim to the new chapter from 11.3.3.1.1.3

with the exception of 5.2.1.1.1 through 5.2.1.1.5, 9.3.1 and 9.3.2 which do not apply to VFA’s with internal storage that exceeds the NGV 5.1 limits of 9.0 SCF. Also, 10.3.1.1‐10.1.1.5 do not apply since these are exemptions for indoor installations, and since VFAs with internal storage over 9.0 SCF are not allowed for installation indoors, these sections are not applicable.

13.1.7 VFAs shall not be installed at residential occupancies. Rationale: This text originates from 11.3.3.1.1 but is stipulated as a restriction on installation in

associated with residential occupancies. 13.1.8 Where more than one VFA is located in a common area, spacing between the VFAs shall not be less than 3 ft. (1 m) unless permitted by the installation instructions. VFAs shall not be installed in series. VFAs may be manifolded together on the discharge side unless prohibited by the installation instructions.


Rationale: The language in the first 2 sentences is pulled from current 12.3.7 for RFAs. The

CSA/ANSI NGV 5.2/12.6 listing standard allows for manifolding the discharge of VFAs just as NFPA 52 has always allowed it for non‐residential installations.

13.1.9 VFAs shall not be installed within 10 ft. (3.0 m) of any other flammable gas or liquid storage.

(A) Storage in the vehicle fuel supply container is not considered in this restriction. (B) Gas contained within the VFA for outdoor installation is not considered in this restriction.

Rationale: This requirement originates from 11.3.3.1.1.6 and includes the proposed clarifying

term ‘other’ to delineate storage not serving the VFA. 13.1.10 Where installed indoors in public assembly and educational occupancies, a VFA shall be located in a portion of the occupancy where NFPA 101 or the local building code permits the installation of hazardous equipment.

(A) Where the VFA is located outdoors, the dispensing point shall be permitted to be located indoors without the need for a separate room.

Rationale: Section 13.1.6 and (A) are pulled over verbatim to the new chapter from 11.3.3.1.1.7. 13.1.11 VFAs shall be permitted to be used to fill stationary containers and to be connected to dispensing equipment at vehicle fueling locations.

(A) The method of connecting the VFA to such storage and dispens ing equipment shall comply with the provisions of Chapters 5, 8, and 7 and shall be approved.

(B) The design, siting and installation of such storage shall comply with the provisions of Chapter 8 and 9.

(C) 13.1.4 shall apply to the VFA when connected to stationary containers at vehicle fueling locations

(D) The exemptions contained in 13.1.4 shall not apply to the stationary containers and dispensing equipment.

Rationale: This text has been incorporated from current Chapter 11 coverage of VFAs. An

additional statements regarding storage requirements associated with this new chapter (and requirements of CSA NGV 5.2/12.6), dispensing equipment, and treatment of exemptions are added.

13.1.12 Containers used in a VFA shall comply by design with one of the following, as

applicable:


13.1.14 Where the VFA or the vehicle being fueled is located indoors, a gas detector set to operate at one‐fifth the lower flammable limit (LFL) of natural gas shall be installed in the room.

A. U.S. Department of Transportation (DOT) or Transport Canada (TC) regulations, exemptions, or

special permits;

B. CSA B51, Part 3;

C. ASME Boiler and Pressure Vessel Code Sections VIII or X; or

D. CSA/ANSI NGV 2.

Inspection requirements for any container shall be per the applicable container design standard.

Rationale: The language is added to allow for, and match, the storage technologies included in CSA/ANSI NGV 5.1 and draft CSA NGV 5.2/12.6.

13.1.13 VFA Storage Limits. 13.1.13.1 VFAs Installed Indoors. Storage contained within a VFA listed to CSA/ANSI NGV 5.2/12.6 shall not exceed 9.0 SCF (0.25 SCM) per every 28.3 m3 (1,000 ft3) of contiguous building volume of non‐residential buildings. For contiguous building volumes exceeding 28.3 m3 (1,000 ft3), one combustible gas detector shall be mounted on the VFA and additional gas detection shall be installed in proximity to the VFA and located in accordance with good engineering practice. Rationale: The hazard analyses performed (See the CSA/NGV 5.2/12.6 Storage Limit Justification document) limited the volume of onboard internal gas for an indoor mounted unit, based on the volume of the garage and based on the reaction time of a gas detector to sense a leak and thus preclude buildup of leaked gas. Thus, since these CSA/NGV 5.2/12.6 units are non‐residential, and since they could be installed inside an interior commercial garage, arena, etc. then the limitation should be proportionally based on the volume of the space and the ability of the unit to detect and react to a potential leak. See the CSA NGV 5.2/12.6 Storage Limit Justification document. NFPA 52 gas detection requirements language has been incorporated. 13.1.13.2 VFAs Installed Outdoors. Storage contained within a VFA listed to CSA/ANSI NGV 5.2/12.6 shall not exceed 3,000 SCF (85 SCM) total volume and:

A. Shall not contain gas at pressure above the VFA’s outlet service pressure rating, and B. Shall have no single container with capacity more than 750 SCF (21.3 SCM).

Rationale: The CSA/NGV 5.2/12.6 Storage Working Group developed this language and included it in NGV 5.2 based on guidance found in NFPA 55. In addition, a distinction between VFAs with more than 9 SCF of storage has been made with respect to installation and siting requirements that require them to follow NFPA 52 requirements of Chapter 8.


The gas detector shall be located and installed in accordance with manufacturers’ installation instructions and good engineering practices. Rationale: The objective of this requirement is to meet the minimum protections provided by

the CSA/ANSI NGV 5.1 and 5.2 standards. 13.2 Installation 13.2.1 All VFA equipment shall be installed in accordance with the equipment manufacturer’s instructions. 13.2.2 All equipment related to a VFA installation shall be protected to minimize the possibility of physical damage and vandalism. 13.2.3 The VFA shall be installed on a firm noncombustible support to prevent undue stress on piping and conduit. 13.2.4 All gas piping to the VFA shall be installed in accordance with NFPA 54 and manufacturer’s installation instructions. 13.2.5 All piping and tubing to the VFA shall be tested after installation to be proven free of leaks at a pressure equal to the maximum operating pressure of that portion of the system. 13.2.6 When a VFA is installed indoors the unit shall be mounted or otherwise located such that the unit is vented to the outdoors. 13.2.7 PRVs shall have PRD vents or vent lines to convey escaping gas to the outdoors and then upward to prevent impinging on buildings, other equipment, or areas open to the public (e.g., sidewalks). 13.2.8 An electrical disconnection means shall be provided at least 5 ft. (1.5 m) from the VFA and in view of the VFA. Rationale: This Installation language is in the Chapter 12 for RFAs and is good guidance for VFAs

as well in this new Chapter 13. 13.3 Operation 13.3.1 A VFA shall be operated in accordance with the manufacturer’s instructions. 13.3.2 Where CNG is being transferred to a motor vehicle, the engine shall be turned off.


Rationale: This Operations language is in the Chapter 12 for RFAs and is good guidance for VFAs

as well in this new Chapter 13. 13.4 Maintenance and Inspection. 13.4.1 All VFA equipment shall be inspected and maintained in accordance with the manufacturer's instructions. 13.4.2 After installation, all hose shall be examined visually as part of this inspection. 13.4.3 Hose that are kinked or worn shall be replaced. 13.4.4 All safety relief valves shall be maintained in operating condition in accordance with the manufacturer’s/supplier’s recommendation. Rationale: This Maintenance and Inspection language is in the Chapter 12 for RFAs and is good

guidance for VFAs as well in this new Chapter 13.


13.3.2.1 Design and Construction of Containers, Cylinders and Stationary Tanks.

See Chapter 16.


Title needs to clarify that these containers are stationary.

Title cannot reference cylinders with the current definition 3.3.16 of cylinder:3.3.16 Cylinder. A container constructed, inspected, and maintained in accordance with DOT and Transport Canada regulations or ANSI NGV 2, Compressed Natural Gas Vehicle (NGV) Fuel Containers.

Chapter 16 is for installation requirement for ASME Tanks




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13.3.2.13

Control systems that are used as part of the fire protection system at the LNG plant shall beinspected and tested in accordance with the applicable fire codes and standards and conform tothe following criteria:

(1) Monitoring equipment shall be maintained in accordance with NFPA 72 and NFPA 1221.

(2) Fire protection water systems, if required, shall be maintained in accordance withNFPA 13, NFPA 14, NFPA 15, NFPA 20, NFPA 22, NFPA 24, and NFPA 25.

(3) Portable or wheeled fire extinguishers suitable for gas fires, preferably of of thedry-chemical type, shall be available at strategic locations, as determined in accordancewith Chapter 13, within an LNG facility and on tank vehicles and shall be maintained inaccordance with NFPA 10.

(4) Fixed fire extinguishers and other fire-control systems that are installed shall bemaintained in accordance with NFPA 11, NFPA 12, NFPA 12A, NFPA 16, and NFPA 17.[59A:13.18.4.5 (C)]


Recommend deletion of unenforceable text.


Submitter Full Name: Jennifer Boyle

Organization: FEMA

Affilliation: FEMA

Street Address:

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13.5.1.2

Underground LNG tanks shall be installed in accordance with Table 13.5.1.2. [ 59A : 13.6.3]

Table 13.5.1.2 Distances from Underground Containers and Exposures

(See Attached Public Comment #14)

[ 59A : Table 13.6.3]

The distances for underground storage tanks should be revised to 2-3 foot spacing instead of 15foot.



Public_Comment_14_-_Hold.pdf NFPA 52 - PC#14



LNG Underground storage tank separation distance should be changed to 2-3 foot so as to keep all of the tanks in a 2 or 3 tank arrangement in the same common tank pit or "battery" this is standard within the petroleum industry.

NFPA 30-12.3.5 Horizontal separation shall not be required between aboveground tanks storing CNG, LNG, or LP-Gas and underground tanks containing Class I or Class II liquids, providedthe structural limitations of the underground tanks are not exceeded.

See Typical UST table for Diesel, Gasoline and DEF

4', 6', 8' Diameter TanksMinimum w/ 12" x 12" CSI DeadmenA 18" (457mm) 24" (610mm) B 18" (457mm) 24" (610mm)10' Diameter TanksMinimum w/ 18" x 8" CSI DeadmenA 18" (457mm) 36" (914mm) B 24" (610mm) 24" (610mm)12' Diameter TanksMinimum w/ 18" x 8" DeadmenA 24" (610mm) 36" (914mm) B 24" (610mm) 24" (610mm)



Organization: NFPA

Street Address:

City:



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p




127 of 273 4/18/2017 11:12 AM

Public Comment No. 14-NFPA 52-2014 [ Section No. 13.5.1.2 ]

13.5.1.2

Underground LNG tanks shall be installed in accordance with Table 13.5.1.2. [59A:13.6.3]

Table 13.5.1.2 Distances from Underground Containers and Exposures

Container WaterCapacity

Minimum Distance from Buildings and theAdjoining Property Line That Can Be Built Upon

Distance BetweenContainers

gal m 3 ft m ft m

<18,000 <15.8 15 4.6 15 4.6

18,000–30,000 15.8–114 25 7.6 15 4.6

30,001–100,000 >114 40 12.2 15 4.6

[59A: Table 13.6.3]

The distances for underground storage tanks should be revised to 2-3 foot spacing instead of 15 foot.


LNG Underground storage tank separation distance should be changed to 2-3 foot so as to keep all of the tanks in a 2 or 3 tank arrangement in the same common tank pit or "battery" this is standard within the petroleum industry.

NFPA 30-12.3.5 Horizontal separation shall not be required betweenaboveground tanks storing CNG, LNG, or LP-Gas and undergroundtanks containing Class I or Class II liquids, providedthe structural limitations of the underground tanks are notexceeded.

See Typical UST table for Diesel, Gasoline and DEF

4', 6', 8' Diameter TanksMinimum w/ 12" x 12" CSI DeadmenA 18" (457mm) 24" (610mm)B 18" (457mm) 24" (610mm)10' Diameter TanksMinimum w/ 18" x 8" CSI DeadmenA 18" (457mm) 36" (914mm)B 24" (610mm) 24" (610mm)12' Diameter TanksMinimum w/ 18" x 8" DeadmenA 24" (610mm) 36" (914mm)B 24" (610mm) 24" (610mm)

Related Item



Submitter Full Name: Jim Ames

Organization: Blu Transfuels LLC

Affilliation: Transfuels LLC

Street Address:

City:


1 of 2 8/18/2016 1:09 PM

jdepew

Sticky Note

attachment to PI 31

State:

Zip:

Submittal Date: Thu Nov 06 10:46:50 EST 2014

Committee Statement

CommitteeAction:

Rejected but held

Resolution: This material is being held until the next revision cycle to allow further development andsubstantiation.


I, Jim Ames, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this PublicComment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire norights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative formis used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyrightassignment.

By checking this box I affirm that I am Jim Ames, and I agree to be legally bound by the above Copyright Assignment and the terms andconditions 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


2 of 2 8/18/2016 1:09 PM


14.2 Application.

CNGP CNG and LNG equipment used shall be in accordance with Section 14.3 and the fuelspecific sections of 14.4 or 14.5 as applicable. Where there is a conflict between generalrequirements and fuel specific requirements, the fuel specific requirements shall apply.


The abbreviation CNGP – should just be CNG.


Submitter FullName:

Julie Cairns


Affilliation:CSA Group NGV 6.1 Compressed Natural Gas (CNG) FuelSystems Technical Subcommittee and the B109 Natural Gasfor Vehicles Installation Code Technical Subcommittee

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Submittal Date: Tue Dec 13 14:27:34 EST 2016



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14.3.2.1 OEM Approved Equipment.

The following CNG and LNG fuel supply subsystems and components, if used, shall berecommended by the original equipment manufacturer (OEM) for the intended service and shallbe listed or approved:

(1) Vehicle fuel Fuel supply containers

(2) Fuel quantity gauging systems

(3) Pressure relief devices, including pressure relief valves

(4) Pressure measurement devices

(5) Pressure regulators

(6) Valves

(7) Hose and hose connections

(8) Vehicle fueling connections (nozzle)

(9) Vaporizers

(10) Pumps

(11) Electrical equipment related to engine fuel systems

(12) Gas detection equipment and alarms

(13) Fire protection and suppression equipment


Consistency throughout document.





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14.4.1

All Components for CNG fueled vehicles, where stored CNG is used as the fuel for propulsionshall meet the requirements of CSA NGV 6.1. Clause 14.4.2 thru 14.4.3.8.5 of NFPA 52 are notapplicable for CNG vehicles in compliance with CSA NGV 6.1.


NGV 6.1 was requested by industry to provide a more in depth holistic approach to CNG system design. By using system engineering practices, the NGV 6.1 document covers both the component and interaction of components. The NGV 6.1 technical subcommittee utilized an FMEA approach in developing the performance based safety requirements, as well as providing guidance for the overall design of the system and vehicle integration. By referencing the NGV 6.1 document for CNG engine fuel system requirements, it allows the NFPA 52 Committee to focus on other areas of the document, specifically infrastructure requirements. It will also alleviate confusion between the gaseous portions of LNG systems and straight CNG systems.

(NOTE: Section numbers in the proposed language reflect new section numbers with inclusion of this proposal)



Public Input No. 149-NFPA 52-2016 [New Section after 15.3.1.1]


Submitter FullName:

Julie Cairns



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14.3.3.2 PRVs

Pressure relief valves (PRVs) shall not be fitted with lifting devices.






This text is moved from 14.4.2.2.2.2 and modified to not specifically only address PRVs for CNG service

1) 14.4.2.2 is specific to container Pressure Relief Devices (PRDs) rather than PRVs.Note the definitions in NFPA 52:• 3.3.17.3 Pressure Relief Device (PRD). A device that, when activated under specified performance conditions, is used to vent the container contents.• 3.3.17.4 Pressure Relief Valve (PRV) A reclosing device that opens to relieve pressure at the set pressure.

2) This clause was moved to 14.3 General because PRVs are also applicable to the LNG fuel system – there are PRVs on the LNG tanks (recall that the LNG fuel system includes any components handling LNG or LNG vapor)




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14.3.3.1 Pressure Gauges.

A pressure gauge, if provided, shall be capable of reading at least 1.2 times the maximumallowable working pressure for the dispensing station or 1.2 × 1.25 times the service pressurefor the vehicle.


Delete entire clause. Requirement is identically already found in 14.4.2.3, specific to the CNG fuel system, which is correct since this requirement does not pertain to an LNG fuel system (service pressure is not applicable). The pressure gauge requirements for an LNG fuel system are specified in 14.5.3.8.1 (see below):

“14.5.3.8.1 Pressure gauges shall be designed for the maximum pressure and temperature conditions to which they can be subjected, with a minimum burst pressure safety factor of 4.”




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14.4.1 Application.

This section applies only to pressurized system components handling CNG.

General Comment: As written 14.4 applies to the CNG portion of an LNG vehicle("pressurized system components handling CNG"), even though the wording often does notwork as such. Also, components that touch LNG vapor do not explicitly currently fall under thescope of any of the NFPA 52 sections (not pressurized CNG and not technically LNG).

The scope in 14.4.1 should be clarified if it was only intended for CNG vehicles. In that case aseparate section could be inserted written for the CNG portion of an LNG vehicle. Alternatively,wording for each clause can be revised as appropriate, to accomodate both CNG and LNGvehicles. However, due to the design and operating differences between the CNG system on aCNG vehicle and the CNG system on an LNG vehicle Westport recommends instead anotheralternative: create a separate chapter for CNG vehicle requirements and a separate chapterfor LNG vehicle requirements (which will include CNG components, LNG components, LNGvapor components). Note that this last alternative was proposed by Westport as a separateglobal comment.


As written 14.4 applies to the CNG portion of an LNG vehicle ("pressurized system components handling CNG"), even though the wording often does not work as such. Also, components that touch LNG vapor do not explicitly currently fall under the scope of any of the NFPA 52 sections (not pressurized CNG and not technically LNG).The scope in 14.4.1 should be clarified if it was only intended for CNG vehicles. In that case a separate section could be inserted written for the CNG portion of an LNG vehicle. Alternatively, wording for each clause can be revised as appropriate, to accomodate both CNG and LNG vehicles. However, due to the design and operating differences between the CNG system on a CNG vehicle and the CNG system on an LNG vehicle Westport recommends instead another alternative: create a separate chapter for CNG vehicle requirements and a separate chapter for LNG vehicle requirements (which will include CNG components, LNG components, LNG vapor components). Note that this last alternative was proposed by Westport as a separate global comment.




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Public Input No. 190-NFPA 52-2017 [ Section No. 14.4.2.1 ] 14.4.2.1* Design and Construction of CNG Containers. 14.4.2.1.1 Containers shall be fabricated of steel, aluminum, or composite materials. 14.4.2.1.2 The container shall be designed for CNG service. 14.4.2.1.3 The container shall be permanently marked “CNG” by the manufacturer. 14.4.2.1.4 Containers manufactured prior to the effective date of this code shall be permitted to be used in CNG service if recommended for CNG service by the container manufacturer or if approved by the authority having jurisdiction. 14.4.2.1.5* Cylinders. 14.4.2.1.5.1 Cylinders shall be manufactured in accordance with both of the following:

(1) ANSI NGV 2, Compressed Natural Gas Vehicle (NGV) Fuel Containers, specifically for CNG service

(2) U.S. Federal Motor Vehicle Safety Standard, 49 CFR 571.304, Compressed Natural Gas Fuel Container Integrity

14.4.2.1.5.2 Cylinders that have reached the labeled expiration date shall be removed from service. Cylinders that are disconnected, depressurized, and permanently disabled shall be permitted to be left on the vehicle. 14.4.2.1.5.3* Composite reinforced cylinders or other cylinders marked with exemption or special permit numbers shall be removed from service. 14.4.2.1.6 ASME Compliance. 14.4.2.1.6.1 Pressure vessels shall be manufactured, inspected, marked, and tested in accordance with ASME Boiler and Pressure Vessel Code, Section VIII or Section X. 14.4.2.1.6.2 Adherence to applicable ASME Boiler and Pressure Vessel Code case interpretations and addenda shall be considered as compliant with the ASME Boiler and Pressure Vessel Code. 14.4.2.1.6.3* Pressure vessels manufactured to the requirements of the ASME Boiler and Pressure Vessel Code shall be registered with the National Board of Boiler and Pressure Vessel Inspectors. 14.4.2.1.6.4 The repair or alteration of an ASME pressure vessel shall comply with the requirements of NB-23, National Board Inspection Code. 14.4.2.1.6.5 Other welding or brazing shall be permitted only on saddle plates, lugs, or brackets attached to the pressure vessel by the pressure vessel manufacturer. 14.4.2.1.6.6 The exchange or interchange of pressure vessel appurtenances intended for the same purpose shall not be considered a repair or alteration.

Statement of Problem and Substantiation for Public Input Clarity, since 14.4 is also applicable to the CNG subsystem and components of an LNG vehicle.




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A discussion is required on intent of this clause. The clause needs to be reworked onceintent is clarified. Is this clause referring to ANY CNG cylinder or only the fuel supplycontainer?

Recommended Modified Text: Recommend to change the requirement to be specificto the fuel supply container only since requirements of any cylinder are (or should be)already contained in the cylinder definition:

14.4.2.1.5.1

Cylinders The fuel supply container shall be manufactured in accordance with both of thefollowing:

(1) ANSI NGV 2, Compressed Natural Gas Vehicle (NGV) Fuel Containers, specifically forCNG service

(2) U.S. Federal Motor Vehicle Safety Standard, 49 CFR 571.304, Compressed Natural GasFuel Container Integrity


There may be other CNG cylinders on a vehicle outside the fuel supply. NGV 2 and FMVSS 304 are specific to fuel supply containers only.Original 2013 text appears to be written to accommodate any cylinder (includes general DOT/TC regulations and CSA B51).




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14.4.2.1.5.1

Cylinders shall be manufactured in accordance with both of the following:

(1) ANSI NGV 2, Compressed Natural Gas Vehicle (NGV) Fuel Containers, specifically forCNG service

(2) U.S. Federal Motor Vehicle Safety Standard, 49 CFR 571.304, Compressed Natural GasFuel Container Integrity

Cylinders shall be manufactured in accordance with ANSI NGV-2, Compressed Natural GasVehicle (NGV) Fuel Containers , specifically for CNG service or U.S. Federal Motor VehicleSafety Standaerd, 49 CFR 571.304, Compressed Natural Gas Fuel Container Integrity .


NFPA 52 is adopted as law in many jurisdictions across the country. This section could usurp NHTSA's regulatory authority if ANSI NGV-2 were to conflict with FMVSS 304. NHTSA is an unbiased agency to promote public safety interests. ANSI NGV is a voluntary, industry driven organization with members many of whom have vested commercial interest in the regulatory content.

Further, there is a conflict with Section 3.3.16 and this section. Section 3.3.16 indicates the cylinder is constructed ...with US DOT and TC regulations OR ANSI NGV-2 verses BOTH in Section 14.4.2.1.5.2.


Submitter Full Name: William McGlinchey

Organization: AFV International

Affilliation: President

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Submittal Date: Thu Jan 05 10:54:26 EST 2017



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14.4.2.1.5.2

Cylinders that have reached the labeled expiration date shall be removed from service.Cylinders that are disconnected, depressurized, and permanently disabled shall be permitted tobe left on the vehicle.

Note: For detailed instruction, procedures and information refer to CSA EXP 2.1-16 Bestpractice for defueling, decommissioning, and disposal of compressed natural gas vehicle fuelcontainers.


This clause talks about depressurizing, removal, and disabling of the cylinder. Because CSA Group has recently published a new document specifically addressing these items, we suggest adding a note after the clause referencing CSA EXP2.1 for added guidance


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Julie Cairns



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14.4.2.1.6 ASME Compliance.

14.4.2.1.6.1

Pressure vessels shall be manufactured, inspected, marked, and tested in accordance withASME Boiler and Pressure Vessel Code , Section VIII or Section X.

14.4.2.1.6.2

Adherence to applicable ASME Boiler and Pressure Vessel Code case interpretations andaddenda shall be considered as compliant with the ASME Boiler and Pressure Vessel Code .

14.4.2.1.6.3 *

Pressure vessels manufactured to the requirements of the ASME Boiler and Pressure VesselCode shall be registered with the National Board of Boiler and Pressure Vessel Inspectors.

14.4.2.1.6.4

The repair or alteration of an ASME pressure vessel shall comply with the requirements ofNB-23, National Board Inspection Code .

14.4.2.1.6.5

Other welding or brazing shall be permitted only on saddle plates, lugs, or brackets attached tothe pressure vessel by the pressure vessel manufacturer.

14.4.2.1.6.6

The exchange or interchange of pressure vessel appurtenances intended for the same purposeshall not be considered a repair or alteration.


Relocate to Chapter 8 Facility Equipment or Chapter 9, Outdoor Storage, or both since Chapter 14 applies to vehicles and the coverage addressed in 14.4.2.1.6 – 14.4.2.1.6.6 addresses ASME pressure vessels that are not permissible on CNG vehicles. The code states that you can only use NGV2 and FMVSS 304 storage containers on CNG vehicles for onboard storage.


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Julie Cairns



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14.4.2.1.6.1


14.4.2.1.6.2


14.4.2.1.6.3 *


14.4.2.1.6.4


14.4.2.1.6.5


14.4.2.1.6.6


Delete entire section and move it into a new general chapter at the beginning of the code.



These requirements need to be moved from 14.4.2.1.6 (and 14.5.3.3.1) and put at a “higher” more general level in the document. Currently there is no “general” chapter at the beginning of the standard so proposing that one be added (this is a separate submitted comment).Without a general chapter that includes these pressure vessel requirements these requirements will need to be copied into every chapter that references pressure vessels and/or ASME compliant containers (essentially every chapter).




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14.4.2.1.6.3*

Pressure vessels manufactured to the requirements of the ASME Boiler and Pressure VesselCode shall be registered with the National Board of Boiler and Pressure Vessel Inspectors, ifrequired by the authority having jurisdiction .


Registration with the National Board of Boiler and Pressure Vessel Inspectors is not a requirement of DOT/TC. It is however a requirement for stationary tanks that fall under different safety authorities/jurisdictions.




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14.4.2.1.6.4

The repair or alteration of an ASME pressure vessel shall comply with the requirements ofNB-23, National Board Inspection Code, or by methods acceptable to the authority havingjurisdiction .


Vehicle fuel tanks do not fall under the National Board Inspection Code but rather under transportation codes. NGV fuel tanks are specialized and their repair and alteration should be managed by the OEM.




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Sub-Sections] ]

Each cylinder complying with 14.4.2.1.4 shall 5 shall be fitted with one or more thermallyactivated pressure relief devices (PRDs) with the number, location, and part number as specifiedby the cylinder manufacturer and shall be marked and certified in accordance with ANSI/CSAPRD 1, Pressure Relief Devices for Natural Gas Vehicle (NGV) Fuel Containers. Containersshall be permitted to be protected using a combination of fire-resistant barriers and PRDs.


Cylinder requirements are found in 14.4.2.1.5. This is the reference given in NFPA 52-2013.




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14.4.2.2.2

Pressure vessels complying with 14 . 4.2.1.5 used for stationary storage without temperaturecompensation of the storage operating pressure shall be protected with one or more spring-loaded pressure relief valves in accordance with the ASME Boiler and Pressure Vessel Code.

14.4.2.2.2.1

The minimum rate of discharge of PRDs on containers shall be in accordance with CGA S-1.3,Pressure Relief Device Standards — Part 3 — Stationary Storage Containers for CompressedGases, or the ASME Boiler and Pressure Vessel Code, whichever is applicable.

14.4.2.2.2.2

Pressure relief valves (PRVs) for CNG service shall not be fitted with external manuallyoperated lifting devices and resealing pressure relief devices should only be used downstreamof the regulator .

(A)

The adjustment, if external, shall be provided with a means for sealing the adjustment toprevent tampering.

(B)

If at any time it is necessary to break such a seal, the valve shall be removed from service untilit has been reset and sealed.

(C)

Adjustments shall be made only by the manufacturer or other companies having competentpersonnel and facilities for the repair, adjustment, and testing of such valves.

(D)

The organization making such adjustments shall attach a permanent tag with the setting,capacity, and date.


14.4.2.2.2 - This clause talks about using NGV 2 and FMVSS 304 containers for stationary storage (Clause 14.4.2.1.5). We believe that this is out of scope for Chapter 14 and should be relocated to a Station Chapter.

14.2.2.2.2 A lifting device is a mechanism that can be actuated, by the use of common tools or by hand, to open a valve and release the upstream pressure. A typical example is in the air-brake system of a truck where there is a lifting device on a valve connected to the air tanks. It allows the driver to release the system pressure when the truck is parked.

The intent in NFPA 52 is to prevent such devices from being used on PRV-s.

The PRV-s are not to be used as valves to drain the system pressure.



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Julie Cairns



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Sub-Sections] ]

Delete clause or move to

Chapter 9 (Outdoor Storage) and Chapter 10 (Indoor Storage) or Chapter 10 only (for example,before 10.3.1.6.2).

If moved must modify text. 14.4.2.1.5 is not the correct reference. The correct reference in the2013 version was to “ASME Compliance” (ref NFPA 52-2013, 5.5.2) which is clause 14.4.2.1.6in the 2016 version.

If kept in the current location it doesn't really add any value because pressure vessels arealready defined as meeting ASME. However, below is the recommended modified text if kept inthe current location:

Pressure vessels complying with 14.4.2.1.5 used for stationary storage without temperaturecompensation of the storage operating pressure shall 6 shall be protected with one or morespring-loaded pressure relief valves in accordance with the ASME Boiler and Pressure VesselCode

Also note that 14 . 4.2.1.6 has been recommended in a separate submitted comment to bemoved into a new general chapter at the beginning of the code. In that case the referenceshould be updated also here.


This clause is specific to stationary storage. It should be moved into Chapter 9 (Outdoor Storage) and Chapter 10 (Indoor Storage) or Chapter 10 only (for example, before 10.3.1.6.2). If moved the language should not reference 14.4.2.1.5 (cylinders) but rather 14.4.2.1.6 (pressure vessels). Note the additional recommendation that has been submitted separately to move 14.4.2.1.6 (pressure vessels) into a high level general chapter at the beginning of the code. In this case the reference in this clause will change from 14.4.2.1.6 to the applicable new "general" clause.




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14.4.2.2.2.1

The minimum rate of discharge of PRDs on containers shall be in accordance with CGAS-1.3, Pressure Relief Device Standards — Part 3 — Stationary Storage Containers forCompressed Gases , or the ASME CGA S-1.2 Pressure Relief Device Standards - Part 2 -Portable Containers for Compressed Gases , CGA S-1.1 Pressure Relief Device Standards -Part 1- Cylinders for Compressed Gases or the ASME Boiler and Pressure Vessel Code ,whichever is applicable.


Allowed alternative CGA standards. This is required since cylinder/container sizes can vary. Also, S 1.3 is for stationary applications rather than for transportation.

Differences: The difference between S 1.1 and 1.2 is the size of the container; S 1.1 and 1.2 are for portable containers rather than stationary.




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14.4.2.2.2.2

Pressure relief valves (PRVs) for CNG service shall not be fitted with lifting devices.

(A)

The adjustment, if external, shall be provided with a means for sealing the adjustment toprevent tampering.

(B)

If at any time it is necessary to break such a seal, the valve shall be removed from service untilit has been reset and sealed.

(C)

Adjustments shall be made only by the manufacturer or other companies having competentpersonnel and facilities for the repair, adjustment, and testing of such valves.

(D)

The organization making such adjustments shall attach a permanent tag with the setting,capacity, and date.

Delete entire clause and move it into 14.3 General , and do not explicitly state for CNGservice since it is specific to both types of vehicles.


1) 14.4.2.2 is specific to container Pressure Relief Devices (PRDs) rather than PRVs.Note the definitions in NFPA 52:• 3.3.17.3 Pressure Relief Device (PRD). A device that, when activated under specified performance conditions, is used to vent the container contents.• 3.3.17.4 Pressure Relief Valve (PRV) A reclosing device that opens to relieve pressure at the set pressure

2) This clause should be moved to 14.3 (General) because PRVs are also applicable to the LNG fuel system – there are PRVs on the LNG tanks (recall that the LNG fuel system includes any components handling LNG or LNG vapor)




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A pressure gauge, if provided, shall be capable of reading at least 1.2 times the maximumallowable working pressure for the dispensing station or 1.2 × 1.25 times the service pressurefor the vehicle .


Deleted the first part in regards to the dispensing station since Chapter 14 is for Automotive Equipment (Onboard). The first part can be moved into the dispensing section.




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A pressure gauge, if provided, shall be capable of reading at least 1.2 times the maximumallowable working pressure for the dispensing station or

1) for a CNG vehicle, 1.2 × 1.25 times the service pressure

2) for the CNG fuel system of an LNG vehicle, at least 1 .2 times the maximum allowableworking pressure


1) First part of the requirement should be moved to the dispenser portion of the code - submitted as a separate commentDispenser station requirements are not appropriate for this automotive section.

2) Modified language to suit CNG fuel system of an LNG vehicle• Service pressure does not work for the CNG fuel system of an LNG vehicle.

3) Still need to discuss appropriate level for the CNG portion of the LNG vehicle (1.2 X, 4X). Recommended text is based on the definition of overpressure in 3.3.44:3.3.44 Overpressure. The pressure in a blast wave above atmospheric pressure, a pressure within a containment structure that exceeds the maximum allowable working pressure of the containment structure, or 1.25 times the service pressure of the CNG vehicle component upstream of the first stage of pressure regulation.Or, should the level be 4X to match that required of the regulator and shut off valves (ref 14.4.2.4 and 14.4.2.6.1.2)?




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14.4.2.4 Pressure Regulators.

A 14.4.2.4.1 A pressure regulator inlet and each chamber shall be designed for its operatingpressure with a pressure safety factor of at least four times the operating pressure of thedispensing station.

14.4.2.4.1 2

Low-pressure chambers shall provide for overpressure relief or be able to withstand the servicepressure of the upstream pressure chamber.

14.4.2.4.2 3

A vehicle pressure regulator shall comply with the requirements in 14.4.2.4.1 and 14.4.2.4.2 orANSI NGV 3.1.


Original text and numbering create a circular reference. The original 14.4.2.4.2 requires the regulator to either comply with 14.4.2.4 or NGV 3.1 but its own clause number (14.4.2.4.2) is part of 14.4.2.4




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Sub-Sections] ]

A pressure regulator inlet and each chamber shall be designed for its operating pressure with apressure safety factor of at least four times the operating pressure of the dispensing station.


Dispenser station requirements are not appropriate for this automotive section.Recommended text is the original 2013 version text which is more appropriate and accurate.




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14.4.2.4.1

Low-pressure chambers shall provide for overpressure relief or

If the regulator is not fitted with an integral relief system, a pressure relief valve shall be fitted onthe regulated side or all chambers shall be able to withstand the

service pressureMAWP of the upstream pressure

chamber.source


Original text doesn’t work for a CNG fuel system of an LNG vehicle.Current text from CSA B109 Part 2 (LNG vehicles), 5.15.3: - "If the regulator is not fitted with an integral relief system, a pressure relief valve shall be fitted on the regulated side"Current text from CSA B109 Part 1 (CNG vehicles), 5.6.7.3:- "If a regulator is not fitted with an integral relief system, a pressure relief valve shall be fitted on the regulated side of the first stage of the regulator or installed in the test port of the regulated first stage chamber."

Allows for the option to design a high pressure rated component rather than introduce pressure relief




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14.4.2.5.4

Natural gas piping shall be fabricated and tested in accordance with ANSI/ASME B31.3,Process Piping,

ANSI NGV 3 . 1 Fuel system components for compressed natural gas powered vehicles oranother code acceptable to the authority having jurisdiction.


B31.3 is for process plant piping. It is not applicable to vehicle fuel lines.




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14.4.2.5.5

The A CNG refueling connection shall be permitted to be made of nonsparking wroughtaluminum alloy designed for the pressure employed.


Clarity – clearer to read since this section is also applicable to the CNG fuel system of an LNG vehicle.




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14.4.2.5.6

Aluminum pipe, tubing, and fittings shall be permitted to be used downstream of the first-stagepressure regulator in an a CNG vehicle engine fuel system.


"downstream of the first-stage pressure regulator" is specific to a CNG vehicle.




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14.4.2.6.1.1

Shutoff valves for dispensing stations shall have a rated maximum allowable working pressurenot less than the rated operating pressure of the system and shall be capable of withstanding ahydrostatic test of at least four times the rated operating pressure without rupture.


Clause 14.4.2.6.1.1 is for shutoff valves for dispenser stations and should be relocated to the station Chapter.


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Julie Cairns



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14.4.2.6.1.1



Delete entire clause since it is applicable to dispensing.




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14.4.2.6.1.1



Deleted since applicable to dispensing.




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14.4.2.6.1.2

Shutoff valves for vehicles CNG fuel container shutoff valves shall have a service pressure notless than the service pressure of the fuel container and shall be capable of withstanding ahydrostatic test of at least four times the operating pressure (1.25 times the service pressure)overpressure or shall comply with the requirements in ANSI NGV ? 3.1.


1. Clarified that the clause is specifically for CNG fuel container shut off valves. (Service pressure is not applicable to LNG tanks and original language doesn’t work for the CNG portion of an LNG vehicle where MAWP is more appropriate and shutoff valves can be located anywhere in the CNG system – ie HPDI has an automatic shut off valve in the engine at high pressure).

2. Test pressure is unclear. Recommended text modifies “operating pressure” to “overpressure”: • Is the original text defining operating pressure as 1.25 x service pressure? If so, this is not accurate per the definition of operating pressure. In fact, 1.25 X service pressure is defined as “overpressure” (3.3.44). • Is the original text stating that a test pressure of 4 X operating pressure is equivalent to 1.25 x service pressure? This is not necessarily equivalent since operating pressure is not defined in section 3 as a ratio of service pressure.

Note that 14.4.2.6.1.3, leakage, was updated to replace “service pressure” (2013 version) with “operating pressure” (2016 version)” so perhaps entire clause should reference operating pressure rather than service pressure?




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14.4.2.6.3

The manufacturer shall stamp or otherwise permanently mark the valve body to indicate theservice pressure ratings.

14.4.2.6.3.1

Container valves incorporating integral PRDs complying with 14.4.2.6.1 shall not requireadditional marking.


Add the word pressure to the clause for clarification


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Julie Cairns



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14.4.2.6.3.1

CNG Container valves incorporating integral PRDs complying with 14.4.2.6 2 .1 shall notrequire additional marking.


Clarification and incorrect reference – this clause was copied and modified from NFPA 52-2013, 5.9.4.1 and references the PRD requirements.




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14.4.2.7 CNG Vehicle Fueling Connection.

14.4.2.7.1

CNG vehicle fueling connection devices shall be listed in accordance with ANSI/IAS NGV1,Standard for Compressed Natural Gas Vehicle (NGV) Fueling Connection Devices.

14.4.2.7.2

The refueling connection shall be permitted to be made of nonsparking wrought aluminum alloydesigned for the pressure employed.

14.4.2.7.3 Service Pressure.

14.4.2.7.3.1

The service pressure of the fueling connection receptacle shall not exceed the service pressureof the fuel supply cylinders.

14.4.2.7.3.2

The service pressure of the fueling receptacle shall not exceed 80 percent of the set pressure ofany relief valves installed on fuel supply containers in the vehicle.


Clarity, easier to read.




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14.4.2.7.1

CNG vehicle fueling connection devices shall be listed in accordance with CSA/ ANSI /IASNGV1, Standard for Compressed Natural Gas Vehicle (NGV) Fueling Connection Devices.


Correct designation of standard.


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Julie Cairns



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14.4.2.7.3.1

The service pressure of the fueling connection receptacle shall not exceed the service pressureof the fuel supply cylinders.

Need to discuss: The only service pressure defined in the code (section 3) is the fuel supplycylinder service pressure. Do we need to include a new definition of fueling receptacle servicepressure to section 3?


Service pressure technically should not be used since the definition in section 3 is specific to fuel supply containers.




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14.4.2.8.2

Dispensing station hose, metallic hose, flexible metal hose, tubing, and their connections shallbe designed or selected for the most severe pressures and temperatures under normaloperating conditions with a burst pressure of at least four times the maximum allowableworking pressure.

14.4.2.8.2.1

Prior to use, hose assemblies shall be tested by the OEM or its designated representative at apressure of at least twice the maximum allowable working pressure (MAWP).


This clause is intended for dispenser hoses, and should be relocated to a station Chapter.


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Julie Cairns



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14.4.2.8.2

Dispensing station hose, metallic hose, flexible metal hose, tubing, and their connections shallbe designed or selected for the most severe pressures and temperatures under normaloperating conditions with a burst pressure of at least four times the maximum allowableworking pressure.

14.4.2.8.2.1

Prior to use, hose assemblies shall be tested by the OEM or its designated representative at apressure of at least twice the maximum allowable working pressure (MAWP).


Delete entire clause and move to Chapter 8 since the requirements are applicable to dispensing.




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14.5.1 Application.

This section applies only to vehicular engine fuel system components handling LNG or LNGvapor .


Components that handle LNG vapor are within scope of the LNG fuel system




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14.5.2.2

Metallic material used in construction of the fuel system shall be listed in accordance withANSI/ASME B31.3, Process Piping, and the the ASME Boiler and Pressure Vessel Code, orAPI API 620, Design and Construction of Large, Welded, Low-Pressure Storage Tanks,Appendix Q, and or another code acceptable to the authority having jurisdiction. The materialshall not be used below the minimum design temperature established in these codes orstandards the applicable code or standard .


Neither B31.3 (process plant piping), ASME BPVC (pressure vessels) or API 620 (low pressure storage tanks) is entirely applicable to vehicle fuel lines, especially high pressure fuel lines such as the Westport HPDI system (approx 5000 psi+). The modification allows the most flexibility and highest possibility to find a listed material that meets the specific vehicular fuel line design requirements.




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14.5.2.4.1

Stainless steels that do not resist chloride-induced pitting/corrosion cracking and sensitization-induced corrosion resistance reduction shall not be used.


All metals corrode to one degree or another. This clause should be deleted until further information and instruction is available which provides the items discussed below and provides more details on test conditions and pass/fail criteria:

1. Test duration2. Concentration of chloride3. Acceptable rate of pitting or corrosion4. Acceptable level of sensitization5. Guidelines on sample preparation and test setup 8. Etc




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14.5.2.8 Engine Compartment.

14.5.2.8.1

Onboard fuel system components inside the engine compartment shall be compatible with theliquids and gases throughout the full range of temperatures [ that are in contact with LNG shallbe designed for service over a temperature range of -260°F to 250°F (-162°C to 121°C)] .

14.5.2.8.2

Onboard

Components that are not fuel system components that are in contact with LNG shall bedesigned for service over a temperature range of -260°F to 250°F (-162°C to 121°C) and arelocated within the operational area of LNG or LNG vapor shall also be protected or maintain aservice range equal to the onboard fuel system .


1) 14.5.2.8.1 and 14.5.2.8.2 are repetitive and therefore redundant - therefore deleted original 14.5.2.8.12) Renumbered 14.5.2.8.2 to 14.5.2.8.13) New 14.5.2.8.2: • copied the text and modified it from 14.5.2.10 because the wording states “equal to the onboard fuel system”Modifications:• “LNG liquid” is redundant and not required. LNG stands for Liquefied Natural Gas, ie a liquid.• “Gaseous leaks” changed to “LNG Vapor”: “gaseous leaks could mean CNG”• Will need to modify 14.5.1 scope since it says "this section applies only to vehicular engine fuel system components handling LNG" and therefore non-fuel system components are out of scope. Discussion is required on appropriate wording since all the other requirements in this section (ie material requirements etc.) should not be prescribed to the non-fuel system components.




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14.5.2.9.3

Components that are not fuel system components and are located within the operational area ofLNG or LNG vapor shall be designed for service over a temperature range of −260°F to 180°F(−162°C to 82°C).


1) Need to revise the scope of 14.5.1 - scope says “this section applies only to vehicular engine fuel system components handling LNG”. Discussion is required on appropriate wording since all the other requirements in this section (ie material requirements etc.) should not be prescribed to the non-fuel system components.2) text copied and modifed from 14.5.2.10 - note that separate additional comments have been submitted also recommended that it be copied into 14.5.2.8 and that 14.5.2.10 can now be deleted.Reads better this way, listed in each section separately rather than as a separate clause (14.5.2.10). As is, due to the current format and titling, 14.5.2.10 looks as if it falls under the “outside engine compartment” requirements

Modificiations to the text:• “LNG liquid” is redundant and not required. LNG stands for Liquefied Natural Gas, ie a liquid• “Gaseous leaks” changed to “LNG Vapor”: “gaseous leaks could mean CNG”• Onboard does not make sense for components outside the engine compartment.




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14.5.2.9.2

Other components that are not in contact with LNG shall be designed for service over atemperature range of -40°F to 180°F (-40°C to 82°C).

Discussion required on whether to delete this requirement or revise scope of 14.5.1 sincescope does not include components that are not in contact with LNG.


14.5.1 scope says “this section applies only to vehicular engine fuel system components handling LNG” so either the scope or this section must be revised.




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14.5.2.10

Components that are not fuel system components and are located within the operational areaof LNG or LNG liquid or gaseous leaks shall also be protected or maintain a service rangeequal to the onboard fuel system.


Delete entire clause - move requirements into 14.5.2.8 and 14.5.2.9. See comments submitted for these clauses.

Original wording stated “onboard” only but is listed as an entirely separate clause applicable to both onboard and outside the engine compartment.

Reads better if listed in each section rather than as a separate clause. As is, due to the current format and titling, 14.5.2.10 looks as if it falls under the “outside engine compartment” requirements




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14.5.3 Vehicular Fuel Containers. LNG Fuel Supply Container

14.5.3.1 Design.

Containers LNG fuel supply containers shall be designed, fabricated, tested, and marked (or stamped) in accordance with the regulations of DOT Specification 4L or the “Rules for the Construction of Unfired Pressure Vessels,” in ASME Boiler and Pressure Vessel Code, applicable at the date of manufacture.

14.5.3.1.1

LNG containers that are in contact with LNG or cold LNG vapor shall be physically and chemically compatible with LNG and designed for service at –260°F (–162°C).

14.5.3.1.2

Container appurtenances shall have a rated working pressure not less than the maximum allowable working pressure of the container.

14.5.3.1.3

For vacuum insulation, the inner tank, outer tank, and internal lines shall be tested for vacuum leaks prior to installation on the vehicle.

14.5.3.2* Heat Leak.

The manufacturer shall identify the maximum operating design pressure of the container.

14.5.3.2.1

The construction of the container shall be such that the unrelieved pressure inside the container will not exceed the maximum allowable working pressure of the container within a 72 hour period after the container has been filled to its maximum filling volume with LNG stabilized at the designed operating pressure and temperature equilibrium has been established.

14.5.3.2.2

The ambient temperature during the 72 hour period shall be 70°F (21°C).

14.5.3.3 Design and Construction of Containers.


14.5.3.3.1.1

Pressure vessels shall be manufactured, inspected, marked, and tested in accordance with ASME Boiler and Pressure Vessel Code, Section VIII or Section X.

14.5.3.3.1.2

Adherence to applicable ASME Boiler and Pressure Vessel Code case interpretations and addenda shall be considered as compliant with the ASME Boiler and Pressure Vessel Code.

14.5.3.3.1.3

Pressure vessels manufactured to the requirements of the ASME Boiler and Pressure Vessel Code shall be registered with the National Board of Boiler and Pressure Vessel Inspectors.

14.5.3.3.1.4

The repair or alteration of an ASME pressure vessel shall comply with the requirements of NB-23, National Board Inspection Code.

14.5.3.3.1.5

Other welding or brazing shall be permitted only on saddle plates, lugs, or brackets attached to the pressure vessel by the pressure vessel manufacturer.

14.5.3.3.1.6

The exchange or interchange of pressure vessel appurtenances intended for the same purpose shall not be considered a repair or alteration.

14.5.3.4 Pressure Relief Devices (PRDs).

14.5.3.4.1

The discharge flow rate of the PRD shall not be reduced below that required for the capacity of the container upon which the device is installed.

14.5.3.4.2

PRDs shall be located so that the temperature to which they are subjected is representative of the temperature to which the fuel supply container is subjected.

14.5.3.4.3

The minimum rate of discharge of PRDs on containers shall be in accordance with CGA S-1.3, Pressure Relief Device Standards — Part 3 — Stationary Storage Containers for Compressed Gases, or the ASME Boiler and Pressure Vessel Code, whichever is applicable.

14.5.3.4.4

PRVs protecting ASME pressure vessels shall be repaired, adjusted, and tested in accordance with NB-23, National Board Inspection Code.

14.5.3.4.5

Containers and pressure vessels not constructed in accordance with 14.4.2.1.4 or 14.5.3.3.1 shall be provided with PRDs approved by the authority having jurisdiction.

14.5.3.5 Container Filling.

14.5.3.5.1

Containers shall be equipped with a device or devices that provide an indication of when the container is filled to the maximum allowable liquid level.

14.5.3.5.2

The function shall allow for the ullage volume to be determined by the manufacturer to be that which maintains the required hold time as required by 14.5.3.2.

14.5.3.6* Vehicular Fuel Container Shutoff Valves.

14.5.3.6.1

The container shall be equipped with shutoff valves that allow for its complete isolation from the rest of the vehicular fuel system.

14.5.3.6.1.1

Container shutoff valves shall be labeled as to their function.

14.5.3.6.1.2

Decals or stencils shall be acceptable.

14.5.3.6.2

Normally closed automatic shutoff valves that are held open by electric current, pneumatic or hydraulic pressure, or a combination thereof, or manually operated shutoff valves shall be permitted to be used to meet this requirement.

14.5.3.7 Vehicular Fuel Container Pressure Relief Devices (PRDs) and Pressure Control Valves.

Containers shall be equipped with the PRDs or pressure control valves required by the code under which the containers were designed and fabricated.

14.5.3.7.1

PRDs shall be sized for simultaneous conditions of fire and loss of vacuum.

14.5.3.7.2

PRDs shall be sized in accordance with CGA S-1.1, Pressure Relief Device Standards — Part 1 — Cylinders for Compressed Gases, and CGA S-1.3, Pressure Relief Device Standards — Part 3 — Stationary Storage Containers for Compressed Gases.

14.5.3.8 Vehicular Fuel Container Pressure Gauges.

14.5.3.8.1

Pressure gauges shall be designed for the maximum pressure and temperature conditions to which they can be subjected, with a minimum burst pressure safety factor of 4.

14.5.3.8.2

Dials shall be graduated to indicate at least 1.2 times the pressure at which the pressure relief device incident to the pressure gauge is set to function.

14.5.3.8.3

A gauge opening shall not exceed 0.055 in. (1.4 mm) (No. 54 drill size) at the inlet connection.


Aligns with definition 3.3.10.4. Fuel Supply Container Add “LNG” for clarity.




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Delete asterisk:

14.5.3.2* Heat Leak. Hold Time

The manufacturer shall identify the maximum operating design pressure of the container.

14.5.3.2.1

The construction of the container shall be such that the unrelieved pressure inside the containerwill not exceed the maximum allowable working pressure of the container within a 72 hourperiod after the container has been filled to its maximum filling volume with LNG stabilized atthe designed operating pressure and temperature equilibrium has been established.

14.5.3.2.2

The ambient temperature during the 72 hour period shall be 70°F (21°C).


"Hold Time" is the standard terminology.

Appendix A 14.5.3.2 is being recommended for deletion in a separate submitted comment since the information contained in the appendix is not appropriate for heat leak (hold time).

14.5.3.2 hold time requirements are clearly written without need for further instructions




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14.5.3.3.1.1


14.5.3.3.1.2


14.5.3.3.1.3


14.5.3.3.1.4


14.5.3.3.1.5


14.5.3.3.1.6


Delete entire clause and move into a new general chapter at the beginning of the code.



These requirements need to be moved from 14.5.3.3.1 (and 14.4.2.1.6) and put at a “higher” more general level in the document. Currently there is no “general” chapter at the beginning of the standard so proposing that one be added (this is a separate submitted comment).Without a general chapter that includes these pressure vessel requirements these requirements will need to be copied into every chapter that references pressure vessels and/or ASME compliant containers (essentially every chapter).




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14.5.3.3.1.3

Pressure vessels manufactured to the requirements of the ASME Boiler and Pressure VesselCode shall be registered with the National Board of Boiler and Pressure Vessel Inspectors. , ifrequired by the authority having jurisdiction


Registration with the National Board of Boiler and Pressure Vessel Inspectors is not a requirement of DOT/TC. It is however a requirement for stationary tanks that fall under different safety authorities/jurisdictions.




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14.5.3.3.1.4

The repair or alteration of an ASME pressure vessel shall comply with the requirements ofNB-23, National Board Inspection Code, or by methods acceptable to the authority havingjurisdiction .


Vehicle fuel tanks do not fall under the National Board Inspection Code but rather under transportation codes. Particularly, LNG fuel tanks (14.5.3.3.1.2 and 14.5.3.3.1.3) are highly specialized and their repair and alteration should be managed by the OEM.




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14.5.3.4 Pressure Relief Devices Valves (PRDs PRVs ).

14.5.3.4.1

The discharge flow rate of the PRD PRV shall not be reduced below that required for thecapacity of the container upon which the device is installed.

14.5.3.4.2

PRDs PRVs shall be located so that the temperature to which they are subjected isrepresentative of the temperature to which the fuel supply container is subjected.

14.5.3.4.3

The minimum rate of discharge of PRDs PRVs on containers shall be in accordance with CGAS-1.3, Pressure Relief Device Standards — Part 3 — Stationary Storage Containers forCompressed Gases , or the ASME Boiler and Pressure Vessel Code, whichever is applicable.

14.5.3.4. 4

PRVs protecting ASME pressure vessels shall be repaired, adjusted, and tested in accordancewith NB-23, National Board Inspection Code .

14. 5 .3.4.5

Containers and pressure vessels not constructed in accordance with 14.4.2. 1 . 4 or14 .5.3.3.1 shall be provided with PRDs PRVs approved by the authority having jurisdiction.

14.5.3.4.6 Pressure relief valves (PRVs) shall not be fitted with lifting devices.






PRVs are appropriate for LNG tanks

14.5.3.4.4: should be deleted entirely. This requirement in the 2013 version was only for the CNG fuel system (chapter 5 in the 2013 version) and was deleted in the 2016 version from the CNG fuel system requirements and therefore should also be deleted from the LNG fuel system requirements. This inspection code is applicable to stationary vessels.

14.5.3.4.5:• Pressure vessels do not need to be included in this “alternative compliance” clause since ASME compliance is a “shall” requirement for pressure vessels (per 14.5.3.3.1).



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• Note that Westport suggests to move the requirements of 14.5.3.3.1 (ASME compliance) to a new "general" chapter at the beginning of the code (recommendation submitted separately). In that case the reference here must be changed to reference the new "general" clause.

14.5.3.4.6: Copied and slightly modified the text from 14.4.2.2.2.2 (removed "for CNG service") since the requirements are applicable




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14.5.3.6.3

Other methods of container isolation shall be permitted, provided these methods comply withthe applicable performance specifications in this Code and can be made available for inspectionby the authority having jurisdiction.


This creates a performance spec rather than a prescriptive spec, and allows designers to use a variety of methods to obtain tank isolation (for example, Westport uses three redundant systems).




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14.5.3.7 Vehicular Fuel Container Pressure Relief Devices (PRDs) and Pressure ControlRelief Valves.

Containers shall be equipped with the PRDs or pressure control relief valves required by thecode under which the containers were designed and fabricated.

14.5.3.7.1

PRDs shall be sized for simultaneous conditions of fire and loss of vacuum.

14.5.3.7.2

PRDs shall be sized in accordance with CGA S-1.1, Pressure Relief Device Standards — Part 1— Cylinders for Compressed Gases, and CGA S-1.3, Pressure Relief Device Standards —Part 3 — Stationary Storage Containers for Compressed Gases.


Pressure control valve is undefined in section 3.




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14.5.3.7.2

PRDs shall be sized in accordance with CGA S-1.1, Pressure Relief Device Standards — Part 1— Cylinders for Compressed Gases,

CGA S-1.2 Pressure Relief Device Standards - Part 2 - Portable Containers for CompressedGases and CGA S-1.3, Pressure Relief Device Standards — Part 3 — Stationary StorageContainers for Compressed Gases .


Added additional alternative to size in accordance to S 1.2. This may be required based on the application and cylinder/container size.

Differences: S 1.3 is for stationary applications rather than for transportation. S 1.1 and 1.2 are for portable containers rather than stationary. The difference between S 1.1 and 1.2 is the size of the container




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14.5.3.8 Vehicular Fuel LNG Fuel Supply Container Pressure Gauges.

14.5.3.8.1

Pressure gauges shall be designed for the maximum pressure and temperature conditions towhich they can be subjected, with a minimum burst pressure safety factor of 4.

14.5.3.8.2

Dials shall be graduated to indicate at least 1.2 times the pressure at which the pressure reliefdevice incident to the pressure gauge is set to function.

14.5.3.8.3

A gauge opening shall not exceed 0.055 in. (1.4 mm) (No. 54 drill size) at the inlet connection.


Per definition.• 3.3.10.4 Fuel Supply Container. A container mounted on a vehicle to store LNG or CNG as the fuel supply to the vehicle.

Add “LNG” for clarification




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14.5.4 Fuel System Pressure Regulators.

The engine pressure regulator inlet and each chamber shall have a design operating pressurenot less than the maximum pressure MAWP of the container upstream pressure source .


Original language suits a CNG vehicle. Modified language will suit both a CNG or an LNG vehicle. On a Westport LNG vehicle the container is the lowest pressure component, an LNG pump pressurizes the LNG which is vaporized at this high pressure before being passed to a regulator on the engine.




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14.5.5 Piping, Tubing, and Fittings.

Piping, tubing, and fittings shall be designed, installed, inspected, and tested in accordancewith ANSI/ASME B31.3, Process Piping . with CSA B109 Natural gas for vehicles installationcode or another code and/or methods acceptable to the authority having jurisdiction.


CSA B109 is a well-known and established vehicular design and installation code. Likewise, it requires that fuel lines be tested to ANSI NGV 3.1 Fuel system components for compressed natural gas powered vehicles, which is a much more applicable code than B31.3 (process plant piping). The final sentence allows alternative but approved methods for instances where CSA B109 is not appropriate for a particular installation.




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14.5.7.1

The fueling receptacle on the vehicular fuel system shall be supported and meet all of thefollowing requirements:

(1) Receive the fueling connector and accommodate the service pressure be designed forthe MAWP of the vehicle fuel system tank

(2) Incorporate a means to minimize the entry of dust, water, and other foreign material

(3) Be designed for the temperature and any corrosive conditions that are anticipated


Tank MAWP is applicable, service pressure is not applicable to an LNG tank.




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15.2.2 OEM Approved Equipment.

The subsystems and components if used, shall be meet the general and applicable fuel specificequipment requirements of Chapter 15 .


Delete the entire clause since it adds no value. The scope of 15.1 already states that Chapter 15 applies to all CNG and LNG fuel supply systems so the subsystems and components must also meet the equipment requirements contained in the chapter by default.




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Sub-Sections] ]

In addition to the requirements of 15.2.2 , system components shall comply with the applicableprovisions of Chapter 8 and with 15.2.5.1 and 15.2.5.2 .


Delete entire clause. • The text is not listing any system component qualifications. •15.2.2 is unnecessary (see comments submitted for that clause suggesting its deletion)• Chapter 8 (Facility equipment)is not applicable for vehicles• 15.2.5.2 is not necessary in this clause (see comments submitted for this clause suggesting it move)




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15.2.5.2

All other components shall be designed or selected for service for a minimum temperaturerange of –40°F (–40°C) to 180°F 185°F (82°C 85°C ).


To be consistent with the temperature range specified in CSA Group and ISO component level standards.


Submitter FullName:

Julie Cairns



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15.2.5.2

All other components shall be designed or selected for service for a minimum temperaturerange of –40°F (–40°C) to 180°F (82°C).


Delete. Move to after 15.3.2.3. Note that this requirement only needs to be in the CNG vehicle section since it is already included in the LNG section (14.5.2.9.2)




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15.2.6.1 Locations of Fuel Supply Containers.

Fuel 15.2.6.1.1 CNG fuel supply containers on vehicles shall be permitted to be located within,below, or above the driver or passenger compartment, provided all connections to thecontainer(s) are external to, or sealed and vented from, these compartments.

15.2.6.1.2 LNG fuel supply containers

a) shall not be located in the vehicle engine compartment.

b) shall be mounted on the vehicle in a location/position that minimizes the possibility ofdamage to the tank and its accessories.

c) shall not be located/mounted/placed in a compartment capable of accumulating naturalgas.

d) shall not be located in front of the vehicle front axle.

e) may be located rearward of the vehicle rear axle if the vehicle structure protects the tankfrom impact.

f) shall not be mounted above an operator or passenger compartment.

g) shall be installed so as to not adversely affect the handling characteristics of the vehicle


Revised to account for the additional requirements of LNG tanks. LNG tank locations aligns with CSA B109 Part 2.




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15.2.6.2 Containers Mounted in the Interior of CNG Vehicles.

Containers shall be installed and fitted so that no gas from fueling operations can be releasedinside the passenger compartment, by permanently installing the fueling receptacle outside thepassenger compartment of the vehicle in a location protected from physical damage anddislodgment.


Clarify that the requirement pertains to a CNG vehicle exclusively, since it is very dangerous to mount an LNG container in the interior of vehicles.




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15.2.6.3 Installation of Containers.

Fuel supply containers shall be installed in accordance with the instructions of the containermanufacturer and the fuel specific requirements in for CNG and for LNG.


Editorial




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15.2.6.4.2

Containers shall be secured to the vehicle body, bed, or frame by means capable ofwithstanding the loads defined in 15. 3.3.1.6 and 15. 4.4.2.


15.3.3.1.6 are the loads on the CNG fuel supply containers.




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15.2.8.2

Manifolds connecting containers or container pressure relief devices or valves shall bedesigned to vent gas from the individual container(s) exposed to a fire to meet therequirements of Section 14.4.2.2 and 14 . 5.3.4 .


Revised to include LNG fuel systems.




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Sub-Sections] ]

Each CNG or LNG each vehicle shall be identified with a permanent, diamond-shaped labellocated on the exterior vertical surface or near-vertical surface on the lower right rear of thevehicle other than on the bumper of the vehicle (or on the trunk lid of a vehicle so equipped, butnot on the bumper or tailgate of any vehicle), inboard from any other markings.


Editorial




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15.2.11.1.3

The marking in the label required by 15.2.11.1.1 shall consist of a border and the letters “CNG”or “LNG “LNG” , ” as appropriate [1 in. (25 mm) minimum height centered in the diamond] ofsilver or white reflective luminous material on a blue background.



TIA_52_16_1.pdf NFPA TIA 16-1 Log No. 1203


Note: This public input originates from Tentative Interim Amendment No. 16-1 Log 1203 issued by the Standards Council on April 26, 2016 and per the NFPA Regs., needs to be reconsidered by the Technical Committee for the next edition of the Document.

Substantiation. During the re-organization of NFPA for the 2016 edition, Section 9.12.8.5 was transposed to Section 15.2.11.1.3, resulting in the loss of LNG in context. The new section15.2.11.1.3 applies to both CNG and LNG vehicles because 15.2 is "General." However,15.2.11.1.3 allows only the letters "CNG" on the label when in fact it should allow either the letters "CNG" or "LNG". Please replace "CNG" with "CNG or LNG, as appropriate".

Emergency Nature. The correction needs to be made before the 2016 edition of NFPA 52 is published because if not done, the consequence will be the REQUIRED mislabeling of LNG fuel as CNG. LNG has significantly different properties from CNG in that it is cryogenic and may cause “burns” when in contact with humans. Secondly, unlike CNG, LNG cannot be odorized and thus cannot be detected with the nose. Thirdly, when leaking, LNG will first sink before rising as its temperature reaches equilibrium with ambient temperature.



Organization: NFPA TC on Vehicular Gaseous Fuel Systems Code

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Note: Text of the TIA was issued and approved for incorporation into the document prior toprinting.

1. Add new 15.2.11.1.4 to read as follows:

1 5 . 2 . 1 1 . 1 . 4 The marking in the label required in 15.2.11.1.2 shall consistof a border and the letters “CNG” or “LNG”, as appropriate, [1.2 in. (30 mm) minimumheight centered in the diamond] of silver or white reflective luminous material on a bluebackground.

2. Renumber current 15.2.11.1.4 and 15.2.11.1.5 as 15.2.11.1.5 and 15.2.11.1.6.



TIA_52-16-4.pdf NFPA TIA 16-4 Log 1207


Note: This public input originates from Tentative Interim Amendment No. 16-4 Log 1207 issued by the Standards Council on April 6, 2016 and per the NFPA Regs., must be reconsidered by the Technical Committee for the next edition of the Document.

Substantiation. During the reorganization of NFPA 52 for the 2016 edition, sections 6.11.3.4 and 9.12.8.6 of the 2013 version were meant to be transposed to section 15.2.11. This was partly corrected when section 6.11.3.4 (for CNG vehicles) was transposed to section 15.3.6.2.4. However, section 9.12.8.6 (for LNG vehicles) was lost during the reorganization. As a result, LNG vehicles of class 6 or higher do not require a label marking. Adding this section will correct the error made during the reorganization of the document and restore the original intent of15.2.11 to address both CNG and LNG labeling requirements.

Emergency Nature. This correction needs to be made in order to address a critical omission that occurred during the reorganization of the document. The omission of this text results in a significant safety hazard, and therefore needs to be included in the document as it was originally intended to be.



Organization: NFPA 52 TC on Vehicular Gaseous Fuel systems

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15.2.11.1.5

The labels for 19,500 lb (8863 kg) GVWR and greater shall be a minimum of 5.7 in. long ×4.2 in. high (145 mm × 107 mm). In addition to the requirement in 15.2.11.1.2 for placement ofthe diamond-shaped label on the lower right rear of the vehicle, labels shall be affixed to eachside of the power unit. If a DOT number is required to be displayed in accordance with 49 CFR390.21, then the labels shall be affixed near the DOT numbers on each side of the power unit.


Deleted first sentence since it is an exact repeat of 15.2.11.1.2




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15.2.11.1.6

Vehicles with roof-mounted CNG fuel containers shall include a permanent label in the drive’sdriver’s compartment, clearly visible to a seated operator, which includes the maximum totalheight of the unladen vehicle.


Editorial




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15.3.2CNG Engine Fuel Systems, where stored CNG is used as the fuel for propulsion shall meetCSA NGV 6.1.

Clause 15.3.3.1 thru 15.3.10.7.2 of NFPA 52 are not applicable for CNG vehicles in compliancewith CSA NGV 6.1.


NGV 6.1 was requested by industry to provide a more in depth holistic approach to CNG system design. By using system engineering practices, the NGV 6.1 document covers both the component and interaction of components. The NGV 6.1 technical subcommittee utilized an FMEA approach in developing the performance based safety requirements, as well as providing guidance for the overall design of the system and vehicle integration. By referencing the NGV 6.1 document for CNG engine fuel system requirements, it allows the NFPA 52 Committee to focus on other areas of the document, specifically infrastructure requirements. It will also alleviate confusion between the gaseous portions of LNG systems and straight CNG systems.



Public Input No. 148-NFPA 52-2016 [New Section after 14.3.3.1]


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Julie Cairns



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208 of 273 4/18/2017 11:12 AM


15.3.2.1

In addition to the requirements of Section 15.2 , system components shall comply with theapplicable provisions of Chapter 15 and this section.


Delete entire clause since it is unnecessary. The scope of Chapter 15 is already clear in 15.1, that system components must meet Chapter 15.




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209 of 273 4/18/2017 11:12 AM


15.3.2.3 Temperature Range.

15.3.2.3.1 Components in the engine compartment shall be designed or selected for aminimum temperature range of -40°F to 250°F (-40°C to 121°C).

15.3.2.3.2 All other components shall be designed or selected for service for a minimumtemperature range of –40°F (–40°C) to 180°F (82°C).


Text moved from 15.2.5.2. Note that the added requirement only needs to be in the CNG vehicle section since it is already included in the LNG section (14.5.2.9.2)




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210 of 273 4/18/2017 11:12 AM


15.3.2.4

System components shall comply with the applicable provisions of Chapter 15 and thissection.


This clause is virtually identical to 15.3.2.1.

Delete entire clause since it is unnecessary. The scope of Chapter 15 is already clear in 15.1, that system components must meet Chapter 15.




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211 of 273 4/18/2017 11:12 AM


15.3.3.1.4.2*

The fuel An NGV system, including containers, shall be installed with as much road clearanceas practical when installed, should not intrude into the original vehicle’s approach, departure, orbreakover angles, without further engineering evaluation and protection as necessary .


“Leaving as much road clearance as practical” is too vague and open to interpretation.


Submitter FullName:

Julie Cairns



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212 of 273 4/18/2017 11:12 AM


Note: Text of the TIA was issued and approved for incorporation into the document prior to

printing.

1 . Revise 15.3.3.1.5

to read as follows:

15.3.3.1.5 Each fuel supply container shall be secured to the vehicle in a manner that

minimizes the risk of damage from road hazards, slippage, loosening, or transfer of vehicle chassis loads to the container due to frame flexing.

2 . Renumber Figure 15.3.3.1.5 as 15.3.3.1.6.

Fi g ure 15.3.3.1.6 The Six Principal Directions.

3 . Revise 15.3.3.1.6 to read as follows:

15.3.3.1.6 Each fuel supply container shall be secured in a manner that it is capable of

withstanding a static force, applied in the six principal directions shown in Figure 15.3.3.1.6 of eight times the weight of the fully pressurized container.

4 . Revise Section 15.3.3.6 to read as follows:

15.3.3.6 Fuel-Subsystem Isolation.

15.3.3.6.1 Container Isolation.

15.3.3.6.1.1 Every fuel container shall be equipped with either of the following: (1) A

manual shutoff valve

(2) A normally closed, remotely actuated shutoff valve connected directly to the container.

15.3.3.6.1.2 Vehicles with more than one fuel supply container, where each container is

equipped with a normally closed remotely actuated shutoff valve, shall have an automatic system to detect the failure of any one of the valves.

15.3.3.6.1.3 When shut-off valves are attached directly to fuel containers, there shall be

a means for the technician to determine if there is still pressure in the container, regardless of the valve position.

15.3.3.6.1.4 If an interconnected PRD system is protecting a group of containers

installed in accordance with 15.3.3.8.7, a single valve shall be permitted that will isolate the group of containers.

15.3.3.6.1.5* A means shall be provided to bleed the container manually even in the

event that a remote actuated shutoff valve fails or an excess flow device should remain closed.

15.3.3.6.2 Fuel System Isolation. In addition to the valve required by 15.3.3.6.1, a

manual shutoff valve or a normally closed, automatically actuated shutoff valve shall be installed that allows isolation of the container(s) from the remainder of the fuel system.

(A) An additional manual shutoff valve shall not be required on vehicles that are not

normally operated on public streets, that have a single fuel supply container, and that are equipped with an accessible manual container shutoff valve.

(B) The fuel system isolation valve shall be mounted and shielded or installed in a

protected location to minimize damage from vibration and unsecured objects.

(C) Where a manual shutoff valve is used, it shall be in an accessible location.

(D) The manual shutoff valve shall have not more than 90 degrees rotation (quarter turn

fuel delivery valve) from the open to the closed positions.

(E) Access to the manual shutoff valves shall not require the use of any key or tool.

(F) Where a manual shutoff valve is used, the valve location shall be indicated by means

of a decal or label containing the words

“MANUAL SHUTOFF VALVE.”

(G) A weather-resistant decal or label with red, blue, or black letters on a white or silver

reflective background shall be used.

(H) The valve required by 15.3.3.6.2 shall not be used to introduce high-pressure gas to

downstream components of the fuel system that have previously been depressurized.

15.3.3.6.3 Engine Isolation. A valve or, fuel injector, or other means shall be provided

that automatically prevents the flow of gaseous fuel to the engine when the engine is not running, even if the ignition is switched on.

15.3.3.6.4* Multiple Fuel Systems. Where multiple fuel systems are installed on the

vehicle, automatic valves shall be provided, as necessary, to shut off the fuel not being used.

15.3.3.6.5 Fuel Backflow Prevention. The fueling system shall be equipped with a

backflow check valve that prevents the return flow of gas from the container(s) to the filling connection.

15.3.3.6.5.1 The backflow check valve shall be mounted to withstand the breakaway

force specified in 8.4.2.4.

15.3.3.6.5.2 A second check valve shall be located between the fueling receptacle and

the fuel supply containers.



TIA_52_16_3.pdf NFPA TIA 16-3 Log 1206


Note: This public input originates from Tentative Interim Amendment No. 16-3 Log 1206 issued by the Standards Council on April 6, 2016 and per the NFPA Regs., must be reconsidered by the Technical Committee for the next edition of the Document. Substantiation. Items 1-3: The proposed wording eliminates redundancy with 15.3.3.1.6 and substitutes the phrase “minimizes the risk of” for the term “prevents.” It is not possible to completely prevent unless the environment and duty cycle is completely defined and controlled. The figure of the six principle directions has been moved to the appropriate section, as it is no longer referenced in 15.3.3.1.5. Item 4: The word "cylinder" is replaced with the term "container" to provide consistency and allow potential future designs that may not use a cylindrical container to store fuel. Headings were added to clarify the intent of the three isolation valves. In paragraph 15.3.3.6.3, the phrase "or other means" is added to make it a performance requirement rather than specifying components. Emergency Nature. During the second draft stage, the reorganization of NFPA 52 resulted in errors in a number of second revisions. Some of the revisions that were voted on during the second draft meeting were not carried over during the editorial process, and therefore the revisions that were balloted were not the same as what the committee had actually voted on. The proposed text corrects this error by including the language the committee agreed upon as a second revision.



Organization: NFPA 52 TC on Vehicular Gaseous Fuel Systems Code

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15.3.3.1.6

Each fuel supply container, together with valves, enclosures, and all other items that aremounted and attached, shall be secured in a manner that it is capable of withstanding a staticforce, applied in the six principal directions shown in Figure 15.3.3.1.6 of eight times the weightof the fully pressurized container plus its contents, without loss of contents .

15.3.3.1.7 * The container, the plumbing, and the mounting attachments shall withstand theeffects of shock, vibration, and acceleration encountered in normal service.

Figure 15.3.3.1.6 The Six Principal Directions.


Consistency - modified to align with the securement requirements of an LNG tank (15.4.4.2).




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216 of 273 4/18/2017 11:12 AM


15.3.3.1.12

Where a fuel supply container is located on a trailer, the fuel supply line shall contain anemergency breakaway device designed to retain CNG on both sides of the breakaway point.


FMCSA regulation do not allow to fuel engine from a trailer, why require Emergency breakaway device on equipment that cannot be used


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Julie Cairns



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217 of 273 4/18/2017 11:12 AM


15.3.3.1.12

Where a fuel supply container is located on a trailer, the fuel supply line shall contain anemergency breakaway device designed to retain CNG on both sides of the breakaway point.


Delete entire clause. This clause is in contradiction with 15.4.5.4.5 (LNG fuel systems) in which it is not allowed. Is a CNG fuel supply container allowed to be located on a trailer but not an LNG one? Fuel tanks receive exemptions from Transportation of Dangerous Goods regulations by being mounted on the "motive of transport". Therefore, if the tank is located on the trailer it should be subject to Transportation of Dangerous Goods regulations.

Note:15.4.5.4 Piping, Tubing, and Fittings.15.4.5.4.5 A fuel connection between a tractor and trailer or other over-the-road vehicle units shall not be permitted.

15.3.3.1.12 originated in Chapter 6, section 6.5.10 of NFPA 52-2013 (CNG), whereas 15.4.5.4 originated in Chapter 9, section 9.12.3.5 (LNG)




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218 of 273 4/18/2017 11:12 AM


15.3.3.1.13

Where parts of the vehicular fuel container are exposed to higher temperatures than the PRDduring a localized fire, the fuel container shall should be protected by any of the following (seeAnnex C) :

(1) Noncombustible heat-insulating shielding to retard localized heating of the container

(2) Installation of a thermally sensitive “fusing” system to trigger the PRD in a fire situation

(3) Other design for venting of the fuel container in a fire situation


Annex C is in regards to PRD and localized fires and the requirements of 15.3.3.1.13 are listed as a “should” in the Annex.




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219 of 273 4/18/2017 11:12 AM


15.3.3.5.6

A bend in metallic tubing shall be prohibited where such a bend weakens the tubing not inexcess of the recommended minimum bend radius for the diameter of the tubing and a crimpresulting from a bend shall be prohibited .


Current clause is too vague and subjective. The new proposed wording better illustrates the intent of the clause.


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Julie Cairns



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220 of 273 4/18/2017 11:12 AM


15.3.3.6.1.2

Vehicles For vehicles with more than one fuel supply container, where each container isequipped with a normally closed remotely actuated shutoff valve, shall have an automaticsystem to detect the failure of any one of the valves. , OEMs, FSVIMs, alterers, and convertors,shall provide guidance, as part of the maintenance procedures, how to check that the solenoidvalve is operating as intended.


It is uncertain whether there is an automatic system to detect failure of solenoid. The propose language provides an “Onboard approach” that evaluates whether the solenoid is operating. Replace with language that provides procedures to detect an issue.


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Julie Cairns



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221 of 273 4/18/2017 11:12 AM


Sub-Sections] ]

In addition to the valve required by 15.3.3.6.1, a manual shutoff valve or and a normally closed,automatically actuated shutoff valve shall be installed that allows isolation of the container(s)from the remainder of the fuel system.

The automatic shutoff valve should be closed with the key on and the engine off (KOEO).


NOTE: This has been understood by the NGV industry to prevent flow from the high pressure storage system in the case of a vehicle roll-over, etc. and is in conflict with para. 15.3.3.6.3 Engine Isolation. By adding ''A valve fuel injector...' in this section a safety hazard is created if fuel is allowed thru the entire fuel system up to the injector. A least one vehicle was destroyed by this approach. See Indiana DOT fire (http://www.forabodiesonly.com/mopar/attachments/dump_truck_wayne_1_20130408132819_640_480-jpg.1714608861/)





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222 of 273 4/18/2017 11:12 AM

Public Input No. 136-NFPA 52-2016 [ Section No. 15.3.3.6.2(H) ]

(H)

The valve required by 15.3.3.6.2 shall not be used to introduce high-pressure gas todownstream components of the fuel system that have previously been depressurized.


The requirement, the way it is written, is not possible. Once the valve is opened, depending on the location, high pressure gas may be introduced downstream of the valve.


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Julie Cairns



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223 of 273 4/18/2017 11:12 AM


15.3.3.7.2

Larger vehicles such as buses and trucks shall be permitted to use fueling connections that aredesigned to prevent the connection of a lower service pressure vehicle to a higher servicepressure source.


NGV 1 now includes transit and heavy duty fill nozzles and receptacles within its scope, this clause is no longer needed.


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Julie Cairns



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224 of 273 4/18/2017 11:12 AM


15.3.3.8.2

PRD manifolds connecting two or more containers shall be permitted if in accordance with thecontainer manufacturer’s instructions. DELETE

Each cylinder complying with 14.5.3.4 shall be fitted with one or more pressure relief devices(PRD's) as specified by the cylinder manufacturer and OEM for CNG service. Additional PRD'sconnecting two or more containers shall be permitted if in accordance with the containermanufacturere's instructions.


First, FMVSS 304 prescribes bonfire testing upon a single container. It does not have any allowances for bonfire testing groups of containers that are manifolded together.

Second, NHTSA issued a regulatory interpretation in 2007 which very specifically indicated compliance is demonstrated by bonfire testing a single cylinder.

Third, fire performance and flow rate performance of a manifolded system is generally not accurately represented by breaking up the system and attempting to bonfire test the containers individually.

Fourth, this section does not set forth any criteria for manufacturers to verify that a manifolded system is actually safe for public use.





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225 of 273 4/18/2017 11:12 AM


15.3.3.10.1

A safety sign(s) as depicted in Figure 15.3.3.10.1 shall indicate the PRD vent location (s)location(s) .

Figure 15.3.3.10.1

ATTENTION

CNG PRD Location


Proposal is to replace the existing Figure 15.3.3.10.1 with a New Figure. The intention is to use the same color and fonts as previously required in the current figure (just revise text)

Because of known failure modes by PRD vent cooling by first responders, it should be more important to know where not to direct the stream of water vs. where the PRD may vent.


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Julie Cairns



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227 of 273 4/18/2017 11:12 AM


15.3.4.1.1

The gas to be removed from the container shall be discharged into a closed transfer system orvented flared. Vented by an approved method of atmospheric venting, is allowed when noother option is available .


Industry is moving toward capturing or flaring released gas to address GHG concerns.


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Julie Cairns



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228 of 273 4/18/2017 11:12 AM


15.3.4.2

Personnel training container depressurization shall do the following:

(1) Depressurize containers only in accordance with manufacturer’s instructions

(2) Use grounding to prevent static electrical charge buildup

(3) Limit the rate of gas release from plastic-lined containers to a value not greater than thatspecified by the container manufacturer

(4) Restrain containers during depressurization to prevent container movement

NOTE: See CSA EXP 2.1, Best practice for defueling, decommissioning, and disposal ofcompressed natural gas vehicle fuel containers, for further guidance


Provides the reader further guidance material.


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Julie Cairns



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229 of 273 4/18/2017 11:12 AM


15.3.9.3.1

Fuel containers whose service life has expired shall be removed from service.

NOTE: See CSA EXP 2.1, Best practice for defueling, decommissioning, and disposal ofcompressed natural gas vehicle fuel containers, for further guidance


Provides the reader further guidance material.


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Julie Cairns



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230 of 273 4/18/2017 11:12 AM


15.3.9.7.1

All personnel engaged in activities in 15.3.4, 15.3. 5, 15.3. 8, and 15.3.9, namely, dischargingCNG fuel containers or inspection, maintenance, repair, replacement, removal, and testing ofCNG fuel system or its components shall be qualified mechanics.


Inspections of CNG fuel systems and fuel containers must also be performed by qualified mechanics.


Submitter Full Name: Quon Kwan

Organization: US Department of Transportation

Affilliation: US Department of Transportation

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231 of 273 4/18/2017 11:12 AM


15.4.1.1

In addition to the general requirements of 15.2, the fuel specific requirements of section 15.4shall apply to fuel systems service serving LNG fueled vehicles.


Editorial




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232 of 273 4/18/2017 11:12 AM

Public Input No. 163-NFPA 52-2017 [ Section No. 15.4.2 ] 15.4.2 Materials of Construction. 15.4.2.1 Metallic materials used in construction of the fuel system, except fusible links, shall have a minimum melting point of 1000°F (538°C). 15.4.2.2 Metallic material used in construction of the fuel system shall be listed in accordance with ANSI/ASME B31.3, Process Piping, and the ASME Boiler and Pressure Vessel Code, or API 620, Design and Construction of Large, Welded, Low-Pressure Storage Tanks, Appendix Q, and shall not be used below the minimum design temperature established in these codes or standards. 15.4.2.3 The use of dissimilar metal junctions shall be minimized, but if such a junction cannot be avoided, good corrosion protection practice shall be employed to reduce the effect of such a material combination on the long-term corrosion behavior of the junction. 15.4.2.4 All materials shall be selected or installed to minimize corrosion or to protect the material from corrosion. 15.4.2.4.1 Stainless steels that do not resist chloride-induced pitting/corrosion cracking and sensitization-induced corrosion resistance reduction shall not be used. 15.4.2.4.2 The use of all copper–zinc and copper–tin alloy families shall be restricted to those alloys that are metallurgically inhibited to prevent accelerated metallurgical deterioration from external environmental sources. 15.4.2.5 Brazing filler material shall have a melting point exceeding 1000°F (538°C). 15.4.2.6 Oxy–fuel gas welding shall not be permitted. 15.4.2.7 Furnace butt-welded steel products shall not be used. 15.4.2.8 Engine Compartment. 15.4.2.8.1 Onboard fuel system components inside the engine compartment shall be compatible with the liquids and gases throughout the full range of temperatures [-260°F to 250°F (-162°C to 121°C)]. 15.4.2.8.2 Onboard fuel system components that are in contact with LNG shall be designed for service over a temperature range of -260°F to 250°F (-162°C to 121°C). 15.4.2.9 Outside Engine Compartment. 15.4.2.9.1 All other components shall be designed or selected for service for a minimum temperature range of -40°F to 180°F (-40°C to 82°C). 15.4.2.9.2 Components outside the engine compartment shall be designed for service over a temperature range of -40°F to 180°F (-40°C to 82°C). 15.4.2.10 Components that are not fuel system components and are located within the operational area of LNG or LNG liquid or gaseous leaks shall also be protected or maintain a service range equal to the onboard fuel system.

Statement of Problem and Substantiation for Public Input Delete entire section. Identical requirements to 14.5.2 and therefore redundant.




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15.4.3.1

In addition to the requirements of 15.2 , system components shall comply with the applicableprovisions of Chapter 8 and this section.


Delete entire clause. Almost identical to 15.4.1.1. Chapter 8 (facility equipment) is not applicable.




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235 of 273 4/18/2017 11:12 AM

Public Input No. 272-NFPA 52-2017 [ Section No. 15.4.5.1 ] 15.4.5.1 Installation of Pressure Relief Device and Pressure Relief Valves. 15.4.5.1.1 All discharge lines and outlets shall be installed in accordance with 15.4.5.1.1.1 through 15.4.5.1.1.13. 15.4.5.1.1.1 Pressure relief discharge lines shall be designed for the pressure and temperature of the discharged LNG. 15.4.5.1.1.2 Components shall be designed for operation at an LNG temperature of –260°F (–162°C). 15.4.5.1.1.3 Individual discharge lines and adapters shall be sized, located, and secured so as to permit the maximum required relief discharge capacity in order to minimize the possibility of physical damage. 15.4.5.1.1.4 The discharge lines shall be able to withstand the pressure of the relief vapor discharge when the PRD is in the full-open position. 15.4.5.1.1.5 A means shall be provided (e.g., loose-fitting caps) to minimize the possibility of the entrance of water or dirt into either the relief device or its discharge line and to drain any water that accumulates in the discharge line. 15.4.5.1.1.6 The means of protection shall remain in place except when the PRD operates. 15.4.5.1.1.7 In this event, the means of protection shall permit the relief device to operate at maximum required capacity. 15.4.5.1.1.8 The outlet of the discharge line shall be fitted with a device or configured to prevent the formation or accumulation of any ice or frozen LNG that prevents the relief device from operating at required capacity. 15.4.5.1.1.9 The relief valve discharge shall be directed away from the refueling operator and not hinder manually shutting off any fuel system devices. 15.4.5.1.1.10 The discharge line from PRVs on all vehicles shall be directed upward near the highest point on the vehicle. Discharge outlets shall be located such that venting gas will not enter a wheel well, the engine compartment, the passenger compartment, or the cargo compartment of the vehicle. Discharge outlets shall not be directed toward the engine exhaust or components that are normally hot during vehicle use, or toward any other ignition source. 15.4.5.1.1.11 PRV discharge lines shall be secured at intervals in such a manner so as to minimize the possibility of damage, corrosion, breakage, or dislocation due to gas flow forces during venting, expansion, contraction, vibration, strains, or wear and tear and to prevent any loosening while in operation. 15.4.5.1.1.12 If the outlet of a discharge line from a PRV is located behind a shield or screen or is obscured from the view of a person approaching the exterior side of the vehicle on which the outlet is located, a label shall be affixed to that exterior side of the vehicle as close as possible to the outlet to point out the location of the outlet. 15.4.5.1.1.13 Secondary relief devices designed to prevent rupture of the container upon failure of the primary relief device shall not be required to be piped away from the tank. 15.4.5.1.2 PRDs and pressure control valves shall be so designed that the possibility of tampering is minimized. 15.4.5.1.3 Externally set or adjusted valves shall be provided with a means of sealing the adjustment.

Statement of Problem and Substantiation for Public Input LNG fuel systems have PRVs.




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15.4.4.6.2

Further requirements for clearances shall be measured as follows:

(1) Containers installed between axles shall comply with 15.4.4.6.2(3) or shall not be lowerthan the lowest point on a structural component of the body, frame or subframe, if any,engine, or transmission, including the clutch housing or torque converter housing, forwardof the container measured as if the wheel rims were on the ground.

(2) Containers installed behind the rear axle and extending below the frame shall comply with15.4.4.6.2(3)or shall not be lower than both of the following:

(3) The lowest point of a structural component of the body, engine, or transmission,including clutch housing or torque converter housing, forward of the container

(4) The lowest point of those lines extending rearward from each wheel at the pointwhere the wheel rims contact the ground directly below the center of the axle to thelowest and most rearward structural interference (e.g., bumper, frame). Where thereare two or more rear axles, the projections shall be made from the rearmost axle.

(5) Where an LNG container is substituted for the fuel container installed by the originalchassis manufacturer of the vehicle, the LNG container shall either fit within the space inwhich the original fuel container was installed or comply with 15.4.4.6.2 (1) or15.4.4.6.2(2) and shall meet, when available, the specifications of the chassis and fuel system OEMs.


Additional text to item (3) was added since it was mistakenly not copied over from NFPA 52-2013 during the reorganization into the 2016 version. This text was directly copied over from the applicable text in NFPA 52-2013 (9.12.1.6.2 (3)).




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240 of 273 4/18/2017 11:12 AM


15.4.4.12

Where a container is installed above the operator or passenger compartment of a vehicle, thefollowing requirements shall apply:

(1) The container and its piping, fittings, and valves shall be protected from damage by thefollowing:

(2) A guard rail or similar device that is designed to absorb the impact of a collision witha stationary object when the vehicle is moving either forward or backward at 5 mph/hr(8 km/hr)

(3) A shield designed to absorb impacts that can occur during loading, unloading, oruse of the vehicle

(4) The top of the container and any related piping, fitting, valve, housing, guardrail, or shieldshall not be more than 13.5 ft (4.1 m) above the road surface.

(5) The cylinder shall be protected from accidental contact with overhead electrical wiring bymetallic or nonmetallic covers.

15.4.4.12.1

The guard rail or similar device shall be free of projections that could damage the container orits valves and fittings.

15.4.4.12.2

The shield shall be free of projections that subject the container or its valves and fittings todamage.

Discussion required. Should a container be allowed above the operator or passengercompartment of a vehicle? This is not allowed in CSA B109.


CSA B1095.7.3 Location of LNG tankThe following shall apply for LNG tank locations. f) LNG tanks shall not be mounted above an operator or passenger compartment.




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Sub-Sections] ]

Where a container is roof-mounted or installed above the operator or passenger compartmentof a vehicle, the following requirements shall apply:

(1) The container and its piping, fittings, and valves shall be protected from damage by thefollowing:

(2) A guard rail or similar device that is designed to absorb the impact of a collision witha stationary object when the vehicle is moving either forward or backward at 5 mph/hr(8 km/hr)

(3) A shield designed to absorb impacts that can occur during loading, unloading, or useof the vehicle

(4) The top of the container and any related piping, fitting, valve, housing, guardrail, or shieldshall not be more than 13.5 ft (4.1 m) above the road surface.

(5) The cylinder shall be protected from accidental contact with overhead electrical wiring bymetallic or nonmetallic covers.

(6) The vehicle shall include a permanent label in the driver's compartment, clearly visible to aseated operator, which includes the maximum total height of the unladen vehicle.


This revision would make vehicles with LNG tanks that are roof-mounted or installed above the operator's or passenger compartment subject to the same requirement as vehicles with CNG tanks that are roof-mounted. Drivers of vehicles with roof-mounted LNG tanks need to be made aware of their vehicle's clearance height to avoid striking bridges and overpasses. See existing section 15.3.6.2.5.





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243 of 273 4/18/2017 11:12 AM


15.4.4.13 Containers Mounted in the Interior of Vehicles.

15.4.4.13.1

Enclosures, structures, seals, and conduits used to vent enclosures shall be fabricated ofmaterials designed to resist damage, blockage, or dislodgment caused by the movement ofarticles carried in the vehicle or by the closing of luggage compartment enclosures or vehicledoors.

15.4.4.13.1.1

Enclosures shall require the use of tools for removal.

15.4.4.13.2

Container valves, appurtenances, and connections shall be protected to prevent damage dueto incidental contact with foreign objects.


Delete entire section since it is repeated material and therefore redundant. 15.4.4.13.1 and 15.4.4.13.1.1 are identical to 15.2.7.1 and 15.2.7.1.1. 15.4.4.13.2 is identical to 15.4.4.1.3.

Also title is dangerous since LNG containers should not be mounted in the interior of vehicles. Also note that 15.2.6.2 is already a section titled "Containers Mounted in the Interior of Vehicles".




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244 of 273 4/18/2017 11:12 AM


Sub-Sections] ]

Enclosures, structures, seals, and conduits used to vent enclosures shall be fabricated ofmaterials designed to resist damage, blockage, or dislodgment caused by the movement ofarticles carried in the vehicle or by the closing of luggage compartment enclosures or vehicledoors .


This requirement (exact text) is already found in 15.2.7 (which pertains to both CNG and LNG systems).




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245 of 273 4/18/2017 11:12 AM


15.4.4.13.1.1

Enclosures shall require the use of tools for removal.


Delete since identical requirements in 15.2.7.1.1




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15.4.5.1 General

A

means shall be provided to revent the flow of fuel to the engine when the ignitionswitch is off or in the accessory position and when the engine is not running and theignition switch is on.


A performance requirement, rather than specific to a particular architecture, and therefore needs to be placed in a general "fuel system equipment installation" section.

This clause should be placed right after 15.4.5.




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247 of 273 4/18/2017 11:12 AM


15.4.4.13.2

Container valves, appurtenances, and connections shall be protected to prevent damage dueto incidental contact with foreign objects.


Identical to 15.4.4.1.3.This clause does not pertain to the clause title “Containers Mounted in the Interior of Vehicles”




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248 of 273 4/18/2017 11:12 AM

Public Input No. 258-NFPA 52-2017 [ Section No. 15.4.5.1 ] 15.4.5.1 Installation of Pressure Relief Device or Pressure Relief Valve. 15.4.5.1.1 All discharge lines and outlets shall be installed in accordance with 15.4.5.1.1.1 through 15.4.5.1.1.13. 15.4.5.1.1.1 Pressure relief discharge lines shall be designed for the pressure and temperature of the discharged LNG. 15.4.5.1.1.2 Components shall be designed for operation at an LNG temperature of –260°F (–162°C). 15.4.5.1.1.3 Individual discharge lines and adapters shall be sized, located, and secured so as to permit the maximum required relief discharge capacity in order to minimize the possibility of physical damage. 15.4.5.1.1.4 The discharge lines shall be able to withstand the pressure of the relief vapor discharge when the PRD or PRV is in the full-open position. 15.4.5.1.1.5 A means shall be provided (e.g., loose-fitting caps) to minimize the possibility of the entrance of water or dirt into either the relief device or valve or its discharge line and to drain any water that accumulates in the discharge line. 15.4.5.1.1.6 The means of protection shall remain in place except when the PRD or PRV operates. 15.4.5.1.1.7 In this event, the means of protection shall permit the relief device or valve to operate at maximum required capacity. 15.4.5.1.1.8 The outlet of the discharge line shall be fitted with a device or configured to prevent the formation or accumulation of any ice or frozen LNG that prevents the relief device or valve from operating at required capacity. 15.4.5.1.1.9 The relief device or valve discharge shall be directed away from the refueling operator and not hinder manually shutting off any fuel system devices. 15.4.5.1.1.10 The discharge line from PRDs and PRVs on all vehicles shall be directed upward near the highest point on the vehicle. Discharge outlets shall be located such that venting gas will not enter a wheel well, the engine compartment, the passenger compartment, or the cargo compartment of the vehicle. Discharge outlets shall not be directed toward the engine exhaust or components that are normally hot during vehicle use, or toward any other ignition source. 15.4.5.1.1.11 PRD and PRV discharge lines shall be secured at intervals in such a manner so as to minimize the possibility of damage, corrosion, breakage, or dislocation due to gas flow forces during venting, expansion, contraction, vibration, strains, or wear and tear and to prevent any loosening while in operation. 15.4.5.1.1.12 If the outlet of a discharge line from a PRD or PRV is located behind a shield or screen or is obscured from the view of a person approaching the exterior side of the vehicle on which the outlet is located, a label shall be affixed to that exterior side of the vehicle as close as possible to the outlet to point out the location of the outlet. 15.4.5.1.1.13 Secondary relief devices or valves designed to prevent rupture of the container upon failure of the primary relief device or valve shall not be required to be piped away from the tank. 15.4.5.1.2 PRDs and pressure control relief valves shall be so designed that the possibility of tampering is minimized. 15.4.5.1.3 Externally set or adjusted valves shall be provided with a means of sealing the adjustment.

Statement of Problem and Substantiation for Public Input Text modified to allow either a PRD or PRV. This is due to the revision in NFPA 52-2016 of the definition of PRD from being any pressure relieving device (one time PRD or a reclosing relief valve) to being an entirely separate defintion: PRD = one time, PRV = reclosing valve. Refer to section 3,definitions.




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Public Input No. 272-NFPA 52-2017 [ Section No. 15.4.5.1 ] 15.4.5.1 Installation of Pressure Relief Device and Pressure Relief Valves. 15.4.5.1.1 All discharge lines and outlets shall be installed in accordance with 15.4.5.1.1.1 through 15.4.5.1.1.13. 15.4.5.1.1.1 Pressure relief discharge lines shall be designed for the pressure and temperature of the discharged LNG. 15.4.5.1.1.2 Components shall be designed for operation at an LNG temperature of –260°F (–162°C). 15.4.5.1.1.3 Individual discharge lines and adapters shall be sized, located, and secured so as to permit the maximum required relief discharge capacity in order to minimize the possibility of physical damage. 15.4.5.1.1.4 The discharge lines shall be able to withstand the pressure of the relief vapor discharge when the PRD is in the full-open position. 15.4.5.1.1.5 A means shall be provided (e.g., loose-fitting caps) to minimize the possibility of the entrance of water or dirt into either the relief device or its discharge line and to drain any water that accumulates in the discharge line. 15.4.5.1.1.6 The means of protection shall remain in place except when the PRD operates. 15.4.5.1.1.7 In this event, the means of protection shall permit the relief device to operate at maximum required capacity. 15.4.5.1.1.8 The outlet of the discharge line shall be fitted with a device or configured to prevent the formation or accumulation of any ice or frozen LNG that prevents the relief device from operating at required capacity. 15.4.5.1.1.9 The relief valve discharge shall be directed away from the refueling operator and not hinder manually shutting off any fuel system devices. 15.4.5.1.1.10 The discharge line from PRVs on all vehicles shall be directed upward near the highest point on the vehicle. Discharge outlets shall be located such that venting gas will not enter a wheel well, the engine compartment, the passenger compartment, or the cargo compartment of the vehicle. Discharge outlets shall not be directed toward the engine exhaust or components that are normally hot during vehicle use, or toward any other ignition source. 15.4.5.1.1.11 PRV discharge lines shall be secured at intervals in such a manner so as to minimize the possibility of damage, corrosion, breakage, or dislocation due to gas flow forces during venting, expansion, contraction, vibration, strains, or wear and tear and to prevent any loosening while in operation. 15.4.5.1.1.12 If the outlet of a discharge line from a PRV is located behind a shield or screen or is obscured from the view of a person approaching the exterior side of the vehicle on which the outlet is located, a label shall be affixed to that exterior side of the vehicle as close as possible to the outlet to point out the location of the outlet. 15.4.5.1.1.13 Secondary relief devices designed to prevent rupture of the container upon failure of the primary relief device shall not be required to be piped away from the tank. 15.4.5.1.2 PRDs and pressure control valves shall be so designed that the possibility of tampering is minimized. 15.4.5.1.3 Externally set or adjusted valves shall be provided with a means of sealing the adjustment.

Statement of Problem and Substantiation for Public Input LNG fuel systems have PRVs.




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15.4.5.1.1.3

Individual discharge lines and adapters shall be sized, located, and secured so as to permit themaximum required relief discharge capacity and in order to minimize the possibility of physicaldamage.


Two separate requirements.




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253 of 273 4/18/2017 11:12 AM


15.4.5.1.1.4

The discharge lines shall be able to withstand the pressure of the relief vapor discharge whenthe PRD or PRV is in the full-open position.


LNG fuel system may have PRVs.Definition of a PRD is very specific and different than a PRV per Section 3 (3.3.17.3 and 3.3.17.4)




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254 of 273 4/18/2017 11:12 AM


15.4.5.1.1.5

A means shall be provided (e.g., loose-fitting caps) to minimize the possibility of the entrance ofwater or dirt into either the relief device or its discharge line system and to drain any water thataccumulates in the discharge line.


• “relief device” is undefined. It may suggest to a reader “pressure relief device”• Definition of a PRD is very specific and different than a PRV per Section 3 (3.3.17.3 and 3.3.17.4)




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15.4.5.1.1.6

The means of protection shall remain in place except when the PRD or PRV operates.


LNG vehicles can have PRVs rather than PRDs• Definition of a PRD is very specific and different than a PRV per Section 3 (3.3.17.3 and 3.3.17.4)




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256 of 273 4/18/2017 11:12 AM


15.4.5.1.1.7

In this event, the means of protection shall permit the relief device PRD or PRV to operate atmaximum required capacity.






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257 of 273 4/18/2017 11:12 AM


15.4.5.1.1.8

The outlet of the discharge line shall be fitted with a device or configured to prevent theformation or accumulation of any ice or frozen LNG that prevents the relief device system fromoperating at required capacity.






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258 of 273 4/18/2017 11:12 AM


15.4.5.1.1.10

The discharge line from PRVs on all vehicles the fuel supply container primary PRV shall bedirected upward near the highest point on the vehicle. Discharge outlets shall be located suchthat venting gas will not enter a wheel well, the engine compartment, the passengercompartment, or the cargo compartment of the vehicle. Discharge outlets shall not be directedtoward the engine exhaust or components that are normally hot during vehicle use, or towardany other ignition source.


Per 15.4.5.1.1.13 secondary PRVs are not required to be piped away from the tank.

Changed plural to singular, for consistency and easier reading.




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259 of 273 4/18/2017 11:12 AM


15.4.5.1.1.11

The PRV discharge lines line shall be secured at intervals in such a manner so as to minimizethe possibility of damage, corrosion, breakage, or dislocation due to gas flow forces duringventing, expansion, contraction, vibration, strains, or wear and tear and to prevent anyloosening while in operation.


Changed from plural to singular for consistency throughout the document and for easier reading.




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260 of 273 4/18/2017 11:12 AM


15.4.5.1.1.13

Secondary relief devices A secondary means for relief, designed to prevent rupture of thecontainer upon failure of the primary relief device means, shall not be required to be pipedaway from the tank.






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261 of 273 4/18/2017 11:12 AM


15.4.5.1.2

PRDs and pressure control relief valves shall be so designed that the possibility of tamperingis minimized.


Pressure control valves are undefined in section 3.




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262 of 273 4/18/2017 11:12 AM


15.4.5.1.3

Externally PRVs, when provided, shall be externally set or adjusted valves shall be providedwith a means of sealing the adjustment.


More accurate. Clause as originally written mandates PRVs whereas PRDs could be used.




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263 of 273 4/18/2017 11:12 AM

Public Input No. 259-NFPA 52-2017 [ Sections 15.4.5.5.3.1, 15.4.5.5.3.2 ]

Sections 15.4.5.5.3.1, 15.4.5.5.3.2

15.4.5.5.3.1

A positive shutoff valve shall be installed in the fuel supply line.

15.4.5.5.3.2

The shutoff valve shall close automatically and means shall be provided to prevent the flow offuel to the engine when the ignition switch is off or in the accessory position and when theengine is not running and the ignition switch is on.

15.4.5.5.3.2

If a positive shutoff valve is installed in the fuel supply line it must close automatically


Changed to a performance requirement. The requirement is that fuel delivery to the engine is stopped but should not prescribe the exact design/method. For example, when the engine is not running the LNG pump in a Westport HPDI LNG vehicle will stop which in turn stops fuel delivery to the engine.




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264 of 273 4/18/2017 11:12 AM


15.4.8.1.2

Liquid nitrogen or LNG shall flow through the system at least as far as LNG flows when thesystem is in operation, to validate minimum temperature [–260°F (–162°C)] and maximum tankventing cryogenic temperature and tank fill pressure.


1)“maximum tank venting pressure” replaced with “tank fill pressure”: - Original language would require the truck to sit for at least 5 days and then have a tank that is venting. Venting must be avoided. 2) “minimum temperature [–260°F (–162°C)]" replaced with “cryogenic temperature”: - As currently written, the temperature of LNG at max pressure is higher than -162 degC. Also there would be no way to verify the temperature. All that can be done is to estimate the temperature based on pressure and composition and the LNG composition is variable.- This test is typically done during first fill with LNG. The temperature will be closer to minimum but not at minimum




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265 of 273 4/18/2017 11:12 AM


Sub-Sections] ]

When a vehicle is involved in an accident or fire causing damage to the LNG tank, the LNG fuelsystem, or both shall be replaced or inspected by a qualified mechanic in accordance with thevehicle manufacturer’s instructions.


The revision is to clarify that only qualified mechanics are to work on LNG fuel systems





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266 of 273 4/18/2017 11:12 AM


15.4.9.1.1

Motor vehicles equipped with an LNG fuel system or fueled with an unodorized LCNG shall beprovided may be equipped with a methane detection system if the fuel supply container andassociated piping is mounted on the exterior of the vehicle without the possibility of gastrapping. If the fuel supply container is located inside the cargo area then a methane detectionsystem is mandatory that will warn of the presence of methane in the engine compartment,driver’s compartment, and any passenger compartment.


A methane detection system is not required when the tank is in open air and there is no possibility of trapping gas. Revised text is taken from R110, which is copied below:

From R110, (N = truck):18.13. ...The LNG system in category N vehicles may be equipped with a natural gas detector if the fuel storage tank and associated piping is mounted on the exterior of the vehicle without the possibility of gas trapping... If the fuel storage tank is located inside the cargo area of a category N vehicle then a natural gas detector and/or gas tight housing is mandatory




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267 of 273 4/18/2017 11:12 AM

Public Input No. 155-NFPA 52-2017 [ Section No. A.3.2.2 ]

A.3.2.2 Authority Having Jurisdiction (AHJ).

The phrase “authority having jurisdiction,” or its acronym AHJ, is used in NFPA documents in abroad manner, since jurisdictions and approval agencies vary, as do their responsibilities.Where public safety is primary, the authority having jurisdiction may be a federal, state, local, orother regional department or individual such as a fire chief; fire marshal; chief of a fireprevention bureau, labor department, or health department; building official; electrical inspector;or others having statutory authority.Generally, the authority having jurisdiction over natural gascommercial motor vehicles (see section 3.3.65 for definition) is a commecial vehicleenforcement agency, such as a highway patrol, state police, or state transportation agency. Forinsurance purposes, an insurance inspection department, rating bureau, or other insurancecompany representative may be the authority having jurisdiction. In many circumstances, theproperty owner or his or her designated agent assumes the role of the authority havingjurisdiction; at government installations, the commanding officer or departmental official may bethe authority having jurisdiction.


The public generally is not aware that the state fire marshal and/or local fire department is NOT the authority having jurisdiction over natural gas commercial motor vehicles. The change helps to clarify the authority which has jurisdiction over such vehicles.




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268 of 273 4/18/2017 11:12 AM

Public Input No. 282-NFPA 52-2017 [ Section No. A.5.2 ] A.5.2

A typical CNG vehicle fuel system consists of one or more fuel supply containers (if more than one, the containers are manifolded together) holding CNG at high pressure and fitted with the following:

(1) Pressure relief devices and manual shutoff valves

(2) A filling connection with a check valve to prevent gas from flowing back out of the connection

(3) A manual valve downstream from the container valve or valves

(4) A valve that automatically closes if the engine stops for any reason

(5) A pressure regulator to reduce the fuel supply container pressure to a low engine service pressure

(6) A gas-air mixer to produce a flammable mixture

(7) A pressure gauge to indicate the fuel supply container pressure

Systems are designed to operate at fuel supply container service pressures of 2400 psi, 3000 psi, or 3600 psi (7.5 MPa, 20.7 MPa, or 25 MPa). Fueling connections are designed to accommodate compatible filling nozzles suitable only for the proper pressure. Fuel supply containers are installed on either the outside or the inside of the vehicle. If installed on the inside, all connections to the containers are either external to a driver or passenger compartment or inside a compartment that is gastight with respect to a driver or passenger compartment. The compartment is vented to the outside of the vehicle. (See Figure A.5.2.) Figure A.5.2 Typical Vehicular Fuel System Components.

Statement of Problem and Substantiation for Public Input Clarity




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Public Input No. 283-NFPA 52-2017 [ Section No. A.14.4.2.1.5 ]

A.14.4.2.1.5

Current DOT and TC specifications , exemptions, and specified permits do not address the useof cylinders that are approved for the transportation of natural gas to be used in CNG service.

The following Compressed Gas Association publications are relevant cylinder inspectionstandards:

(1) CGA C-6, Standards for Visual Inspection of Steel Compressed Gas Cylinders

(2) CGA C-6.1, Standards for Visual Inspection of High Pressure Aluminum Compressed GasCylinders

(3) CGA C-6.2, Guidelines for Visual Inspection and Requalification of Fiber Reinforced HighPressure Cylinders

(4) CGA C-10, Recommended Procedures for Changes of Gas Service for Compressed GasCylinders

The following Compressed Gas Association publication is specified in ANSI/ISA NGV2,Compressed Natural Gas Vehicle (NGV) Fuel Containers, as appropriate for CNG containerinspection:

CGA C-6.4, Methods of External Visual Inspection of Natural Gas Vehicle (NGV) FuelContainers and Their Installations


Deleted reference to DOT and TC exemptions or special permits since 14.4.2.1.5 was revised in the 2016 version to exclude exemptions or special permits.




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272 of 273 4/18/2017 11:12 AM

Public Input No. 229-NFPA 52-2017 [ Section No. A.14.5.3.2 ]

A.14.5.3.2

SAE J2343, Recommended Practice for LNG Medium and Heavy-Duty Powered Vehicles ,drop and heat leak testing should be used to establish the final test criteria for acceptance forheat leak testing.


Delete A.14.5.3.2 entirely.

14.5.3.2 is hold time requirements. SAE J2343 does not include “heat leak testing” requirements. SAE J2343 drop test is not appropriate as final test criteria for heat leak testing

14.5.3.2 hold time requirements are clearly written without need for further instructions




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Technical Committee on Vehicular Alternative Fuel Systems

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Transcript of Technical Committee on Vehicular Alternative Fuel Systems