National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org

MEMORANDUM TO: NFPA Technical Committee on Liquefied Petroleum Gases FROM: Jenny Depew, Administrator, Technical Projects DATE: January 4, 2013 SUBJECT: NFPA 58, Proposed TIA No. 1074, TC Ballot FINAL

____________________________________________________________________________ According to 5.4 in the NFPA Regs., the final results show this TIA HAS NOT achieved the ¾ majority vote needed on both Question 1 (Technical Merit) and Question 2 (Emergency Nature): 29 Eligible to Vote 8 Not Returned (Belke, Dimopoulos, Fossa, Garza-Obregon, Kastanas, King, Meyer, Wilson) Technical Merit:

Emergency Nature:

6 Abstentions (Burnell, Freeman, Osterhaus, Stainbrook, Swiecicki, Woodward)

2 Abstentions (Burnell, Freeman)

5

Agree (w/comment: Barber)

4

Agree (w/comment: Barber)

10 Disagree (Coates, Fredenburg, Gentry, Mahnken, Mahre, McTier, Mortimer, Raj, Ruffcorn, Zeman)

15 Disagree (Coates, Fredenburg, Gentry, Hoffman, Mahnken, Mahre, McTier, Mortimer, Osterhaus, Raj, Ruffcorn, Stainbrook, Swiecicki, Woodward, Zeman )

There are two criteria necessary to pass ballot [(1) affirmative ¾ vote and (2) simple majority] with both questions needing to pass ballot in order to recommend that the Standards Council issues this TIA. (1) The number of affirmative votes needed for the report to be published is 12.

Technical Merit: (29 eligible to vote - 8 not returned - 6 abstentions = 15 × 0.75 = 11.25 = 12) Emergency Nature: (29 eligible to vote - 8 not returned - 2 abstentions = 19 × 0.75 = 14.25 = 15)

(2) In all cases, an affirmative vote of at least a simple majority of the total membership eligible to vote is

required. This is the calculation for simple majority: [29 eligible ÷ 2 = 14.5 = (15)] Final ballot comments are attached for your review. Ballots received from alternate members are not included, unless the ballot from the principal member was not received. Attachments

EMAIL Ballot Submission: From: Fredenburg, Richard G Sent: Thursday, December 27, 2012 10:50 PM To: Depew, Jenny Subject: NFPA 58 TIA Log No. 1074 TC Ballot  I vote disagree on technical merit and emergency nature.  Not that I am against this matter if it is confirmed by a peer review.  There are too many formulas and equations with no independent review and not enough references.  What is presented is of too technical a nature for a quick review by the committee.  With these concerns and with no related problems with relief valves, the speedy need to make these changes is not evident and does not, to my mind, meet the definitions of emergency nature in section 5.2  Richard Fredenburg  LP-Gas Engineer 

TECHNICAL COMMITTEE LETTER BALLOT PROPOSED TENTATIVE INTERIM AMENDMENT LOG NO. 1074

To insert a new item Section 5.2.8.3(C)(7), renumbering subsequent items accordingly, Revise Sections 5.7.2.5(A), 5.7.2.6, Delete Table 5.7.2.6, Revise Sections 5.7.2.7, 5.7.2.8, and E.2.2

of the 2011 Edition and Proposed 2014 Edition of NFPA 58, Liquefied Petroleum Gas Code

Question 1: I agree with the TECHNICAL MERITS of the Proposed TIA to insert a new item Section 5.2.8.3(C)(7), renumbering subsequent items accordingly, Revise Sections 5.7.2.5(A), 5.7.2.6, Delete Table 5.7.2.6, and Revise Sections 5.7.2.7, 5.7.2.8, and E.2.2 ____________ AGREE _______X_____ DISAGREE* ____________ ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation must accompany a disagreement or abstaining position.

The Compressed Gas Association is the publisher of CGA S-1.1, S-1.2 and S-1.3. These

Publications are referenced by DOT, TC, ASME and other organizations. These

pressure relief device standards are open to the public to comment upon using the CGA

proposed change system (www.cganet.com). The proposals are reviewed by the

experts and are accepted, modified or rejected. No comments have been received by

the CGA concerning the formulas in the CGA Publications. Likewise, no incidents have

been reported indicating that the long standing published formulas are incorrect or

causing accidents.

This information is new business and should be reviewed by the experts of CGA, NFPA

and NPGA.

Question 2: I agree that the subject is of an EMERGENCY NATURE. ____________ AGREE ______X______ DISAGREE* ____________ ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation must accompany a disagreement or abstaining position.

With all due respect, no comments or reports have been received by the CGA

concerning the formulas in the CGA Publications. Likewise, no incidents have been

reported indicating that the long standing published formulas are incorrect or causing

accidents.

Steven T Gentry Signature

TECHNICAL COMMITTEE LETTER BALLOT PROPOSED TENTATIVE INTERIM AMENDMENT LOG NO. 1074

To insert a new item Section 5.2.8.3(C)(7), renumbering subsequent items accordingly, Revise Sections 5.7.2.5(A), 5.7.2.6, Delete Table 5.7.2.6, Revise Sections 5.7.2.7, 5.7.2.8, and E.2.2

of the 2011 Edition and Proposed 2014 Edition of NFPA 58, Liquefied Petroleum Gas Code

Question 1: I agree with the TECHNICAL MERITS of the Proposed TIA to insert a new item Section 5.2.8.3(C)(7), renumbering subsequent items accordingly, Revise Sections 5.7.2.5(A), 5.7.2.6, Delete Table 5.7.2.6, and Revise Sections 5.7.2.7, 5.7.2.8, and E.2.2 ____________ AGREE _______X_____ DISAGREE* ____________ ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation must accompany a disagreement or abstaining position. _____________________________________________________________________ The basis for the proposed changes needs to be vetted before being introduced into the code. _____________________________________________________________________

_____________________________________________________________________

Question 2: I agree that the subject is of an EMERGENCY NATURE. ____________ AGREE _______X_____ DISAGREE* ____________ ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation must accompany a disagreement or abstaining position. _____________________________________________________________________ The substantiation does not clearly demonstrate how the existing calculation method results in inadequate relief valve sizing. Comparison examples are needed

____________ Signature Glenn Mahnken ________________________________ Name (Please Print) _________Dec 27, 2012 Date Please return the ballot on or before December 27, 2012. PLEASE RETURN TO: Jenny Depew, Administrator, Technical Projects NFPA 1 Batterymarch Park Quincy, MA 02169 FAX: (617) 984-7070 E-mail: jdepew@nfpa.org

TECHNICAL COMMITTEE LETTER BALLOT PROPOSED TENTATIVE INTERIM AMENDMENT LOG NO. 1074

To insert a new item Section 5.2.8.3(C)(7), renumbering subsequent items accordingly, Revise Sections 5.7.2.5(A), 5.7.2.6, Delete Table 5.7.2.6, Revise Sections 5.7.2.7, 5.7.2.8, and E.2.2

of the 2011 Edition and Proposed 2014 Edition of NFPA 58, Liquefied Petroleum Gas Code

Question 1: I agree with the TECHNICAL MERITS of the Proposed TIA to insert a new item Section 5.2.8.3(C)(7), renumbering subsequent items accordingly, Revise Sections 5.7.2.5(A), 5.7.2.6, Delete Table 5.7.2.6, and Revise Sections 5.7.2.7, 5.7.2.8, and E.2.2 ____________ AGREE _____X_______ DISAGREE* ____________ ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation must accompany a disagreement or abstaining position.

The changing of a long term practice without other experts agreeing in advance on this complicated practice should not be considered by the Committee.

Question 2: I agree that the subject is of an EMERGENCY NATURE.

____________ AGREE ______X______ DISAGREE* ____________ ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation must accompany a disagreement or abstaining position.

We have been operating with the present practice without known safety problems on pressure relief valves. We know of no emergencies on this present practice _____________________________________________________________________

Samuel Mctier Signature Name (Please Print) 12/27/2012 ________________________________ Date Please return the ballot on or before December 27, 2012. PLEASE RETURN TO: Jenny Depew, Administrator, Technical Projects NFPA 1 Batterymarch Park Quincy, MA 02169  

TECHNICAL COMMITTEE LETTER BALLOT PROPOSED TENTATIVE INTERIM AMENDMENT LOG NO. 1074

To insert a new item Section 5.2.8.3(C)(7), renumbering subsequent items accordingly, Revise Sections 5.7.2.5(A), 5.7.2.6, Delete Table 5.7.2.6, Revise Sections 5.7.2.7, 5.7.2.8, and E.2.2

of the 2011 Edition and Proposed 2014 Edition of NFPA 58, Liquefied Petroleum Gas Code

Question 1: I agree with the TECHNICAL MERITS of the Proposed TIA to insert a new item Section 5.2.8.3(C)(7), renumbering subsequent items accordingly, Revise Sections 5.7.2.5(A), 5.7.2.6, Delete Table 5.7.2.6, and Revise Sections 5.7.2.7, 5.7.2.8, and E.2.2 ____________ AGREE _____X_______ DISAGREE* ____________ ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation must accompany a disagreement or abstaining position. The current code has been used for a long time and the current method appears to be adequate.

Question 2: I agree that the subject is of an EMERGENCY NATURE. ____________ AGREE ____X_______ DISAGREE* ____________ ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation must accompany a disagreement or abstaining position. The subject can be brought before the TC during the next revision cycle. Not an eminent hazard that needs to be addressed before the next cycle. _____________________________________________________________________

_____________________________________________________________________

Frank. J Mortimer Signature Dec 20, 2012 Please return the ballot on or before December 27, 2012. PLEASE RETURN TO: Jenny Depew, Administrator, Technical Projects NFPA 1 Batterymarch Park Quincy, MA 02169 FAX: (617) 984-7070 E-mail: jdepew@nfpa.org

TECHNICAL COMMITTEE LETTER BALLOT PROPOSED TENTATIVE INTERIM AMENDMENT LOG NO. 1074

To insert a new item Section 5.2.8.3(C)(7), renumbering subsequent items accordingly, Revise Sections 5.7.2.5(A), 5.7.2.6, Delete Table 5.7.2.6, Revise Sections 5.7.2.7, 5.7.2.8, and E.2.2

of the 2011 Edition and Proposed 2014 Edition of NFPA 58, Liquefied Petroleum Gas Code

Question 1: I agree with the TECHNICAL MERITS of the Proposed TIA to insert a new item Section 5.2.8.3(C)(7), renumbering subsequent items accordingly, Revise Sections 5.7.2.5(A), 5.7.2.6, Delete Table 5.7.2.6, and Revise Sections 5.7.2.7, 5.7.2.8, and E.2.2 ____________ AGREE _____X_______ DISAGREE* ____________ ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation must accompany a disagreement or abstaining position. _____________________________________________________________________ The model provided as justification for the corrections proposed seems to have serious

problems. This model has assumptions and analyses steps that are not justifiable from

a scientific perspective. The model needs to be peer reviewed before being

incorporated into a Standard.

_____________________________________________________________________

Question 2: I agree that the subject is of an EMERGENCY NATURE. ____________ AGREE _____X_______ DISAGREE* ____________ ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation must accompany a disagreement or abstaining position. _____________________________________________________________________ There is no justification for emergency in sizing relief valves. We are not informed (in

the justification) of any immediate serious safety problems confronting the propane

industry that requires an urgent attention, and which require implementing changes to

the current requirements in NFPA 58. ___________________

Signature

PHANI K. RAJ 24th December 2012

TECHNICAL COMMITTEE LETTER BALLOT PROPOSED TENTATIVE INTERIM AMENDMENT LOG NO. 1074

To insert a new item Section 5.2.8.3(C)(7), renumbering subsequent items accordingly, Revise Sections 5.7.2.5(A), 5.7.2.6, Delete Table 5.7.2.6, Revise Sections 5.7.2.7, 5.7.2.8, and E.2.2

of the 2011 Edition and Proposed 2014 Edition of NFPA 58, Liquefied Petroleum Gas Code

Question 1: I agree with the TECHNICAL MERITS of the Proposed TIA to insert a new item Section 5.2.8.3(C)(7), renumbering subsequent items accordingly, Revise Sections 5.7.2.5(A), 5.7.2.6, Delete Table 5.7.2.6, and Revise Sections 5.7.2.7, 5.7.2.8, and E.2.2 ____________ AGREE _____XX_______ DISAGREE* ____________ ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation must accompany a disagreement or abstaining position. *As part of an NFPA 59 Task Group reviewing the technical merits of this proposal, we have discovered a few errors in the calculations. Therefore I can not endorse this proposal as presented.

Question 2: I agree that the subject is of an EMERGENCY NATURE. ____________ AGREE _____XX_______ DISAGREE* ____________ ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation must accompany a disagreement or abstaining position. _____________________________________________________________________ *There have not been many problems using the existing methods, therefore, I see no need to agree that this meets the requirements of an emergency nature. _____________________________________________________________________

Signature

Steve Ruffcorn_______________________________ Name (Please Print) December 27, 2012_______________________________ Date Please return the ballot on or before December 27, 2012. PLEASE RETURN TO: Jenny Depew, Administrator, Technical Projects NFPA 1 Batterymarch Park

TECHNICAL COMMITTEE LETTER BALLOT PROPOSED TENTATIVE INTERIM AMENDMENT LOG NO. 1074

To insert a new item Section 5.2.8.3(C)(7), renumbering subsequent items accordingly, Revise Sections 5.7.2.5(A), 5.7.2.6, Delete Table 5.7.2.6, Revise Sections 5.7.2.7, 5.7.2.8, and E.2.2

of the 2011 Edition and Proposed 2014 Edition of NFPA 58, Liquefied Petroleum Gas Code

Question 1: I agree with the TECHNICAL MERITS of the Proposed TIA to insert a new item Section 5.2.8.3(C)(7), renumbering subsequent items accordingly, Revise Sections 5.7.2.5(A), 5.7.2.6, Delete Table 5.7.2.6, and Revise Sections 5.7.2.7, 5.7.2.8, and E.2.2 ____________ AGREE ____________ DISAGREE* ______X______ ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation must accompany a disagreement or abstaining position. _____________________________________________________________________ __This is a subject that needs to have more discussion in front of the committee.

_____________________________________________________________________

Question 2: I agree that the subject is of an EMERGENCY NATURE. ____________ AGREE ____________ DISAGREE* _______X_____ ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation must accompany a disagreement or abstaining position. _____________________________________________________________________ ____There has not been any documentation presented that states the existing section in

the standard is not adequate until more discussion be had at a committee meeting.

___________________

_____________________________________________________________________

________________________________ Signature _____David Burnell___________________________ Name (Please Print) ______12/24/2012__________________________ Date Please return the ballot on or before December 27, 2012. PLEASE RETURN TO: Jenny Depew, Administrator, Technical Projects

TECHNICAL COMMITTEE LETTER BALLOT PROPOSED TENTATIVE INTERIM AMENDMENT LOG NO. 1074

To insert a new item Section 5.2.8.3(C)(7), renumbering subsequent items accordingly, Revise Sections 5.7.2.5(A), 5.7.2.6, Delete Table 5.7.2.6, Revise Sections 5.7.2.7, 5.7.2.8, and E.2.2

of the 2011 Edition and Proposed 2014 Edition of NFPA 58, Liquefied Petroleum Gas Code

Question 1: I agree with the TECHNICAL MERITS of the Proposed TIA to insert a new item Section 5.2.8.3(C)(7), renumbering subsequent items accordingly, Revise Sections 5.7.2.5(A), 5.7.2.6, Delete Table 5.7.2.6, and Revise Sections 5.7.2.7, 5.7.2.8, and E.2.2 ____________ AGREE ____________ DISAGREE* ______X_____ ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation must accompany a disagreement or abstaining position. __ I abstain because I lack the technical qualifications to assess the proposal. The proposal is extensive and there is insufficient time to understand it and give it full consideration. Question 2: I agree that the subject is of an EMERGENCY NATURE. ____________ AGREE ____________ DISAGREE* _______X____ ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation must accompany a disagreement or abstaining position. The proponent argues that relief valves could theoretically be incorrectly sized using calculations currently given. However, I am unaware of any incident showing that this has occurred or is likely to occur.

____James R Freeman III__ Signature ________________________________ Name (Please Print) ________12/22/2012_____________________ Date Please return the ballot on or before December 27, 2012. PLEASE RETURN TO: Jenny Depew, Administrator, Technical Projects NFPA 1 Batterymarch Park Quincy, MA 02169 FAX: (617) 984-7070 E-mail: jdepew@nfpa.org

TECHNICAL COMMITTEE LETTER BALLOTPROPOSED TENTATIVE INTERIM AMENDMENT LOG NO. 1074

To insert a new item Section 5.2.8.3(C)(7), renumbering subsequent items accordingly,Revise Sections 5.7.2.5(A), 5.7.2.6, Delete Table 5.7.2.6, Revise Sections 5.7.2.7, 5.7.2.8, and E.2.2

of the 2011 Edition and Proposed 2014 Edition of NFPA 58, Liquefied Petroleum Gas Code

Question l: I agree with the TECHNICAL MERITS of the Proposed TIA to insert q new item Section5.2.8.3(C)(7), renumbering subsequent items accordingly, Revise Sections 5.7.2.5(A), 5.7.2.6, DeleteTable 5,7.2,6, qnd Revise Sections 5,7.2.7, 5,7.2.E, and E.2.2

AGREE DISAGREE* Yes ABSTAIN*

EXPLANATION OF VOTE - Please type or print your comments:

*An explanation must accompany a disagreement or abstaining position.

I'm not familiar enouoh with the calculations presented in the TIA to make an informed decision, so I willabstain.

Question 2:Iagree that the subject is of an EMERGENCY NATURE.

AGREE Yes DISAGREE* ABSTAIN*

EXPLANATION OF VOTE - Please type or print your comments:

*An explanation must accompany a disagreement or abstaining position.

As I recall, the information presented in this TIA was discussed at the last NFPA 58 Committeemeetinq. The current lanquaoe has been in the code since 1953 and no one was aware of anv issuesthat have resulted from usinq the current lanquaqe.

Name (Please Print)

12/14/12Date

Please return the ballot on or before December 27 2012.

PLEASE RETURN TO:Jenny Depew, Administrator, Technical Proj ectsNFPAI Batterymarch ParkQuincy, MA 02169 FAX: (617) 984-7070 E-mail: idepew@nfrra.org

TECHNICAL COMMITTEE LETTER BALLOT PROPOSED TENTATIVE INTERIM AMENDMENT LOG NO. 1074

To insert a new item Section 5.2.8.3(C)(7), renumbering subsequent items accordingly, Revise Sections 5.7.2.5(A), 5.7.2.6, Delete Table 5.7.2.6, Revise Sections 5.7.2.7, 5.7.2.8, and E.2.2 of the

2011 Edition and Proposed 2014 Edition of NFPA 58, Liquefied Petroleum Gas Code Question 1: I agree with the TECHNICAL MERITS of the Proposed TIA to insert a new item Section 5.2.8.3(C)(7), renumbering subsequent items accordingly, Revise Sections 5.7.2.5(A), 5.7.2.6, Delete Table 5.7.2.6, and Revise Sections 5.7.2.7, 5.7.2.8, and E.2.2

AGREE DISAGREE* _X ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments:

*An explanation must accompany a disagreement or abstaining position.

The proposal is very complicated and I do not have enough time to spend evaluating it before the ballot deadline. However, it appears that the proposal would result in code text that is much more difficult to understand and comply with.

Question 2: I agree that the subject is of an EMERGENCY NATURE. AGREE x DISAGREE* ABSTAIN*

EXPLANATION OF VOTE - Please type or print your comments:

*An explanation must accompany a disagreement or abstaining position.

NFPA 58 has been using the same procedure for sizing relief valves for many decades, apparently without any problems, Although Mr. Stannard’s proposal may have merit, I do not consider it to be an emergency We should take the time necessary to evaluate it completely.

Bruce Swiecicki Signature

Name (Please Print)

Date Please return the ballot on or before December 27, 2012.

PLEASE RETURN TO:

Reply to the TIA No 1074 from member Don Barber. 23rd December 2012 Before commenting on the TIA I would like to pay further tribute to the submitter, the late James Stannard. Obviously James Stannard cannot now reply to any points arising. However (prior to the time of his submission) in his role as my alternate he discussed his objectives with me; and also arranged for me to receive a copy of all the files on the subject. These date back as far as 1928, and the data is considerable. Regarding the submission. I support the proposals for the TIA, and the Emergency Nature, subject to the following. It is my professional opinion that the submission requires expanding to cover other aspects arising from it. This is an opinion based on the many instances where I have engaged in discussions on this subject.

The formulae and calculations in the proposal should be validated for accuracy, by a competent academic, before being considered for acceptance by the Standards Council in March 2013.

The proposed rate of heat transfer to the tank contents should be expanded to cover the range of heat transfer rates now known to apply. The difference in heat input between a pool fire and a jet fire should be taken into account. (ref 1).

The proposal for a 10% rating for mounded storage tanks should be qualified on the following basis. For a fully mounded tank fire engulfment is impossible, and the heat transfer method to calculate relief valve flow rates becomes inappropriate. In many instances a technical case can be developed concluding that no pressure relief is required. Having no pressure relief is an unacceptable situation, and the 10% rule can be substantiated and applied. For large mounded installations a Risk Assessment should be carried out, including an evaluation of the potential for the relief valves opening due to overfilling. (ref 2). In such circumstances the input flow rate will determine the relief valve flow capacity required. It should be noted that the discharge will be liquid phase LPG, or an aerosol mixture of liquid and vapour. The capacity calculation becomes difficult.

Before confirming the TIA the submission should be discussed with the API, who has a vested interest in the currently used method of calculation. The same formulae are also in use in the UK. I am prepared to liaise with the relevant organisations here to explain the NFPA decision once it has been agreed.

Ref1.TheInstituteofPetroleum(NowTheEnergyInstitute)–Guidelinesforthedesignandprotectionofpressuresystemstowithstandseverefires.Ref2.TheEnergyInstitute(FormerlytheInstituteofPetroleum).EIResearchreport:Hazardandriskassessmentforbulkliquefiedpetroleumgasstorageevents.Published2010.