technical committee on wood and cellulosic …...georgia-pacific llc 133 peachtree street, 7th floor...
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National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org
TECHNICAL COMMITTEE ON WOOD AND CELLULOSIC MATERIALS
PROCESSING
NFPA 664 CMD-WOO (A2016)
Second Draft Meeting
Ritz-Carlton-Atlanta
181 Peachtree Street, NE
Atlanta, GA 30303
July 14th and 15th, 2015 from 8:00 am to 5:00 pm
1. Meeting is called to order at 8 AM each day.
2. Welcome and Self-Introduction of Committee Members and Guests
3. Chair and Staff Liaison Remarks
4. Approve Minutes from the last meeting (attached)
5. Review of Correlating Committee Notes
6. NFPA 664 Second Draft Comments
a. Public Comments
b. Committee Comments – develop and action as required
7. Other Business
9. Adjournment – Meeting will adjourn at 5 pm each day.
Address List No PhoneWood and Cellulosic Materials Processing CMD-WOO
Combustible Dusts
Susan Bershad06/12/2015
CMD-WOO
Jason P. Reason
ChairLewellyn Technology2518 Thorium Drive, Apt 3Greenwood, IN 46143
SE 8/5/2009CMD-WOO
Robert C. Berry
PrincipalLiberty Mutual Insurance Company1508 Beech CircleWilkesboro, NC 28697-2602Alternate: Paul G. Parker
I 7/24/1997
CMD-WOO
Brice Chastain
PrincipalGeorgia-Pacific LLC133 Peachtree Street NE, 9th FloorAtlanta, GA 30303Alternate: Richard F. Masta
U 8/5/2009CMD-WOO
John M. Cholin
PrincipalJ. M. Cholin Consultants Inc.101 Roosevelt DriveOakland, NJ 07436
SE 1/1/1992
CMD-WOO
Stephen E. Dale
PrincipalCincinnati Insurance Company6200 South Gilmore RoadFairfield, OH 45014-5141Alternate: James Yeater
I 08/09/2012CMD-WOO
Ashok Ghose Dastidar
PrincipalFauske & Associates, LLC16W070 83rd StreetBurr Ridge, IL 60527-5802
SE 8/9/2011
CMD-WOO
Randal R. Davis
PrincipalIEP Technologies417-1 South StreetMarlborough, MA 01752-3149Alternate: Peter Karalis
M 7/14/2004CMD-WOO
Scott E. Dillon
PrincipalCrane Engineering2355 Polaris Lane North, Suite 120Plymouth, MN 55447-4777
SE 10/28/2014
CMD-WOO
Dennis W. Eaves
PrincipalBeecher Carlson3415 Kingsland CircleBerkeley Lake, GA 096-6170
I 7/24/1997CMD-WOO
Harvey Eng
PrincipalFM Global165 Commerce Valley DriveThornhill, ON L3T 7V8 Canada
I 4/14/2005
CMD-WOO
Sam W. Francis
PrincipalAmerican Wood Council1 Dutton Farm LaneWest Grove, PA 19390Alternate: Kenneth E. Bland
U 7/1/1996CMD-WOO
Dan A. Guaricci
PrincipalATEX Explosion Protection, L.P.2629 Waverly Barn Road, Suite 121Davenport, FL 33897
M 4/1/1997
CMD-WOO
Peter Levitt
PrincipalSternvent Division of Durex, Inc.5 Stahuber AvenueUnion, NJ 07083-5086
M 4/17/1998CMD-WOO
John Lysy
PrincipalAcadia Insurance Company20 St. Laurent DriveHudson, NH 03051
I 9/30/2004
1
Address List No PhoneWood and Cellulosic Materials Processing CMD-WOO
Combustible Dusts
Susan Bershad06/12/2015
CMD-WOO
Arthur P. Mattos, Jr.
PrincipalGlobal Risk Consultants3216 Tatting RoadMatthews, NC 28105-7181
SE 04/04/1997CMD-WOO
Ken J. Mayeaux
PrincipalInternational Paper CompanyGlobal Risk Management6400 Poplar AvenueTower 3, Room 7-006Memphis, TN 38197
U 04/16/1999
CMD-WOO
Bruce McLelland
PrincipalFike Corporation704 SW 10th StreetBlue Springs, MO 64015-4263Alternate: Adam Morrison
M 08/11/2014CMD-WOO
Timothy J. Myers
PrincipalExponent, Inc.9 Strathmore RoadNatick, MA 01760-2418
SE 4/14/2005
CMD-WOO
Jeffrey C. Nichols
PrincipalIndustrial Fire Prevention LLCPO Box 2046Milledgeville, GA 31059
M 03/07/2013CMD-WOO
Brian Noe
PrincipalCity Of Oshkosh5156 David DriveOshkosh, WI 54903
E 08/09/2012
CMD-WOO
Jack E. Osborn
PrincipalAirdusco, Inc.4739 Mendenhall Road SouthMemphis, TN 38141
M 3/4/2009CMD-WOO
Ronald C. Reynolds
PrincipalVirginia State Fire Marshal’s Office1005 Technology Park DriveGlen Allen, VA 23102
E 08/09/2012
CMD-WOO
Jeffrey R. Roberts
PrincipalXL Global Asset Protection Services128 Twin Oaks DriveBrandon, MS 39047-9027Alternate: Philippe Reid
I 04/08/2015CMD-WOO
James C. Stewart
PrincipalMarsh Risk ConsultingThree James Center1051 East Cary Street, Suite 900Richmond, VA 23219
I 1/17/1997
CMD-WOO
Francois Tanguay
PrincipalLouisiana Pacific Canada Ltd.426, Victoria, Suite 10Saint-Lambert, QC J4P 2H9 CanadaAlternate: Kerry D. Miller
U 3/15/2007CMD-WOO
Erdem A. Ural
PrincipalLoss Prevention Science & Technologies, Inc.2 Canton Street, Suite A2Stoughton, MA 02072
SE 3/4/2009
CMD-WOO
Daniel E. VanderHyde, Jr.
PrincipalGrand Rapids Fire Prevention Bureau38 Lagrave Avenue SEGrand Rapids, MI 49503-4206
E 08/09/2012CMD-WOO
Allen Wagoner
PrincipalFLAMEX, Inc.4365 Federal DriveGreensboro, NC 27410
M 3/4/2009
2
Address List No PhoneWood and Cellulosic Materials Processing CMD-WOO
Susan Bershad06/12/2015
CMD-WOO
Kenneth E. Bland
AlternateAmerican Forest & Paper Association1111 19th Street, Suite 800Washington, DC 20036American Wood CouncilPrincipal: Sam W. Francis
U 1/1/1990CMD-WOO
Peter Karalis
AlternateIEP Technologies417-1 South StreetMarlborough, MA 01752-3149Principal: Randal R. Davis
M 10/29/2012
CMD-WOO
Richard F. Masta
AlternateGeorgia-Pacific LLC133 Peachtree Street, 7th FloorAtlanta, GA 30303Principal: Brice Chastain
U 8/2/2010CMD-WOO
Kerry D. Miller
AlternateLouisiana Pacific Building Products, Inc.414 Union Street, Suite 2000Nashville, TN 37219-1757Principal: Francois Tanguay
U 08/09/2012
CMD-WOO
Adam Morrison
AlternateFike Corporation704 SW 10th StreetBlue Springs, MO 64015-4263Principal: Bruce McLelland
M 08/11/2014CMD-WOO
Paul G. Parker
AlternateLiberty Mutual Property4287 Arbor Club DriveMarietta, GA 30066Principal: Robert C. Berry
I 1/10/2008
CMD-WOO
Philippe Reid
AlternateXL Global Asset Protection Services390, 43rd AvenueLachine, PQ H8T 2H9 CanadaPrincipal: Jeffrey R. Roberts
I 03/07/2013CMD-WOO
James Yeater
AlternateCincinnati Insurance Company401 South East StreetPO Box 39Vanlue, OH 45890Principal: Stephen E. Dale
I 03/03/2014
CMD-WOO
Marvin Lewiton
Nonvoting MemberMassachusetts Department of Labor Standards1001 Watertown StreetWest Newton, MA 02465
E 08/09/2012CMD-WOO
Robert W. Nelson
Member Emeritus28 Wing RoadPO Box 418Pocasset, MA 02559
SE 7/1/1994
CMD-WOO
Lowell E. Pauli
Member EmeritusLowell E. Pauli & AssociatesPO Box 67109Milwaukie, OR 97268
SE 1/1/1978CMD-WOO
Susan Bershad
Staff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169-7471
04/16/2014
3
TECHNICAL COMMITTEE ON WOOD AND CELLULOSIC MATERIALS
PROCESSING
Minutes of Meeting – NFPA 664 First Draft Meeting August 19th – 20th, 2014
Member Attending
Jason Reason – chair Yes Principal
Robert C. Berry Yes Principal
Brice Chastain Yes Principal
John Cholin Yes Principal
Stephen Dale Yes Principal
Ashok Ghose Dastidar Yes Principal
Randal Davis No Principal
Harvey Eng Yes Principal
Sam Francis No Principal
Dan Guaricci Yes Principal
Peter Levitt Yes Principal
John Lysy Yes Principal
Arthur Mattos No Principal
Ken Mayeaux Yes Principal
Tim Myers Yes- by phone Principal
Jeffrey Nichols Yes Principal
Brian Noe No Principal
Jack Osborn Yes Principal
Ronald Reynolds Yes- by phone Principal
James Stewart No Principal
Francois Tanguay No Principal
Erdem Ural Yes- by phone Principal
Daniel VanderHyde Yes Principal
Allen Wagoner Yes Principal
Kenneth Bland No Alternate
Peter Karalis No Alternate
Richard Masta Yes Alternate
Kerry Miller No Alternate
Paul Parker No Alternate
Philippe Reid No Alternate
James Yeater No Alternate
Marvin Lewiton No Nonvoting Member
Robert Nelson No Member Emeritus
Lowell Pauli Member Emeritus
Susan Bershad Yes NFPA staff
Guy Colonna Yes NFPA staff
1.0 The meeting was called to order at 8 am by Jason Reason, chair. The attendees,
guests, and those attending via the web conference made self-introductions. 2.0 Guy Colonna, NFPA staff, introduced the new staff liaison, Susan Bershad, and gave a
presentation on the new process, the schedule for the A2016 cycle, and the committee membership. There are currently 24 voting members on the technical committee.
3.0 The committee reviewed and approved the minutes from the ROC meeting on October 12-14, 2010.
4.0 The committee reviewed and acted on the 24 public input received for NFPA 664. 5.0 The committee generated first revisions based on input from the committee
members. 6.0 The committee created first revisions to eliminate the exceptions in the document,
which are not allowed per the NFPA manual of style requirements. 7.0 A total of 60 first revisions were created. This includes those created in response to
public input, those created based on input from committee members, and those created to eliminate the exception language.
8.0 A task group was established to review the particle size criteria in the combustible dust definition and associated annex material. Members of this task group include Erdem Ural, Ashok Dastidar, and John Cholin. If anyone else is interested in joining this group, they should contact NFPA staff or the chair.
9.0 The meeting adjourned at 5 PM on August 19th, and at 7:30 PM on August 20th. 10.0 The committee discussed the timing and location of the second draft meeting. A
decision was made to hold the second draft meeting after the NFPA annual meeting next June in Chicago. If there are any NITMAMs received on NFPA 652, they will be heard at the June, 2015 annual meeting, which will be held in Chicago June 22nd to the 25th. The committee decided to hold the second draft meeting July 13th and 14th in Atlanta, GA. Note: These dates were originally chosen to coordinate with the NFPA 61 second draft meeting, which was to be held later in the same week. The schedule for the NFPA 61 meeting has changed, and the committee will be polled to determine if they would prefer to move the meeting to later in the same week.
Correlating Committee Note No. 1-NFPA 664-2015 [ Global Input ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Wed Jan 07 16:43:35 EST 2015
Committee Statement
CommitteeStatement:
The 664 technical committee should review the definitions in Chapter 3 for consistency with 652.The definitions in Chapter 3 of 652 should be considered a baseline for those in the other dustdocuments. In some cases, the occupancy specific document may elect to define a term differently.In those cases, the rationale for the differences should be documented. Note that this comment isalso being made to the 61 and the 654 technical committees, and will be made to the 655 and 484committees as they go through their next revision cycle.
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Correlating Committee Note No. 13-NFPA 664-2015 [ Global Input ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: National Fire Protection Assoc
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 08 19:38:41 EST 2015
Committee Statement
CommitteeStatement:
The 664 technical committee should consider adding the language in the first draft of NFPA 61 onconflicts, section 1.4.1 and section 1.4.2.
1.4.1
Where a requirement specified in this industry-specific standard differs from a requirementspecified in NFPA 652, the requirement in this standard shall be permitted to be used instead.
1.4.2
Where a requirement specified in this standard specifically prohibits a requirement specified inNFPA 652, the prohibition in this standard shall be permitted.
The Correlating Committee believes that adding this to 664 would provide clarity to the user of thedocument. This recommendation is also being made to the 654 technical committee and will bemade to the 484 and the 655 technical committees as they enter their revisions cycles.
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Correlating Committee Note No. 16-NFPA 664-2015 [ Global Input ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: National Fire Protection Assoc
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 08 20:38:31 EST 2015
Committee Statement
CommitteeStatement:
The Correlating Committee recommends that the 664 TC consider pointing the user in thedirection of NFPA 87 for guidance on heat transfer systems. This may be best accomplishedthrough the addition of annex material
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Correlating Committee Note No. 17-NFPA 664-2015 [ Global Input ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: National Fire Protection Assoc
Street Address:
City:
State:
Zip:
Submittal Date: Fri Jan 09 10:45:30 EST 2015
Committee Statement
CommitteeStatement:
The 664 technical committee should consider including the language in Section 1.4.1 ofNFPA 654 -
1.4.1
This standard shall be used to supplement the requirements established by NFPA 652.
This clarifies the relationship between 652 and the commodity-specific standards.
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Correlating Committee Note No. 2-NFPA 664-2015 [ Global Input ]
Supplemental Information
File Name Description
652_outline_CC_meeting.docx
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Wed Jan 07 16:45:03 EST 2015
Committee Statement
CommitteeStatement:
The 664 technical committee should review the layout of the document for consistency with NFPA652. The chapter layout for the commodity specific standards should align with the layout of NFPA652 in order to facilitate their use with NFPA 652 in accordance with section 1.4.2 of NFPA 652. Thiscomment is also being made to the 654 and 61 technical committees, and will be made to the 655and 484 technical committees as they go through the next revision cycle.
The Correlating Committee is providing an outline taken from 652 to assist the commodity specificcommittees with their expected alignment to 652 over the next revision cycles. In addition the outlineincludes the level of subsection that a user would use to compare 652 to an industry specificstandard. This is the minimum level of alignment expected, the committee is free to go beyond thislevel. Note that the highlighted sections are those that should be used. It is expected that this maynot be able to be completed in the current revision cycle, but this a goal that committees should worktoward.
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652 Chapter 1 Administration
1.1 Scope
1.2 Purpose
1.3 Application
1.4 Conflicts
1.5 Retroactivity
1.6 Equivalency
1.7 Units and Formulas
Chapter 2 Referenced Publications
2.1 General
2.2 NFPA Publications.
2.3 Other Publications
2.4 References for Extracts in Mandatory Sections
Chapter 3 Definitions
Committees should align with 652 definitions
Chapter 4 General Requirements
4.1* General
4.2 Objectives
4.2.1 Life Safety
4.2.2* Mission Continuity
4.2.3 Mitigation of Fire Spread and Explosions
Chapter 5 Hazard Identification
5.1* Responsibility
5.2 Overview Screening for Combustibility and Explosibility
5.3* Self-Heating and Reactivity Hazards (Reserved)
5.4 Combustibility and Explosibility Tests
5.4.1* Determination of Combustibility
5.4.2 Determination of Flash Fire Hazard (Reserved)
5.4.3 Determination of Explosibility
5.4.4 Quantification of Combustibility and Explosibility Characteristics
5.5 Sampling
5.5.1 Sampling Plan
5.5.2 Mixtures
5.5.3 Representative Samples
Chapter 6 Performance-Based Design Option
6.1* General Requirements
6.1.12 Approved Qualifications
6.1.2* Document Requirements
6.1.4 Sources of Data
6.1.5* Maintenance of the Design Features
6.2 Risk Component and Acceptability (Reserved)
6.3 Performance Criteria
6.3.1 Life Safety
6.3.2 Structural Integrity
6.3.3 Mission Continuity
6.3.4 Mitigation of Fire Spread and Explosions
6.3.5 Effects of Explosions
6.4* Design Scenarios
6.4.1 Fire Scenarios
6.4.2 Explosion Scenarios
6.5 Evaluation of Proposed Design
Chapter 7 Dust Hazard Analysis
7.1* General Requirements
7.1.1 Responsibility
7.2 Criteria
7.2.1* Overview
7.2.2* Qualifications
7.2.4 Documentation
7.3 Methodology
7.3.1 General
7.3.2 Material Evaluation
7.3.3 Process Systems
7.3.4 Facility Compartments
Chapter 8 Hazard Management: Mitigation and Prevention
8.1 Inherently Safe Designs (Reserved)
8.2 Building Design
8.2.1* Construction
8.2.2 Building/Room Protection
8.2.3 Life Safety
8.2.5 Separation of Hazard Areas from Other Hazard Areas and from Other Occupancies
8.3 Equipment Design
8.3.1* Risk Assessment
8.3.2* Design for Dust Containment
8.3.3* Pneumatic Conveying, Dust Collection, and Centralized Vacuum Cleaning Systems
8.3.4 AMS Locations
8.3.5 Recycle of AMS Clean Air Exhaust AMS
8.3.6 Transfer Points (Reserved)
8.4 Housekeeping
8.4.1 General
8.4.2* Methodology
8.4.3 Training
8.4.4 Equipment (Reserved)
8.4.5 Vacuum Trucks
8.4.6 Frequency and Goal
8.4.7 Auditing and Documentation
8.5 Ignition Source Control
8.5.1* General
8.5.2* Risk Assessment
8.5.3 Hot Work
8.5.5 Bearings
8.5.6 Electrical Equipment and Wiring
8.5.7 Electrostatic Discharges
8.5.8 Open Flames and Fuel Fired Equipment
8.5.9 Industrial Trucks
8.5.10 Process Air and Media Temperatures
8.5.11 Self-Heating
8.5.12 Friction and Impact Sparks
8.6 Personal Protective Equipment
8.6.1 Workplace Hazard Assessment
8.6.2 Limitations of PPE Application (Flame-Resistant Garments)
8.6.3 Limitations of PPE to Combustible Dust Flash-Fires (Reserved)
8.6.4 Face, Hands, and Footwear Protection (Reserved)
8.x Pyrophoric Dusts (Reserved)
8.7 Dust Control
8.7.2* Liquid Dust Suppression Methods for Dust Control
8.7.3 Fans to Limit Accumulation (Reserved)
8.8 Explosion Prevention/Protection
8.8.1 General
8.8.2 Risk Assessment
8.8.3 Equipment Protection
8.8.4 Equipment Isolation
8.9 Fire Protection
8.9.1 General
8.9.3 Fire Extinguishers
8.9.4 Hose, Standpipes, Hydrants, and Water Supply
8.9.5 Automatic Sprinklers
8.9.6 Spark/Ember Detection and Extinguishing Systems
8.9.7 Special Fire Protection Systems
Chapter 9 Management Systems
9.1 Retroactivity
9.2* General
9.3 Operating Procedures and Practices
9.4 Inspection, Testing, and Maintenance
9.5 Training and Hazard Awareness
9.6 Contractors
9.6.3* Contractor Training
9.7 Emergency Planning and Response
9.8* Incident Investigation
9.9 Management of Change
9.10* Documentation Retention
9.11 Management Systems Review
9.12* Employee Participation
Correlating Committee Note No. 3-NFPA 664-2015 [ Global Input ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Wed Jan 07 16:46:41 EST 2015
Committee Statement
CommitteeStatement:
The 664 technical committee should review the document to ensure that retroactivity is handledconsistently. Those sections that are to be applied retroactively should be explicitly designated in thedocument section. Typically, management system elements that do not require capitalimprovements, such as training and housekeeping, are retroactive. This comment is also beingmade to the 61 and 654 technical committees and will be made to the 655 and the 484 technicalcommittees as they go through their next revision cycle
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Correlating Committee Note No. 4-NFPA 664-2015 [ Global Input ]
Supplemental Information
File Name Description
Draft_Objectives_for_CC_review.docx
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Wed Jan 07 17:00:45 EST 2015
Committee Statement
CommitteeStatement:
The 664 committee should consider aligning their objectives with those presented in attacheddocument developed by the correlating committee task group on objectives. The correlatingcommittee would like to work towards having all of the dust documents have similar objectives. Thisdocument is a product of a task group with representation from all of the combustible dustcommittees and represents the direction the correlating committee would like to head in. Thisrecommendation is also being made to the 61 and the 654 technical committees, and will be made tothe 484, 655, and 652 technical committees as they enter the next revision cycle.
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NFPA 652 – Draft Objectives for CC review (product of the objectives task group) 4.2 Objectives. 4.2.1 The design of the facility, processes and equipment shall be based upon the goal of providing a reasonable level of safety and property protection by meeting the following objectives:
1.) Life Safety 2.) Mission Continuity 3.) Mitigation of Fire Spread and Explosions
4.2.1.1 The objectives stated in Section 4.2 shall be interpreted as intended outcomes of this standard and not as prescriptive requirements.
4.2.1.2 The objectives stated in Section 4.2 shall be deemed to be met when, consistent with the goal in Section 4.2.1 and the provisions in Sections 1.4 and 1.6,
1.) the facility, processes and equipment are designed, constructed and maintained in accordance with the prescriptive criteria set forth in this standard, and
2.) The management systems set forth in this standard are implemented.
4.2.1.3 Where a performance-based alternative design is used, it shall be documented to meet the same objectives as the prescriptive design it replaces, in accordance with Chapter 6 of this standard.
4.2.2 Life Safety. The life safety objective shall be deemed to have been met when, consistent with the goal in Section 4.2.1 and the provisions in Sections 1.4 and 1.6, the occupants not in the immediate proximity of the ignition are protected from the effects of fires, flash-fires, and explosions for the time needed to evacuate, relocate, or take refuge in order to prevent serious injury. 4.2.3* Mission Continuity. The mission continuity objective shall be deemed to have been met when, consistent with the goal in Section 4.2.1 and the provisions in Sections 1.4 and 1.6, the protection features for the facility, processes and equipment limit damage to levels that ensure the ongoing mission, production, or operating capability of the facility to a degree acceptable to the owner/operator. A.4.2.3 Other stakeholders could also have mission continuity goals that will necessitate more stringent objectives as well as more specific and demanding performance criteria. The protection of property beyond maintaining structural integrity long enough to escape is actually a mission continuity objective.
The mission continuity objective encompasses the survival of both real property, such as the building, and the production equipment and inventory beyond the extinguishment of the fire. Traditionally, property protection objectives have addressed the impact of the fire on structural elements of a building as well as the equipment and contents inside a building. Mission continuity is concerned with the ability of a structure to perform its intended functions and with how that affects the structure's tenants. It often addresses post-fire smoke contamination, cleanup, and replacement of damaged equipment or raw materials. 4.2.4* Mitigation of Fire Spread and Explosions. The mitigation of fire spread and explosions shall be deemed to have been met when, consistent with the goal in Section 4.2.1 and the provisions in Sections 1.4 and 1.6, the prescribed or performance based alternative design features are incorporated into the facility and processes to prevent or mitigate fires and explosions that can cause failure of adjacent buildings or building compartments, or other enclosures, emergency life safety systems, adjacent properties, adjacent storage, or the facility's structural elements. A.4.2.4 Adjacent compartments share a common enclosure surface (wall, ceiling, floor) with the compartment of fire or explosion origin. The intent is to prevent the collapse of the structure during the fire or explosion. 4.2.5 Where a dust fire, deflagration, or explosion hazard exists within a process system, the hazards shall be managed in accordance with this standard. 4.2.6 Where a dust fire, deflagration, or explosion hazard exists with a facility compartment, the effects of the fire, deflagration, or explosion shall be managed in accordance with this standard. 4.2.7* Compliance Options. The objectives in Section 4.2 shall be achieved by either of the following means:
1. A prescriptive approach in accordance with Chapters 5, 7, 8, and 9 in conjunction with any additional prescriptive provisions of applicable commodity-specific NFPA standards.
2. A performance-based approach in accordance with Chapter 6.
A.4.2.7
Usually a facility or process system is designed using the prescriptive criteria until a prescribed solution is found to be infeasible or impracticable. Then the designer can use the performance-based option to develop a design, addressing the full range of fire and explosion scenarios and the impact on other prescribed design features. Consequently, facilities are usually designed not by using performance-based design methods for all facets of the facility but rather by using a mixture of both design approaches as needed.
Correlating Committee Note No. 5-NFPA 664-2015 [ Global Input ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Wed Jan 07 17:05:41 EST 2015
Committee Statement
CommitteeStatement:
The correlating committee recommends that the 664 TC review their response to PI -2 andPI-24 based on CN #4
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Correlating Committee Note No. 6-NFPA 664-2015 [ Global Input ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Wed Jan 07 17:13:29 EST 2015
Committee Statement
CommitteeStatement:
The correlating committee recommends that the 664 technical committee review its response toPI-32. 654 made several first revisions changing the term fire-resistance rating to fire-protectionrating for doors. The 664 committee should review the changes in 654 and ensure that it used theproper term throughout the document. This is a correlating issue between the documents.
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Correlating Committee Note No. 14-NFPA 664-2015 [ Section No. 1.1 [Excluding any
Sub-Sections] ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: National Fire Protection Assoc
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 08 20:36:35 EST 2015
Committee Statement
CommitteeStatement:
The correlating committee recommends that the 664 technical committee revise the scope of thedocument to be consistent with the structure of the scope statement in NFPA 61. This scope statesthe "standard provides requirements...". The correlating committee is working towards aligning thescope statements in all of the dust document to be consistent. This recommendation is also beingmade to the 654 TC and the 484 and 655 technical committees as they enter their revision cycles.
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Correlating Committee Note No. 7-NFPA 664-2015 [ New Section after 1.4.3 ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Wed Jan 07 17:18:09 EST 2015
Committee Statement
CommitteeStatement:
The correlating committee recommends that the 664 committee review this first revision in light ofthe negative comments received on the ballot. This criteria is not consistent with material in 652for triggering a dust hazard analysis.
First Revision No. 2-NFPA 664-2014 [New Section after 1.4.3]
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Correlating Committee Note No. 8-NFPA 664-2015 [ New Section after 3.3.20 ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Wed Jan 07 17:21:48 EST 2015
Committee Statement
CommitteeStatement:
The correlating committee recommends the 664 technical committee reconsider this FR based onthe negative comments received on the ballot. This term is used throughout this document as wellas the other dust documents and should be defined consistently, if it needs to be defined at all.
First Revision No. 35-NFPA 664-2014 [New Section after 3.3.20]
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Correlating Committee Note No. 12-NFPA 664-2015 [ Section No. 4.5 ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Wed Jan 07 17:35:46 EST 2015
Committee Statement
CommitteeStatement:
The 664 technical committee should review this section and correlate it with the material in 652on dust hazard analysis. This would ensure consistency between the two documents.
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Correlating Committee Note No. 11-NFPA 664-2015 [ New Section after 6.3 ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Wed Jan 07 17:33:02 EST 2015
Committee Statement
CommitteeStatement:
The 664 technical committee should consider extracting the definitions for separation,segregation, and detachment from 652 into this document. The material is extracted from 652, butthe terms are not defined. This will ensure consistency with 652.
First Revision No. 32-NFPA 664-2014 [New Section after 6.3]
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Correlating Committee Note No. 10-NFPA 664-2015 [ Section No. 7.4.1 ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Wed Jan 07 17:31:02 EST 2015
Committee Statement
CommitteeStatement:
The correlating committee recommends that the 664 technical committee review this FR inlight of the negative comments received on the ballot.
First Revision No. 16-NFPA 664-2014 [Section No. 7.4.1]
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Correlating Committee Note No. 9-NFPA 664-2015 [ Section No. 8.10.4.4 ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Wed Jan 07 17:28:33 EST 2015
Committee Statement
CommitteeStatement:
The correlating committee recommends that the 664 committee reconsider its action on this FRbased on the negative ballot comments. This material is in a section on storage and the use of theterm "storage" may be more consistent.
First Revision No. 57-NFPA 664-2014 [Section No. 8.10.4.4]
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Public Comment No. 2-NFPA 664-2015 [ Chapter 2 ]
Chapter 2 Referenced Publications
2.1 General.
The documents or portions thereof listed in this chapter are referenced within this standard and shall beconsidered part of the requirements of this document.
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2.2 NFPA Publications.
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National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471.
NFPA 10, Standard for Portable Fire Extinguishers, 2013 edition.
NFPA 11, Standard for Low-, Medium-, and High-Expansion Foam, 2016 edition.
NFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 2015 edition.
NFPA 13, Standard for the Installation of Sprinkler Systems, 2016 edition.
NFPA 14, Standard for the Installation of Standpipe and Hose Systems, 2016 edition.
NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection, 2017 edition.
NFPA 17, Standard for Dry Chemical Extinguishing Systems, 2013 edition.
NFPA 20, Standard for the Installation of Stationary Pumps for Fire Protection, 2016 edition.
NFPA 22, Standard for Water Tanks for Private Fire Protection, 2013 edition.
NFPA 24, Standard for the Installation of Private Fire Service Mains and Their Appurtenances, 2016edition.
NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems,2014 edition.
NFPA 30, Flammable and Combustible Liquids Code, 2015 edition.
NFPA 31, Standard for the Installation of Oil-Burning Equipment, 2016 edition.
NFPA 33, Standard for Spray Application Using Flammable or Combustible Materials, 2016 edition.
NFPA 34, Standard for Dipping, Coating, and Printing Processes Using Flammable or Combustible Liquids,2015 edition.
NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, 2014 edition.
NFPA 54, National Fuel Gas Code, 2015 edition.
NFPA 68, Standard on Explosion Protection by Deflagration Venting, 2013 edition.
NFPA 69, Standard on Explosion Prevention Systems, 2014 edition.
NFPA 70® , National Electrical Code®, 2017 edition.
NFPA 72® , National Fire Alarm and Signaling Code, 2016 edition.
NFPA 80, Standard for Fire Doors and Other Opening Protectives, 2016 edition.
NFPA 82, Standard on Incinerators and Waste and Linen Handling Systems and Equipment, 2014 edition.
NFPA 85, Boiler and Combustion Systems Hazards Code, 2015 edition.
NFPA 91, Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Particulate Solids,2015 edition.
NFPA101® , Life Safety Code®, 2015 edition.
NFPA 221, Standard for High Challenge Fire Walls, Fire Walls, and Fire Barrier Walls, 2015 edition.
NFPA 505, Fire Safety Standard for Powered Industrial Trucks Including Type Designations, Areas of Use,Conversions, Maintenance, and Operations, 2013 edition.
NFPA 600, Standard on Facility Fire Brigades, 2015 edition.
NFPA 652, Standard on the Fundamentals of Combustible Dusts,2016 edition.
NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing,and Handling of Combustible Particulate Solids, 2017 edition.
NFPA 750, Standard on Water Mist Fire Protection Systems, 2015 edition.
NFPA 780, Standard for the Installation of Lightning Protection Systems, 2017 edition.
NFPA 1600®, Standard on Disaster/Emergency Management and Business Continuity Programs, 2016edition.
NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems, 2015 edition.
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NFPA 2112, Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against FlashFire,2017 edition.
NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments forProtection of Industrial Personnel Against Short-Duration Thermal Exposures from Fire,2015 edition.
2.3 Other Publications.
2.3.1 ASME Publications.
American Society of Mechanical Engineers ASME International , Two Park Avenue, New York, NY10016-5990.
Boiler and Pressure Vessel Code, 2013 2015 .
ASME B31.1, Power Piping, 2014.
ASME B31.3, Chemical Plant and Petroleum Refinery Process Piping , 2012 2014 .
2.3.2 ASTM Publications.
ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959.
ASTM E1226, Standard Test Method for Explosibility of Dust Clouds, 2012A.
ASTM E1591, Standard Guide for Obtaining Data for Deterministic Fire Models, 2013.
2.3.3 Other Publications.
Merriam-Webster's Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, 2003.
2.4 References for Extracts in Mandatory Sections.
NFPA 13, Standard for the Installation of Sprinkler Systems, 2016 edition.
NFPA 68, Standard on Explosion Protection by Deflagration Venting, 2013 edition.
NFPA 652, Standard on the Fundamentals of Combustible Dust, 2016 edition.
NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing,and Handling of Combustible Particulate Solids, 2013 edition.
Statement of Problem and Substantiation for Public Comment
Updated ASME organization name, standard names, and editions.
Related Public Comments for This Document
Related Comment Relationship
Public Comment No. 3-NFPA 664-2015 [Chapter F]
Related Item
First Revision No. 3-NFPA 664-2014 [Chapter 2]
Submitter Information Verification
Submitter Full Name: Aaron Adamczyk
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Sat May 09 01:23:48 EDT 2015
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Public Comment No. 6-NFPA 664-2015 [ Section No. 4.4.1 [Excluding any Sub-Sections]
]
A deflagration hazard shall be determined deemed to exist where the in a building compartment when theaverage thickness of the layer of accumulated fugitive deflagrable wood dust on upward-facing surfaces
exceeds 3.2 mm ( 1⁄8 in.) over 5 percent of the area or 93 m 2 (1000 ft 2 ), whichever is smaller .
Statement of Problem and Substantiation for Public Comment
The area limitation of 1000 square feet or 5% of the floor area was brought from the annex to the body of the standard in the 2012 revision cycle without any technical substantiation that the area limitation is valid. The area limitation language should be returned to the annex where it is advisory but not strictly enforceable. There is no loss history that justifies this area limitation. There is no research that substantiates that the area limitation is correct. There are thousands of woodworking and wood processing facilities where this area limitation would impose substantial increased operating cost if it were being enforced. The truth is that the area limitation is being universally ignored.
Technical committees have an ethical obligation to make certain that the criteria in the standard are supported by hard fact, not supposition or hypothecation. The area limitation in 664 does NOT pass that test.
Related Item
First Revision No. 14-NFPA 664-2014 [Section No. 4.2.1]
Submitter Information Verification
Submitter Full Name: JOHN CHOLIN
Organization: J M CHOLIN CONSULTANTS INC
Street Address:
City:
State:
Zip:
Submittal Date: Thu May 14 11:41:41 EDT 2015
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Public Comment No. 8-NFPA 664-2015 [ Section No. 4.4.1 [Excluding any Sub-Sections]
]
A deflagration hazard shall be determined to exist where the layer of accumulated fugitive deflagrable wood
dust on upward-facing surfaces exceeds 3.2 mm ( 1⁄8 in.) over 5 percent of the area or 93 m2 (1000 ft2),whichever is smaller.
A deflagration hazard shall be deemed to exist where the layer of accumulated fugitive combustible dust onupward-facing surfaces exceeds 1/8th inch (3.2 mm) over all the facility areas.
Additional Proposed Changes
File Name Description Approved
Public_Input_Deflagration_Hazard.pdf Public Input on First Draft Revision #14
Statement of Problem and Substantiation for Public Comment
As currently written the article limits the combustible dust accumulation to 1/8’’ thick over 5% of the dust accumulation surface area or a 1,000 ft2, whichever is smaller; if not a deflagration hazard is deemed to exist. There are no technical justifications behind the surface area limitation and the layer depth criterion is not supported by the loss records in the woodworking/woodprocessing industry. First, historical tragic events relates to depth of combustible dust measured in inches rather than fractions of an inch. Second, it is clear from the loss history that there is no new proliferation of combustible dust explosions in the United States by maintaining dust accumulation in fraction of inches throughout all areas of wood processing facilities.
There is a very practical problems with the use of a threshold mass to establish the presence of a dust deflagration hazard in a lack of practical means of determining whether a threshold mass is present. As currently written, users will be unduly burdened with housecleaning frequency and thoroughness to maintain fugitive dust accumulation to levels that have not been adequately justified. And as currently written, users must assume the worst possible interpretation from regulatory authorities.
Related Item
First Revision No. 14-NFPA 664-2014 [Section No. 4.2.1]
Submitter Information Verification
Submitter Full Name: FRANCOIS TANGUAY
Organization: LOUISIANA PACIFIC CANADA LTD
Street Address:
City:
State:
Zip:
Submittal Date: Thu May 14 15:06:18 EDT 2015
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LPCorp.com |
Louisiana-Pacific Corporation
414 Union Street • Suite 2000
Nashville, TN 37219
T 615-986-5600
F 615-986-5666
May 14th, 2015 Attention: NFPA 664 Technical Committee
Object: Public Input
Reference: FR‐14, Section No. 4.2.1
All,
This public input refers to the above mentioned First Draft Revision #14. As currently written and currently revised, article 4.2.1 (of NFPA 664 2012 Edition) is imposing undue burden on woodworking facility operators regarding housekeeping requirements.
First Revision #14, Section 4.2.1
4.4.1
A deflagration hazard shall be determined to exist where the layer of accumulated fugitive deflagrable wood dust on upward-facing surfaces exceeds 3.2 mm (1⁄8 in.) over 5 percent of the area or 93 m2 (1000 ft2), whichever is smaller. For smaller areas, a deflagration hazard shall exist where the accumulated fugitive deflagrable wood dust layer is equivalent to 3.2 mm ( 1 ⁄8 in.) over 5 percent of the area.
4.4.1.1
For smaller areas, a deflagration hazard shall exist where the accumulated fugitive deflagrable wood dust layer is equivalent to 3.2 mm (1⁄8 in.) over 5 percent of the area.
4.4.1.2
A deflagration hazard shall be determined to exist unless otherwise determined by a dust hazard analysis, as described in Section 4.3 . For additional information, see Chapter 7 of NFPA 652.
Statement of Problem
As currently written the article limits the combustible dust accumulation to 1/8’’ thick over 5% of the dust accumulation surface area or a 1,000 ft2, whichever is smaller; if not a deflagration hazard is deemed to exist. There are no technical justifications behind the surface area limitation and the layer depth criterion is not supported by the loss records in the woodworking/woodprocessing industry. First, historical tragic events relates to depth of combustible dust measured in inches rather than fractions of an inch. Second, it is clear from the loss history that there is no new proliferation of combustible dust explosions in the United States by maintaining dust accumulation in fraction of inches throughout all areas of wood processing facilities.
There is a very practical problems with the use of a threshold mass to establish the presence of a dust deflagration hazard in a lack of practical means of determining whether a threshold mass is present. As currently written, users will be unduly burdened with housecleaning frequency and thoroughness to maintain fugitive dust accumulation to levels that have not been adequately justified. And as currently written, users must assume the worst possible interpretation from regulatory authorities.
LPCorp.com |
Louisiana-Pacific Corporation
414 Union Street • Suite 2000
Nashville, TN 37219
T 615-986-5600
F 615-986-5666
Technical Justification
A review of the surface area limitation and layer depth criteria currently used in NFPA 664 and 654 shows inconsistencies.
1. NFPA 664 Dust Layer Calculations
The dust layer calculations shown below that an building area of 40’x50’ (2000 ft2) by 10’ high, of which an area of 10’x10’ (100 ft2) is covered with 1/8’’ thick of combustible dust (typical wood dust of 0.06 oz/ft3 MEC and 15 lbs/ft3 density) would not create an explosive environment even if all the dust is suspended in air. In other to reach the MEC, the building area would need to be limited to 2.8 ft high (see case 3 in table below).
Since most wood processing facilities have building eaves height much higher than this 2.8 ft and since most of the critical combustible dust accumulation is located in hard to reach elevated locations, it has to be assumed that the building height has a major role affecting the dust concentration if ever that dust becomes suspended. Dust on the floor does not have the same propensity to become airborne/suspended in case of a primary explosion. For a facility with a 25 ft building eave height, more than 45% of the whole building area would need to be covered with 1/8’’ thick of combustible dust to reach the MEC if ever that dust would become suspended. For a facility with a 54.8 ft building eave height, the whole building would need to be covered with 1/8’’ thick of combustible dust to reach the MEC.
LPCorp.com |
Louisiana-Pacific Corporation
414 Union Street • Suite 2000
Nashville, TN 37219
T 615-986-5600
F 615-986-5666
2. NFPA 654 Deflagration Hazard
Using a typical mid-size OSB facility as the basis and using the equations found in NFPA 654 to determine if a deflagration hazard exists. Those facilities are built such that no separations exist in between all areas of the facility, but there are height differences. Building areas will be divided per the height differences, as the height impacts the allowable combustible dust accumulation.
According to NFPA 654 article 6.1.1.5, all the four (4) methods described shall be deemed to provide equivalent levels of safety.
Building Dimensions:
• Columns 1-11: 300’ x 250’ x 23’ 10’’ (eave height)
o Area: 75,000 ft2 (6,967 m2)
o Eave height: 7.26 m
• Columns 11-49: 200’ x 761.5’ x 54’ 10’’ (eave height)
o Area: 152,300 ft2 (14,147 m2)
o Eave height: 16.7 m
• Columns 49-61: 200’ x 279.5’ x 23’ 10’’ (eave height)
o Area: 55,900 ft2 (5,192 m2)
o Eave height: 7.26 m
Overall building area: 283,200 ft2
LPCorp.com |
Louisiana-Pacific Corporation
414 Union Street • Suite 2000
Nashville, TN 37219
T 615-986-5600
F 615-986-5666
#1: Layer Depth Criterion Method
• Limiting factor is the 1,000 ft2 (5% of 20,000 ft2) of areas of combustible dust
accumulation.
• Layer depth is adjusted for dust density. Using NFPA 664 20 lbs/ft3 for wood dust, the
layer depth corrects to 1/8’’. Layer depth = 1/32 x 75 / 20 = 0.117 (rounded to 1/8’’)
• A Dust Explosion Hazard would exist, if more than 1/8’’ thick of combustible dust
accumulates over a maximum of 1,000 ft2. This converts into 208 lbs of combustible
dust (1000 ft2 x (0.125 in / 12 in/ft) x 20 lbs/ft3)
#2: Mass Method A
• Limiting factors are surface areas at 2,000 m2 maximum and ceiling height of 12 meters.
• A Dust Explosion Hazard would exist:
o For areas of 2,000 m2 with 7.26 meters eave height, if the accumulated
combustible dust is above 58 kg (0.004 x 2000 x 7.26) or 128 lbs.
o For areas of 2,000 m2 with more than 12 meters eave height, if the accumulated
combustible dust is above 96 kg (0.004 x 2000 x 12) or 211 lbs.
• A Flash Fire Hazard would exist:
o For areas of 2,000 m2, if the accumulated combustible dust is above 40 kg (0.2 x
2000) or 88 lbs.
#3: Mass Method B
• No surface areas limitation.
• Enclosure strength needs to be determined. As per appendix D of NFPA 654, a building
with pre-engineered columns with metal siding on steel girts, the girts will fail at 0.036
bar of internal pressure. The metal siding would fail at 0.017 bar of internal pressure. If
potential damages to the metal siding is acceptable by the owner (LP), the maximum
internal pressure that the girts can support will be used to determine the maximum
allowable combustible dust accumulation.
• The Dynamic Load Factor needs to be determined. In the absence of such a
determination, a factor of 1.5 can be used.
• The worst case dust concentration at the maximum rate-of-pressure can be found in
CIBA test results for the Dryers Fines (0.750 kg/m3).
• The maximum pressure developed during the same above test is 8.3 bar.
• A Dust Explosion Hazard would exist if the combustible dust accumulation per building
areas is above those:
o Columns 1-11: 0.036 x 0.750 x 6,967 x 7.26 / (1.5 x 8.3 x 0.25) = 438 kg or 967 lbs
o Columns 11-49: 0.036 x 0.750 x 14,147 x 16.7 / (1.5 x 8.3 x 0.25) = 2,049 kg or
4,518 lbs
o Columns 49-61: 0.036 x 0.750 x 5,192 x 7.26 / (1.5 x 8.3 x 0.25) = 326 kg or 720
lbs
Total mass: 6,205 lbs
LPCorp.com |
Louisiana-Pacific Corporation
414 Union Street • Suite 2000
Nashville, TN 37219
T 615-986-5600
F 615-986-5666
• A Flash Fire Hazard would exist, if the combustible dust accumulation per building
areas is above those:
o Columns 1-11: 0.05 x 0.750 x (1/1+8.3) x 6,967 x 2 / 0.25 = 224 kg or 495 lbs
o Columns 11-49: 0.05 x 0.750 x (1/1+8.3) x 14,147 x 2 / 0.25 = 456 kg or 1,006 lbs
o Columns 49-61: 0.05 x 0.750 x (1/1+8.3) x 5,192 x 2 / 0.25 = 167 kg or 369 lbs
Total mass: 1,870 lbs
#4: Risk Evaluation Method
• A documented risk evaluation acceptable to the AHJ shall be permitted to be conducted
to determine whether or where a dust explosion hazard or dust flash fire hazard area
exists.
Conclusion
According to NFPA 654 article 6.1.1.5, all the four (4) methods described shall be deemed to provide equivalent levels of safety, but the above example show quite different allowable mass thresholds of combustible dust that would be deemed a deflagration hazard for the same facility, according to the current FR #14. The technical justification behind the limitations or equations used is not provided which does not allow a technical review of their basis.
Determination of how much of the accumulated fugitive combustible dust located on the floor (or other surfaces) will be dispersed and suspended in air during a primary incident and if that suspended dust concentration will be above the MEC, is not an easy task; but that difficulty shouldn’t be passed on the users for them to clean their facility to meet requirements that have not been demonstrated to be necessary.
Proposal
4.2.1 A deflagration hazard shall be deemed to exist where the layer of accumulated fugitive combustible dust on upward-facing surfaces exceeds 1/8th inch (3.2 mm) over all the facility areas.
Annex 4.2.1 A dust hazard analysis is highly recommended to help determine if the potential for a deflagration caused by fugitive combustible dust accumulation exist inside areas of the facility.
François Tanguay, ing./Eng. Regional Engineering Manager OSB North Region Louisiana-Pacific Canada Ltd Phone: (514) 800-7626 Cell: (514) 250-0337 Email: [email protected]
Public Comment No. 1-NFPA 664-2015 [ Section No. 4.8.3 ]
4.8.3 * Mission Continuity.
The facility, woodworking processes and equipment, and human element program shall be designed,constructed, equipped, and maintained to limit damage to levels that ensure the ongoing mission,production, or operating capability of the facility to a degree acceptable to the relevant authority havingjurisdiction.
Statement of Problem and Substantiation for Public Comment
The Technical Committee indicated it did not use PI 24 for a First Revision because the AHJ could be any number of agencies. But that is exactly why the BCDC submitted PI 24. The definition of AHJ is: “3.2.2* Authority Having Jurisdiction (AHJ). An organization, office, or individual responsible for enforcing the requirements of a code or standard, or for approving equipment, materials, an installation, or a procedure.” By this definition, the “relevant” AHJ is inferred, and the term “relevant” is unnecessary. The confusion is that the term “relevant” infers that there cannot be more than one AHJ.
Related Item
Public Input No. 24-NFPA 664-2014 [Section No. 4.6.3]
Submitter Information Verification
Submitter Full Name: Jim Muir
Organization: Building Safety Division, Clark County, WA
Affilliation: NFPA's Building Code Development Committee (BCDC)
Street Address:
City:
State:
Zip:
Submittal Date: Tue May 05 14:26:06 EDT 2015
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Public Comment No. 7-NFPA 664-2015 [ New Section after A.4.4.2 ]
A.4.4.1 Determination of Deflagration Hazard
This standard has used a layer depth criterion of 1/8th inch (3.2 mm) for many years as the criterion fordetermining where a deflagration hazard exists due to the accumulation of deflagrable wood dust. The losshistory in the forest products industries does not include events of building compartment deflagrations (flashfires) when the dust layers are as low as 1/8 inch (3.2 mm) in thickness. The losses have been in facilitieswhere the dust accumulations are far greater. Consequently, the 1/8th inch (3.2 mm) criterion appears tohave a substantial margin of safety.
In earlier editions of this standard there was advisory text in the annex that recommended that a 1,000square foot (93 m2) or 5% of the floor area limitation be considered when determining where a buildingcompartment deflagration hazard exists. This recommendation is based upon calculations, not loss history. In the last revision cycle those recommendations were moved to the body of the standard. With thisrevision the recommendations are being returned to this annex.
When a large building compartment is involved 1/8th inch of dust distributed evely over the entire area canresult in a substantial quantity of dust. If that quantity is all ignited a serious deflagration will result. But thisconclusion is reliant upon a number of simplifying assumptions in calculations used to support such aprediction. The lack of loss history with dust accumulations at the 1/8th inch (3.2 mm) thickness levelsuggests that some of those simplifying assumptions might not be valid. To date no research has beendone that provides advice on how valid those simplifying assumptions actually are. Since the designation ofa building compartment as a deflagration hazard places significant limitations on how processess areoperated in such an environment, the techncial committee has concluded that there must be a solidtechnical basis for making the area limitation an enforcable part of the standard. At this time that basis doesnot exist.
Statement of Problem and Substantiation for Public Comment
This comment provides annex text for 4.4.1 explaining the history of the area limitation and why it has been moved to the Annex.
Related Item
First Revision No. 14-NFPA 664-2014 [Section No. 4.2.1]
Submitter Information Verification
Submitter Full Name: JOHN CHOLIN
Organization: J M CHOLIN CONSULTANTS INC
Street Address:
City:
State:
Zip:
Submittal Date: Thu May 14 11:54:31 EDT 2015
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Public Comment No. 5-NFPA 664-2015 [ Section No. A.8.2.2.3.2(2) ]
A.8.2.2.3.2(2)
Abort gates are most commonly used on systems that have the air-moving device located upstream of anydust collection equipment (i.e., positive pressure systems). This arrangement facilitates clearing theductwork of all burning material by stopping material infeed and leaving the fan running when the abort gateactivates. This is the recommended arrangement and operating sequence when this alternative is used.Figure A.8.2.2.3.2(2)(a) shows the normal and aborted airflow conditions.
Figure A.8.2.2.3.2(2)(a) Aborting of Positive Pressure Systems.
It is possible, but more costly, to use two abort gates to accomplish the same duct-clearing operation onsystems that have the air-moving device located downstream from the collector. Figure A.8.2.2.3.2(2)(b)shows how this is done.
Figure A.8.2.2.3.2(2)(b) Aborting of Negative Pressure Systems.
Negative pressure systems without a bypass to the fan inlet will not clear material from the ductwork oncethe abort gate activates, and this design is not recommended. In an abort activation, this design requirescomplete interior inspection and cleaning or flushing of the ducting prior to abort reset and system restart tobe sure there are no smoldering embers lying in the duct.
There is a simple way to arrange an abort gate to divert burning material from the dust collector which doesachieve the need to purge the up-stream ducts of material. It is shown in Figure A.8.2.2.3.2(2)(c).
Figure A.8.2.2.3.2(2)(c)
Additional Proposed Changes
File Name Description Approved
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9 of 13 5/18/2015 10:30 AM
NFPA_664_Figure_Diversion_of_Sparks_from_DC.pdfOne means to divert sparks from a negative pressure dust collector
Statement of Problem and Substantiation for Public Comment
The figures in the annex have been misinterpreted by many as being the ONLY means by which the requirements can be met. this additional figure provides a more cost-effective means that is equally effective
Related Item
First Revision No. 27-NFPA 664-2014 [Section No. A.8.2.2.2.2(2)]
Submitter Information Verification
Submitter Full Name: JOHN CHOLIN
Organization: J M CHOLIN CONSULTANTS INC
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Submittal Date: Thu May 14 10:52:06 EDT 2015
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Diversion of Sparks with a Single Abort Gate
Diverted FlowNormal Operation
Public Comment No. 3-NFPA 664-2015 [ Chapter F ]
Annex F Informational References
F.1 Referenced Publications.
The documents or portions thereof listed in this annex are referenced within the informational sections ofthis standard and are not part of the requirements of this document unless also listed in Chapter 2 for otherreasons.
F.1.1 NFPA Publications.
National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471.
NFPA 1, Fire Code, 2015 edition.
NFPA 10, Standard for Portable Fire Extinguishers, 2013 edition.
NFPA 13, Standard for the Installation of Sprinkler Systems, 2016 edition.
NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection, 2012 edition.
NFPA 20, Standard for the Installation of Stationary Pumps for Fire Protection, 2013 edition.
NFPA 24, Standard for the Installation of Private Fire Service Mains and Their Appurtenances, 2013edition.
NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems,2014 edition.
NFPA 30, Flammable and Combustible Liquids Code, 2015 edition.
NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, 2014 edition.
NFPA 55, Compressed Gases and Cryogenic Fluids Code, 2013 edition.
NFPA 68, Standard on Explosion Protection by Deflagration Venting, 2013 edition.
NFPA 69, Standard on Explosion Prevention Systems, 2014 edition.
NFPA 70 ®, National Electrical Code ®, 2014 edition.
NFPA 72 ®, National Fire Alarm and Signaling Code, 2013 edition.
NFPA 77, Recommended Practice on Static Electricity, 2014 edition.
NFPA 80, Standard for Fire Doors and Other Opening Protectives, 2013 edition.
NFPA 80A, Recommended Practice for Protection of Buildings from Exterior Fire Exposures, 2012 edition.
NFPA 85, Boiler and Combustion Systems Hazards Code, 2015 edition.
NFPA 101 ®, Life Safety Code ®, 2015 edition.
NFPA 499, Recommended Practice for the Classification of Combustible Dusts and of Hazardous(Classified) Locations for Electrical Installations in Chemical Process Areas, 2013 edition.
NFPA 600, Standard on Facility Fire Brigades, 2015 edition.
NFPA 652, Standard on the Fundamentals of Combustible Dusts, 2016 edition.
NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing,and Handling of Combustible Particulate Solids, 2013 edition.
Fire Protection Guide to Hazardous Materials,2010.
Fire Protection Handbook, 20th edition, 2008.
Frank, T. 1981. “Fire and Explosion Control in Bag Filter Dust Collection Systems.” Fire Journal, March,73–94.
F.1.2 Other Publications.
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F.1.2.1 ACGIH Publications.
American Conference of Governmental Industrial Hygienists, 1330 Kemper Meadow Drive, Cincinnati, OH45240-1634.
Industrial Ventilation — A Manual of Recommended Practice, 28th edition, 2013.
F.1.2.2 ASME Publications.
American Society of Mechanical Engineers ASME International , Two Park Avenue, New York, NY10016-5990.
Boiler and Pressure Vessel Code, 2001 2015 .
F.1.2.3 ASTM Publications.
ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959.
ASTM E1226, Standard Test Method for Explosibility of Dust Clouds, 2012a.
ASTM E1355, Standard Guide for Evaluating the Predictive Capability of Deterministic Fire Models, 2012.
ASTM E1515, Standard Test Method for Minimum Explosible Concentration of Combustible Dusts, 2007.
F.1.2.4 FM Publications.
FM Global, 1301 Atwood 270 Central Avenue , P.O. Box 7500, Johnston, RI 02919.
FM 6-7, Fluidized Bed Combustors and Boilers,April 2012.
FM 6-13, Waste Fuel-Fired Boilers, May 2010.
FM 7-10, Wood Processing and Woodworking Facilities,2002 May 2010.
FM 7-11, Belt Conveyors,January 2012.
FM 7-73, Dust Collectors and Collection Systems,2000, 2002, January 2012.
FM 7-76, Prevention and Mitigation of Combustible Dust Explosions and Fires,April 2013.
FM 7-99, Heat Transfer by Organic and Synthetic Fluids, January 2014.
F.1.2.5 ISO Publications.
International Standards Organization , 1 Rue de Varembé for Standardization , ISO CentralSecretariat, BIBC II, 8, Chemin de Blandonnet , Case Postale 56, Ch-1211 Genève 20, 401 , 1214Vernier, Geneva , Switzerland.
ISO 6184-1, Explosion Protection Systems — Part 1: Determination of Explosion Indices of CombustibleDusts in Air, 1985.
ISO 6184-4, Explosion Protection Systems — Part 4: Determination of Efficiency of Explosion SuppressionSystems, 1985.
F.1.2.6 SFPE Publications.
Society of Fire Protection Engineers, 7315 Wisconsin Avenue 9711 Washington Blvd. , Suite 1225 W380 , Bethesda Gaithersburg , MD 20814 20878 .
SFPE Computer Software Directory.
SFPE Engineering Guide to Performance-Based Fire Protection, 2nd edition, 2008.
SFPE Handbook of Fire Protection Engineering, 4th edition, 2008.
F.1.2.7 U.S. Government Publications.
U.S. Government Printing Government Publishing Office, Washington, DC 20402.
Title 30, Code of Federal Regulations, Part 36, “Approval Requirements for Permissible Mobile Diesel-Powered Transportation Equipment,” 2005.
F.1.2.8 Other Publications.
Friedman, Raymond. 1992. “An International Survey of Computer Models for Fire and Smoke.” Journal ofFire Protection Engineering, 13(2), 87-110.
VDI 3673, Pressure Venting of Dust Explosions, 2002.
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F.2 Informational References.
The following documents or portions thereof are listed here as informational resources only. They are not apart of the requirements of this document.
NFPA 497, Recommended Practice for the Classification of Flammable Liquids, Gases, or Vapors and ofHazardous (Classified) Locations for Electrical Installations in Chemical Process Areas, 2012 edition.
F.3 References for Extracts in Informational Sections.
NFPA 68, Standard on Explosion Protection by Deflagration Venting, 2013 edition.
NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing,and Handling of Combustible Particulate Solids, 2013 edition.
Statement of Problem and Substantiation for Public Comment
Updated SDO names, addresses, standard names, numbers, and editions.
Related Public Comments for This Document
Related Comment Relationship
Public Comment No. 2-NFPA 664-2015[Chapter 2]
Updated SDO names, addresses, standard names, numbers,and editions.
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First Revision No. 13-NFPA 664-2014 [Chapter F]
Submitter Information Verification
Submitter Full Name: Aaron Adamczyk
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Sat May 09 01:29:25 EDT 2015
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