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Report on Proposals -- Copyright, NFPA

Report of the Committee on

Tank Leakage and Repair Safeguards Gary T. Austerman, Burns & McDonnell Engineering Co., MO [SE] Larry Beasley, Robert and Company, GA [SE] Paul E. Calderwood, City of Everett Fire Department, MA [E] Wayne Geyer, Steel Tank Institute, IL [M] Rep. Steel Tank Institute Richard S. Kraus, Petroleum Safety Consultants, VA [U] Rep. American Petroleum Institute James W. Naylor, Westinghouse Savannah River Co., SC [U] John F. Rekus, John F. Rekus & Associates, Ltd., MD [SE] Rep. American Industrial Hygiene Assn/Confined Spaces Committee Robert N. Renkes, Petroleum Equipment Institute, OK [M] Rep. Petroleum Equipment Institute Thomas M. Riddle, Tank Construction & Service Co., Inc., IN [IM] Joyce A. Rizzo, JD2 Environmental, Inc., PA [SE] Adam M. Selisker, Northampton Township Fire Department, PA [E] Robert P. Siegel, 3M Company, MN [U] Timothy R. Smith, US Environmental Protection Agency, DC [E] Edward J. Willwerth, Atlantic Environmental & Marine Services, Inc., MA [SE] Rep. Marine Chemists Association Inc. Alternates John H. Bagnall, Burns & McDonnell Engineering Company Inc., MO [SE] (Alt. to Gary T. Austerman) Leslie Blaize, Belay Incorporated, OR [SE] (Alt. to Edward J. Willwerth) Lorri Grainawi, Steel Tank Institute, IL [M] (Alt. to Wayne Geyer) Staff Liaison: Robert P. Benedetti

Committee Scope: This Committee shall have primary responsibility for documents on safeguarding against fire, explosion, and health hazards associated with entry, cleaning and repair of tank systems and methods for detecting, controlling, and investigating releases that could cause these hazards. This list represents the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A key to classifications is found at the front of this book. The Technical Committee on Tank Leakage and Repair Safeguards is presenting two Reports for adoption, as follows: Report I: The Technical Committee proposes for adoption, a complete revision to NFPA 326, Standard for the Safeguarding of Tanks and Containers for Entry, Cleaning, or Repair, 1999 edition. NFPA 326-1999 is published in Volume 8 of the 2003 National Fire Codes and in separate pamphlet form.

NFPA 326

NFPA 326 has been submitted to letter ballot of the Technical Committee on Tank Leakage and Repair Safeguards, which consists of 14 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report. Report II: The Technical Committee proposes for adoption, a complete revision to NFPA 329, Recommended Practice for Handling Releases of Flammable and Combustible Liquids and Gases, 1999 edition. NFPA 329-1999 is published in Volume 13 of the 2003 National Fire Codes and in separate pamphlet form. NFPA 329 has been submitted to letter ballot of the Technical Committee on Tank Leakage and Repair Safeguards, which consists of 14 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report.

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NFPA 326 _______________________________________________________________ 326-1 Log #CP2 Final Action: Accept in Part ( Entire Document (MOS) ) ________________________________________________________________ Submitter: Technical Committee on Tank Leakage and Repair Safeguards Recommendation: Completely revise entire document to comply with the NFPA Manual of Style as follows: 1. Revise Chapter 1 to contain administrative text only as follows: (show revised text here or indicate where revised text can be found) 2. Revise Chapter 2 to contain only referenced publications cited in the mandatory portions of the document. 3. Revise Chapter 3 to contain only definitions. 4. Revise so that all units of measure in document are converted to SI units with inch/pound units in parentheses. 5. Appendices are to be restructured and renamed as "Annexes." 6. All mandatory sections of the document must be evaluated for usability, adoptability, and enforceability language. Generate necessary committee proposals as shown (or indicate where shown). 7. Reword exceptions as requirements. 8. Single sentences per requirement as shown (or indicate where shown). Substantiation: Editorial restructuring, to conform with the 2000 edition of the NFPA Manual of Style. Committee Meeting Action: Accept in Part See the rewrite draft of NFPA 326-2005 at end of this report. Items 1 through 6 done. Items 7 and 8 done where necessary or where sensible to do so. Committee Statement: Items 7 and 8 have been done where the proposed changes do not adversely affect the original intent of the text or where splitting a requirement of more than one sentence into several individually numbered requirements does not adversely affect the ability of the user to understand the intent of the requirements. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-2 Log #17 Final Action: Accept ( Entire Document ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Delete all references to OSHA 29 CFR standards from NFPA 326 and move to the appropriate appendix item. Insert the words "applicable regulations". Substantiation: This is an internationally accepted standard and should REQUIRE compliance with APPLICABLE REGULATIONS and not just US standards. The appropriate OSHA Standard should be listed in the Appendix under each part. Committee Meeting Action: Accept Where a reference appears to "29 CFR Part xxx", replace the reference in the text with "applicable regulations". Place an asterisk after the paragraph number and add the following to Annex A: "An example of an applicable regulation is 29 CFR Part xxx." Committee Statement: The Committee Action specifies the change to be made. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-3 Log #CP1 Final Action: Accept ( Foreword ) ________________________________________________________________ Submitter: Technical Committee on Tank Leakage and Repair Safeguards Recommendation: Move the text of the Foreword to other locations as follows: 1. Move the first paragraph to Chapter 2 as new 2.1.1. Renumber accordingly 2. Delete the first sentence of the second paragraph. 3. Move the second sentence of the second paragraph to Chapter 1 as new 1.2.3. 4. Move the third paragraph to Chapter 2 as new 2.1.4, after renumbered 2.1.4. Substantiation: Editorial relocation of text to comply with NFPA Manual of Style, which does not permit Forewords. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1

Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: The primary reason for my abstention was that, because of unworkable scheduling, I was not able to attend the meeting and felt unacquainted with the issues at stake. I therefore felt that abstention was the best position to take.

NFPA 326

________________________________________________________________ 326-4 Log #1 Final Action: Accept in Principle ( 1.2.1(b) ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Add the following to the end of the sentence "during removal operations." Substantiation: Clarifies the intent of the purpose so as to specifically apply to the removal and not to other non-related operations. Committee Meeting Action: Accept in Principle Revise 1.2.1(b) to read: "The safe removal of flammable, combustible, or other hazardous substance vapors, liquids, or solid residues from tanks or containers, and safeguarding these vessels, for entry, cleaning, or repair." Committee Statement: The Technical Committee agrees with the concept of the proposal, but has broadened its applicability to all operations covered by NFPA 326. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-5 Log #CP6 Final Action: Accept ( 1.4 ) ________________________________________________________________ Submitter: Technical Committee on Tank Leakage and Repair Safeguards Recommendation: Add a new definition of Degassing to read as follows; Degassing. The process of collecting, oxidizing, or treating vapors and gases expelled from a tank or vessel to prevent or reduce the amount of organic volatile compounds released into the atmosphere during vapor- and gas-freeing operations. [API Standard 2015] Substantiation: This term is used in NFPA 326 and needs to be defined. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 8 Negative: 1 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanation of Negative: SIEGEL: The term "degassing," and especially the definition given, may be specific to the petroleum industry. It is not a common term in general industry, and in fact in some applications has a very different meaning. Since I am voting negative on the use of this term in this standard, I am also voting negative on its inclusion in the definitions. Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-6 Log #2 Final Action: Reject ( 1.4 Attendant ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Change definition of attendant. Attendant. A person trained in emergency rescue procedures and who is assigned to remain on the outside of the confined space and to be incommunication with those working inside. Attendant. An individual stationed outside one or more permit spaces who monitors the authorized entrants and who perform all attendants duties assigned in the employers permit space program." Substantiation: The proposed definition is identical to that used by OSHA and by API. The current definition is incorrect as attendants need not be trained rescuers. Also if assigned to be on the outside, how can an attendant enter to rescue (if the NFPA definition is correct as written?). Committee Meeting Action: Reject Committee Statement: The definition of "attendant" accepted under Proposal 326-9 (Log #CP3) is more accurate with respect to the responsibilities of the attendant. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

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Combustible Gas Indicator (secondary) NFPA 326, 1999 ed. An instrument that samples air and indicates whether there are any combustible vapors present. Container (preferred) NFPA 329, 1999 ed. A device that is intended to contain an accumulation of hazardous substances that is too small for human entry or has a capacity that can be effectively and safely cleaned without human entry. Container (secondary) NFPA 326, 1999 ed. A vessel, intended to contain an accumulation of hazardous substances, that is too small for human entry or has a capacity that can be effectively and safely cleaned without human entry. Flammable Vapor (preferred) NFPA 115, 1999 ed. A concentration of constituents in air that exceeds 10 percent of its lower flammable limit (LFL). Flammable Vapor (secondary) NFPA 326, 1999 ed. Any substance that exists in the gaseous state at normal atmospheric temperature and pressure and that is capable of being ignited and burned when mixed with the proper proportions of air, oxygen, or other oxidizer. Inert Gas (preferred) NFPA 69, 2002 ed. A gas that is noncombustible and non-reactive. Inert Gas (secondary) NFPA 326, 1999 ed. Any gas that is nonflammable, non-reactive, and non-contaminating. Lower Flammable Limit (LFL) (preferred) NFPA 329, 1999 ed. ________________________________________________________________ That concentration of a combustible material in air below which ignition will 326-8 Log #4 Final Action: Accept not occur. Also known as the Lower Explosive Limit (LEL) Mixtures below ( 1.4 Confined Space, Non-Confined Space, Permit Required Confined Space ) this limit are said to be "too lean." ________________________________________________________________ Lower Flammable Limit (LFL) (secondary) NFPA 326, 1999 ed. Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. The concentration of a combustible material in air below which ignition will American Petroleum Institute not occur. Recommendation: Add the following definitions: Purging (preferred) NFPA 410, 1999 ed. Confined Space; Any tank or vessel that meets all three of the following The removal of flammable vapor atmospheres or any residue capable of requirements; producing flammable vapors in the tank and connected distribution lines so 1. Is large enough and so configured that as person can enter and perform that subsequent natural ventilation will not result in the reinstatement of a assigned work; flammable atmosphere unless or until a flammable liquid is again introduced 2. Has limited or restricted means for entry or exit, and into the tank or its connected distribution lines. 3. Is not designed or meant to be continuously occupied. Purging (secondary) NFPA 326, 1999 ed. Permit Required Confined Space: A confined space that meets all three of the The process of displacing vapors or gases from an enclosure or confined confined space requirements and also has one or more of the following four space. characteristics: Static Electricity (preferred) NFPA 77, 2000 ed. 1. Contains or has the potential to contain a hazardous substance An electric charge that is significant only for the effects of its electrical field 2. Contains a material with the potential to engulf an entrant component and that manifests no significant magnetic field component. 3. Has an internal configuration such that an entrant could become trapped Static Electricity (secondary) NFPA 326, 1999 ed. or asphyxiated by inwardly converging walls or floor that slope downwards, The electrification of materials through physical contact and separation and tapering to small cross sections the various effects that result from the positive and negative charges so formed, 4. Contains any other recognized serious safety or health hazard. particularly where they constitute a fire or explosion hazard. Non-Confined Space: A space that previously was a confined space but no Tank (preferred) NFPA 122, 2000 ed. longer meets any of the requirements for a confined space or a permit required A closed vessel having a liquid capacity in excess of 60 U.S. gal (227 L). confined space, (such as a tank with a large door sheet cut into the side). Tank (secondary) NFPA 326, 1999 ed. Substantiation: These definitions are the same as OSHA and API and are A stationary or portable vessel large enough to allow human entry that is needed to understand how the requirements of NFPA 326 apply to each. intended to contain an accumulation of hazardous substances. Committee Meeting Action: Accept Vapor (preferred) NFPA 921, 2001 ed. Delete the words "or vessel" in the first line. The gas phase of a substance, particularly of those that are normally liquids or Committee Statement: The deleted words are not necessary. solids at ordinary temperatures. Number Eligible to Vote: 14 Vapor (secondary) NFPA 326, 1999 ed. Ballot Results: Affirmative: 9 Abstain: 1 The evaporated phase of a substance that is normally a liquid at room Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH temperature and pressure. Explanatin of Abstention: Substantiation: Adoption of preferred definitions will assist the user by WILLWERTH: See my Explanation of Abstention for Committee Proposal providing consistent meaning of defined terms throughout the National Fire 326-3 (Log #CP1). Codes. The following procedure must be followed when acting on defined terms ________________________________________________________________ (extract from the Glossary of Terms Definitions Procedure): 326-9 Log #CP3 Final Action: Accept in Part 2.1 Revising Definitions ( 1.4 Definitions (GOT) ) 2.1.1 Prior to revising Preferred definitions, the Glossary of Terms should be ________________________________________________________________ consulted to avoid the creation of additional Secondary definitions. Submitter: Technical Committee on Tank Leakage and Repair Safeguards 2.1.2 All Secondary definitions should be reviewed and eliminated where Recommendation: Adopt the preferred definitions from the NFPA Glossary of possible by the following method (in order of preference): Terms for the following terms: (a) adopt the preferred definition if suitable. Attendant (preferred) NFPA 1670, 1999 ed. (b) modify the secondary term and/or definition to limit its use to a specific A term used to describe U.S. federally regulated industrial workers who are application within the scope of the document. qualified to be stationed outside one or more confined spaces, who monitor (c) request that the Standards Council determine responsibility for the term. authorized entrants, and who perform all of the following duties: (d) request that the Standards Council authorize a secondary definition. (a) Remain outside the confined space during entry operations until (extract from the NFPA Manual of Style): relieved by another attendant 2.3.2.6 Existing general definitions contained in the NFPA Glossary of Terms (b) Summon rescue and other needed resources as soon as the attendant shall be used where technically accurate and correct. determines that authorized entrants might need assistance to escape from Committee Meeting Action: Accept in Part confined space hazards Accept the "preferred" definitions for the following terms: Attendant, (c) Perform nonentry rescues as specified by the rescue procedure listed Combustible Gas Indicator, and Vapor. Accept the "secondary" definitions for on the permit. the following terms: Container, Flammable Vapor, Purging, and Tank. Precede Attendant (secondary) NFPA 326, 1999 ed. each secondary definition with the words "For the purpose of this standard, " A person trained in emergency rescue procedures and who is assigned to Replace the current definition of Inert Gas with the following: Inert Gas. For remain on the outside of the confined space and to be in communication with the purpose of this standard, a gas that is nonflammable, chemically inactive, those working inside. noncontaminating for the use intended, and oxygen-deficient to the extent Combustible Gas Indicator (preferred) NFPA 921, 2001 ed. required." An instrument that samples air and indicates whether there are combustible Replace the current definition of Lower Flammable Limit with the following: vapors present. Lower Flammable Limit.* For the purpose of this standard, the concentration ________________________________________________________________ 326-7 Log #3 Final Action: Accept in Principle ( 1.4 Bonding ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Add the following text: Bonding. The permanent or temporary joining of metal parts..." Substantiation: Bonding is not necessarily permanent. Bonding of educators/ fas/hoses/pumps etc., to the tank for cleaning purposes is usually temporary (for the duration of the operation). Committee Meeting Action: Accept in Principle Replace the current definition of Bonding to read: Bonding. The joining of metal parts to form an electrically conductive path that will ensure electrical continuity and the capacity to conduct safely any current likely to be imposed. Committee Statement: The words "permanent or temporary" are superfluous. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

NFPA 326

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of a flammable gas or flammable vapor, expressed as a volume percent in air, below which propagation of a flame does not occur upon contact with an ignition source, when tested in accordance with ASTM E681-2001, Standard Test Method for Concentration Limits of Flammability of Chemicals (Vapors and Gases). Add the following Annex item: Also known as the "lower explosive limit". Mixtures below this limit are said to be "too lean". Replace the current definition of Static Electricity with the following: Static Electricity. For the purpose of this standard, the electrification of materials through physical contact and separation and the various effects that result from the positive and negative charges so formed.

causing ignition under appropriate circumstances. Substantiation: Clarifies the definition for static electricity. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

NFPA 326

________________________________________________________________ 326-13 Log #7 Final Action: Accept Committee Statement: The secondary and Technical Committee-developed ( 1.4 Ventilation ) definitions are more accurate within the context of NFPA 326 and are necessary ________________________________________________________________ for proper understanding of the text. Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. Number Eligible to Vote: 14 American Petroleum Institute Ballot Results: Affirmative: 9 Abstain: 1 Recommendation: Add the following new text: Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Ventilation: The introduction of fresh air into a tank or vessel to maintain an Explanatin of Abstention: atmosphere within acceptable permit limits and provide the required number of WILLWERTH: See my Explanation of Abstention for Committee Proposal air changes per hour. 326-3 (Log #CP1). Substantiation: Further defines the process of ventilation to distinguish it from purging and to conform with OSHA use of forced air ventilation and with ________________________________________________________________ API 2015/2016 definition and terminology. 326-10 Log #5 Final Action: Accept in Principle Committee Meeting Action: Accept ( 1.4 Lower Flammable Limit ) Number Eligible to Vote: 14 ________________________________________________________________ Ballot Results: Affirmative: 9 Abstain: 1 Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH American Petroleum Institute Explanatin of Abstention: Recommendation: Revise text to read as follows: WILLWERTH: See my Explanation of Abstention for Committee Proposal Lower Flammable Limit (LFL). The concentration of a flammable vapor or 326-3 (Log #CP1). combustible material in air below which ignition will not occur. Substantiation: Flammable vapor LFL is a serious potential fire hazard in ________________________________________________________________ tank cleaning (in addition to combustible material which is normally a dust). 326-14 Log #9 Final Action: Accept Committee Meeting Action: Accept in Principle ( 2.1.3 ) Committee Statement: See the Technical Committee-developed definition of ________________________________________________________________ this term in Proposal 326-9 (Log #CP3). Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. Number Eligible to Vote: 14 American Petroleum Institute Ballot Results: Affirmative: 9 Abstain: 1 Recommendation: Revise text to read as follows: Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH 2.1.3 All appropriate permits required by the authority having jurisdiction Explanatin of Abstention: shall be obtained if required by the authority having jurisdiction. prior to WILLWERTH: See my Explanation of Abstention for Committee Proposal beginning work. 326-3 (Log #CP1). Substantiation: Changed for clarification by deleting word "if". A permit may be appropriate (such as an entry permits) but may not be required by the AHJ. ________________________________________________________________ Also, permits should be obtained before work starts. 326-11 Log #6 Final Action: Accept in Principle Committee Meeting Action: Accept ( 1.4 Purging ) Number Eligible to Vote: 14 ________________________________________________________________ Ballot Results: Affirmative: 9 Abstain: 1 Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH American Petroleum Institute Explanatin of Abstention: Recommendation: Change the definition as follows: WILLWERTH: See my Explanation of Abstention for Committee Proposal Purging: The process of displacing vapors or gases from an enclosure or 326-3 (Log #CP1). confined space. The introduction of an inert gas or flue gas into a tank in order to reduce the oxygen content or to reduce the concentration of hydrocarbon ________________________________________________________________ vapors by displacement. 326-15 Log #10 Final Action: Accept in Principle Substantiation: The definition is too broad as written and does not ( 2.1.5 ) differentiate between displacement (by water or other liquid), ventilation ________________________________________________________________ (dilution with fresh air) or purging (inert gas). As changed, the definition is the Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. same as in API 2015/2016 and in ISGOTT. And conforms to accepted industry American Petroleum Institute standard definition of purging. Purging is not used in OSHA 1910.146, which Recommendation: Revise text to read as follows: refers to forced air ventilation. 2.1.5 Prior to opening or accessing tanks or containers, any internal pressure Committee Meeting Action: Accept in Principle shall be reduced to atmospheric pressure. Tank or container vapors shall be See Proposal 326-9 (Log #CP3). vented to a safe location or where required, appropriately degassed. Committee Statement: See the definition of this term adopted in Proposal Substantiation: Many jurisdictions do not permit venting of vapors to 326-9 (Log #CP3). atmosphere. Number Eligible to Vote: 14 Committee Meeting Action: Accept in Principle Ballot Results: Affirmative: 8 Negative: 1 Abstain: 1 Revise the second sentence of 2.1.5 to read: Tank or container vapors shall Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH be vented to a safe location or, where required, degassed. Explanation of Negative: Committee Statement: The Technical Committee agrees with the proposal, SIEGEL: I support the definition adopted in 326-9(Log #CP3). I specifically but has removed the word "appropriately" because it is ambiguous. object to the language in the proposed 326-11(Log #6), which allows purging Number Eligible to Vote: 14 using flue gas. Flue gas is not necessarily inert, and may introduce new Ballot Results: Affirmative: 8 Negative: 1 Abstain: 1 hazards not otherwise present. Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: Explanation of Negative: WILLWERTH: See my Explanation of Abstention for Committee Proposal SIEGEL: I object to the term "degassed." See my Explanation of Negative 326-3 (Log #CP1). vote for Proposal 326-5(Log #CP6). Explanatin of Abstention: ________________________________________________________________ WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-12 Log #8 Final Action: Accept 326-3 (Log #CP1). ( 1.4 Static Electric Discharge ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Add the following definition. Static Electric Discharge: The release of static electricity in the form of a spark, corona, brush or propagating brush discharge that might be capable of

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________________________________________________________________ 326-16 Log #11 Final Action: Accept in Principle ( 2.2.1 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 2.2.1 Prior to conducting any procedures required by this standard, the area around the tank or container shall be safeguarded from all sources of ignition. The area to be safeguarded and the methods of control shall be determined by the qualified person based on the potential for ignition around the tank or container. The area shall then be inspected for flammable liquids and tested for the presence of flammable vapors. Barricades and warning signs reading "Flammable - No Smoking", shall be provided and placed in accordance with the requirements of the authority having jurisdiction. The area shall then be tested for the presence of flammable liquids or vapors. Where the potential exists for flammable vapors, a hot work permit shall be issued to conduct any operations that constitute a source of ignition. Substantiation: The changes both clarify and strengthen the safe work requirements by requiring a hot work permit. Committee Meeting Action: Accept in Principle Accept all changes to 2.2.1 except the added last sentence; insert this sentence as a second sentence to Section 2.2. Committee Statement: The relocated text is more appropriate as a basic introductory requirement. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-17 Log #12 Final Action: Accept ( 2.2.3 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 2.2.3 Before operations are started, the qualified person shall determine safe procedures for working on tanks or containers that have the potential for pyrophoric action or that have contained nitrocellulose, pyroxylin solutions, nitrates, chlorates, perchlorates, peroxides and other materials that contain enough oxygen to support combustion in an otherwise inerted atmosphere. Add the following new text: A.2.2.3 The qualified person shall be aware of and determine appropriate controls for the hazards associated with materials that contain enough oxygen to support combustion in inert atmospheres. Substantiation: The change is made to include pyrophorics, a serious ignition hazard in many tanks and vessels. The words relating to inert atmosphere are removed as any of the materials listed can emit oxygen in ANY kind of atmospheres (low oxygen, high vapor, etc.) not just in an inerted atmosphere. Anyway, since this standard does not cover inerted tanks or vessels why was this reference to inerted included? I have recommended that it be moved to the appendix. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 8 Negative: 1 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanation of Negative: SIEGEL: The term "...in otherwise inerted atmosphere." should remain, as this alerts users of the standard to a hazard they may not recognize. further, the argument in the justification is not valid. The standard does not address "entry of a tank that contains an inert atmosphere." It does address working on tanks and containers that have been inerted, and therefore the warning is valid and appropriate. Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-18 Log #13 Final Action: Accept ( 2.2.4 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 2.1.4 The qualified person shall determine any firefighting equipment to be provided in the area based upon the actual and potential hazards, require that the equipment be in place before issuing a hot work permit and assure that assigned persons are qualified in the use of the fire fighting equipment. Substantiation: It is not enough to "determine" the equipment. There is a need for hazard recognition, permit requirements and personnel qualification. Committee Meeting Action: Accept Number Eligible to Vote: 14

Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

NFPA 326

________________________________________________________________ 326-19 Log #14 Final Action: Accept ( 2.2.6 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 2.2.6 Any electrical equipment permitted to be used shall be suitable for Class I, Group D, Division 1 or suitable for Zone 0 or Zone 1 hazardous classified locations as defined in NFPA 70, National Electrical Code and shall be approved and inspected by a qualified person to assure that it is in good condition so as to be intrinsically safe. Substantiation: Adds Zone 0 and Zone 1 to comply with tables in NFPA 30. Adds "permitted to be" to indicate that use of electrical equipment in a hazardous area requires a permit. (Note: many companies PROHIBIT use of electrical equipment in tank cleaning operations. This will assure compliance by contractors. Add requirements for equipment inspection and approval by a qualified person. These requirements are included in API 2015/2016. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-20 Log #15 Final Action: Accept ( 2.2.7 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Delete 2.2.7. Substantiation: This is the same requirement as in 2.2.2 which covers all tank activities. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-21 Log #16 Final Action: Accept ( 3.1.3 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Add the following text. 3.1.3 Any removal of locks, tabs or other protective measures shall be done in accordance with OSHA 29 CFR 1910.147, "The Control of Hazardous Energy (Lockout/Tagout) and the above procedure (3.1.2). Substantiation: Section 3.1.2 requires a procedure to remove locks. This procedure may be stricter in its requirements than the OSHA standard. So it should be included. Also, there is some question as to referencing OSHA in a supposedly international standard. Committee Meeting Action: Accept But editorially revise to read: Any removal of locks, tabs or other protective measures shall be done in accordance with OSHA 29 CFR 1910.147, "The Control of Hazardous Energy (Lockout/Tagout) and the procedure set forth in 3.1.2. Committee Statement: The Technical Committee has editorially revised the proposal for reason of style and clarity. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

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________________________________________________________________ 326-22 Log #18 Final Action: Accept ( 3.2.1 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Change the last sentence in the section as follows: 3.2.1 Where reactivity and solubility are not a concern, water or fuel oil or approved chemicals shall be permitted to be pumped into..." Substantiation: There is a need to include materials (besides water) that are commonly used in industry. Fuel oil and chemicals are approved for use by API 2015/2016. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

________________________________________________________________ 326-25 Log #21 Final Action: Accept in Principle ( 4.1.1 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 4.1.1 To determine that an atmosphere within or around a confined space is safe for the designated work, tests for oxygen, flammable, combustible or other hazardous substance vapors, fumes or dusts shall be made with an appropriate instrument, as follows: (1) Before entry or re-entry into a confined space (2) Before beginning alterations or repairs within a confined space or on a tank or vessel that is classified as a confined space. (3) Before, and as determined by a qualified person, during welding, cutting or heating within or around a confined space. CAUTION: Tanks or containers that have held contain residue from flammable, combustible or toxic liquids with high flash points can become hazardous during hot work, cutting and welding operations. (4) Frequently Continuously or periodically during the course of the work as ________________________________________________________________ determined by a qualified person. 326-23 Log #19 Final Action: Accept (5) After cleaning the interior of each tank or container to determine that the ( 3.2.2 ) cleaning procedures have been effective. ________________________________________________________________ (6) After any industrial process or activity has been introduced occurred in the Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. tank or container that could change the atmosphere within the tank or container. American Petroleum Institute Substantiation: 4.1.1 Confined space has been added for clarity. Dusts and Recommendation: Revise text to read as follows: fumes are also common confined space hazards. (1), (2) and (3) all specify 3.2.2 Where flammable or combustible liquids or vapors are contained or confined space so as to not apply to work in non-confined spaces. Since hot have been contained in a tank or container, approved explosion proof electric, work in confined spaces normally does not occur until the tank is empty and or steam driven or air driven pumps shall be used. Pump motors, suction hoses, cleaned, it is the residue or deposits (is rust) that are hazards. nozzles, and lines, as well as receiving tanks, containers, trucks or vessels, shall (4) The supervisor (qualified person) issuing the permit must determine the be bonded to the tank or container being emptied to prevent static electricity testing requirements. It may be continuous ignition hazards. (6) What is an industrial??? Process. It is NOT defined in 326. Any process Substantiation: There is a need to add "approved" and "electric" to better (chemical, mechanical, etc.) could change the atmosphere. And, it does define this equipment (see Section 3.1). In addition to hoses and pumps, all not matter if it is inside or outside of the tank. For example, a nearby tank lines and receiving containers must also be bonded to the tank (and each other). receiving gasoline delivery could produce hazardous vapors into the work area. This bonding is a requirement of API 2015/2016. Committee Meeting Action: Accept in Principle Committee Meeting Action: Accept Revise 4.1.1 to read: Number Eligible to Vote: 14 4.1.1* To determine that an atmosphere is safe for the designated entry, Ballot Results: Affirmative: 9 Abstain: 1 cleaning, or repair work, tests for oxygen and for flammable, combustible Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH or other hazardous substance vapors, fumes or dusts shall be made with an Explanatin of Abstention: appropriate instrument, as follows: WILLWERTH: See my Explanation of Abstention for Committee Proposal (1) Before entry or re-entry. 326-3 (Log #CP1). (2) Before beginning alterations or repairs. (3) Before and during any hot work, cutting, welding, or heating operation. ________________________________________________________________ (4) Continuously or periodically during the course of the work as determined 326-24 Log #20 Final Action: Accept in Principle by a qualified person. ( 3.3.1 ) (5) After cleaning the interior of each tank or container to determine that the ________________________________________________________________ cleaning procedures have been effective. Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. (6) After any industrial process or activity has been introduced occurred in American Petroleum Institute the tank or container that could change the atmosphere within the tank , or Recommendation: Delete the word plugged in the last sentence of 3.3.1 and container, or area. add an additional sentence as follows: Committee Statement: The Technical Committee has editorially amended the 3.3.1 All piping that is connected to the tank that is capable of producing a proposal for clarity. hazard shall be isolated by being disconnected, plugged, double-blocked and Number Eligible to Vote: 14 bled or blanked off. Pipe plugging shall be permitted only after an analysis is Ballot Results: Affirmative: 9 Abstain: 1 made by a qualified person to assure that the plug is suitable and appropriate to Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH withstand any potential pressure in the piping that could dislodge the plug. Explanatin of Abstention: Substantiation: This change is required as numerous incidents and fatalities WILLWERTH: See my Explanation of Abstention for Committee Proposal have occurred when pipe plugs failed. 326-3 (Log #CP1). Committee Meeting Action: Accept in Principle Add the proposed new sentence as the last sentence to 3.3.1 so that 3.3.1 ________________________________________________________________ reads: Prior to opening, the tank or container shall be isolated from all supply 326-26 Log #22 Final Action: Accept and dispensing piping systems. If the tank or container on which work is to be ( 4.1.3 ) performed is equipped with a manifold vent, vapor recovery system, fill line, ________________________________________________________________ siphon assembly, or other methods of connection to other tanks or containers, Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. the qualified person shall determine the necessary measures required to isolate American Petroleum Institute that tank or container from all other tanks or containers. All piping connected Recommendation: Revise text to read as follows: to the tank that is capable of producing a hazard shall be isolated by being 4.1.3 Qualified persons responsible for testing shall be trained or educated disconnected, plugged, double-blocked and bled, or blanked off. Pipe plugging in the use of the instruments and be aware of their its limitations, have an shall be permitted only after an analysis is made by a qualified person to assure understanding of the significance of its readings and be aware of its limitations. that the plug is suitable and appropriate to withstand any potential pressure in Substantiation: Changed for clarity. Limitations applies to the instruments the piping that could dislodge the plug. and NOT to the readings. This is as opined by both OSHA and API 2015/2016. Committee Statement: The existing text is accurate as stated. Deleting the This word qualified has been added to designate the testers requirement. word "plugged" would render the new text irrelevant, since plugging would not Committee Meeting Action: Accept be allowed. Editorially revise to read as follows: Number Eligible to Vote: 14 The qualified person responsible for testing shall be trained or educated Ballot Results: Affirmative: 9 Abstain: 1 in the use of the instruments and be aware of their its limitations, have an Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH understanding of the significance of its readings and be aware of its limitations. Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

NFPA 326

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Committee Statement: The Technical Committee agrees with the proposal but has made a minor editorial change but changing the subject of the sentence from plural to singular. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-27 Log #23 Final Action: Accept ( 4.1.4 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 4.1.4 All tests for oxygen and flammable or toxic vapors and gases shall be conducted using a properly calibrated and adjusted instrument. The adjustment of the instrument shall be checked before each days (or shifts) use or more often if the tester or qualified person determines there is a need to do so. Substantiation: There is a need to add toxic exposures. Instruments should be checked more often than daily if used on shifts. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-28 Log #24 Final Action: Accept in Principle ( 4.3 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 4.3 When testing for flammable vapors a properly calibrated and adjusted combustible gas indicator shall be used. Substantiation: See NFPA 326, 4.1.4 requires adjustment. Committee Meeting Action: Accept in Principle Revise 4.3 to read: To determine flammable vapor content, a properly calibrated and adjusted combustible gas indicator shall be used. Committee Statement: The proposed text has been editorially revised for clarity. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-29 Log #25 Final Action: Accept in Principle ( 4.3.1 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 4.3.1 All work within the confined space shall be stopped immediately when the flammable vapors in the atmosphere exceed 10 percent of the LFL. The source of the vapors release shall be located and eliminated or controlled. Substantiation: The 10 percent LEL is required for work inside confined spaces per OSHA and API 2015/2016. The flammable vapors may be inside the confined space (due to seepage, rust, etc.) or outside (due to a nearby spill or release). The source need not be a "release". The first method is to eliminate the hazard. It is controlled only if it cannot be eliminated. Committee Meeting Action: Accept in Principle Revise 4.3.1 to read: All work in or around the tank or container shall be stopped immediately when the flammable vapors in the atmosphere exceed 10 percent of the LFL. The source of the vapors release shall be located and eliminated or controlled. Committee Statement: The replacement of the words "within the confined space" is for clarity and emphasizes that the area around the confined space needs to be monitored as well. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

________________________________________________________________ 326-30 Log #26 Final Action: Accept in Principle ( 4.3.2 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 4.3.2 Any equipment that could provide a source of ignition shall not be permitted within the safeguarded area of a tank or container being cleaned until the area has been tested (see 2.2.1) and found to be vapor free or there has been a "hot work allowed" designation (see 6.2.4) and an appropriate hot work permit has been issued by a qualified person. Substantiation: A permit needs to be issued to assure the safe operation of ignition sources in tank areas. Committee Meeting Action: Accept in Principle Revise 4.3.2 to read: Any equipment that could provide a source of ignition shall not be permitted within the safeguarded area of a tank or container being cleaned, entered, or repaired until the area has been tested (see 2.2.1) and found to be vapor free in accordance with 6.2.4 or there has been a "hot work allowed" designation (see 6.2.4) and an appropriate hot work permit has been issued by a qualified person. Committee Statement: The Technical Committee has revised the proposed to broaden its applicability to entry or repair operations. The requirement applies equally to entry ad repair operations. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-31 Log #27 Final Action: Accept ( 4.3.3 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 4.3.3 During ventilation or air purging of any tank or container, the flammable vapor concentration of the effluent shall be tested as often as needed as determined as required by the qualified person to ensure determine the flammability and toxicity of the vented vapors. The qualified person shall determine the direction of the vented effluent to assure that it does not reach a source of ignition. will not be ignited. Substantiation: Ventilation is the same as "air" purging. When purging with inert gas, steam, fuel oil or water, flammable vapors will also be emitted. The actual need when venting is to control where the vapors are vented and travel to, regardless of their LEL/UEL, at any time during venting. Just testing the vapors (even continuously) does nothing to prevent their ignition if they reach a source of ignition. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 8 Negative: 1 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanation of Negative: SIEGEL: The recommendation correctly points out that toxicity of vented vapors may be an issue, but then improperly addresses it. I suggest the last sentence be changed to "The qualified person shall determine the direction of the vented effluent, and shall assure that flammable vapors do not reach a source of ignition, and that toxic or otherwise hazardous vapors do not result in unacceptable human health or environmental exposures." Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-32 Log #28 Final Action: Accept ( 4.3.4 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 4.3.4 If an eductor performs the purging ventilation, the eductor shall create a vacuum that draws air through at least one tank or container opening and discharges through the opening to which it is attached. Testing for flammable vapors shall be conducted using a combustible gas indicator with its probe inserted into the probe hole provided in the side of the eductor. Testing for flammable vapor concentrations shall be performed with the eductor on and tightly secured and bonded to the tank or container fill hole. When a reading of 10 percent or less of the Lower Flammable Limit is obtained, the eductor shall be shut off and readings taken again after a few minutes waiting time. If the readings in the tank or container are taken through the fill opening, any fill tube that extends into the tank or container shall be removed prior to purging or ventilation operations. The eductor shall be immediately turned on after the last test in the tank or container and the tank or containers effluent vent

NFPA 326

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opening shall be tested thereafter as long as ventilation continues and as often as determined necessary by the qualified person. Substantiation: See previous comments regarding purging. Purging is use of inert gas, steam, etc. Ventilation is use of air. The eductor must be bonded to prevent static discharge. The eductor is not usually connected to a fill hole. It is most often connected to a manway. Additional information similar to 4.3.5 has been added. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-33 Log #30 Final Action: Accept ( 4.3.5 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 4.3.5 If an air blower performs the purging ventilation, the blower shall force air into the tank or container through at least one tank or container opening and discharge through another opening. Testing for flammable vapors shall be performed with a combustible gas indicator whose probe is placed in the tank or containers discharge opening. When a reading of 10 percent or less of the Lower Flammable Limit is obtained, the air blower shall be shut off and readings taken again after a few minutes waiting time. If the readings in the tank or container are taken through the fill opening, any fill tube that extends into the tank or container shall be removed prior to purging or ventilation operations. The air blower shall be immediately turned on after the last test in the tank or container and the tank or containers vent opening shall be tested thereafter as long as ventilation continues and as often as determined necessary by the qualified person. Substantiation: See previous comments regarding purging. Purging is use of inert gas, steam, etc. Ventilation is use of air. The eductor must be bonded to the shell to prevent static discharge. The eductor is not usually connected to a fill hole. It is more often connected to a manway. Committee Meeting Action: Accept Replace "vent opening" with "effluent" in the last sentence. Committee Statement: The replacement in the last sentence is to correlate 4.3.5 with 4.3.4. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

________________________________________________________________ 326-35 Log #32 Final Action: Accept in Principle ( 5.1.1 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 5.11 Flammable vapors in a tank or container shall be permitted to be purged vented with air, or purged with inert gas, water or steam (See Section 8.5). The qualified person shall select the appropriate method chosen shall be appropriate of ventilating or purging the tank or container on which the work will be performed in accordance with regulatory requirements, facility and contractor programs and procedures and industry standards, including ANSI/API 2015 and ANSI/API 2016. Substantiation: The change differentiates between purging and fresh air ventilation and specifies where the safe requirements may be found and where the "appropriate methods" come from, such as mandatory confined space entry, permit, lockout and other applicable written programs. Committee Meeting Action: Accept in Principle Revise 5.1.1 to read as follows: 5.1.1* Flammable vapors in a tank or container shall be permitted to be purged vented with air, or purged with inert gas, water or steam (See Section 8.5). The qualified person shall select the appropriate method chosen shall be appropriate of ventilating or purging the tank or container on which the work will be performed in accordance with regulatory requirements, facility and contractor programs and procedures and industry standards. Add an annex item to read: A.5.1.1 See ANSI/API 2015 and ANSI/API 2016. Committee Statement: In this case, the references more appropriately belong in the annex. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

NFPA 326

________________________________________________________________ 326-36 Log #33 Final Action: Accept ( 5.1.3 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 5.1.3 Other hazardous substances and vapors that are not flammable or combustible but have adverse environmental or human health effects shall be eliminated or controlled prior to proceeding. Many of the methods identified in Section 5.1 shall apply to the removal or control of these other hazardous substances whether they be liquids, solids, vapors, dusts, fumes, mists and gases. The specific hazardous substances and the appropriate methods of their ________________________________________________________________ removal or control of these vapors shall be identified by the qualified person 326-34 Log #29 Final Action: Accept prior to proceeding with ventilation or purging. ( 4.3.6 ) Substantiation: Includes hazards other than vapors (i.e., H2S gas, lead in air, ________________________________________________________________ chemical fumes, catalyst dust, liquid chemicals, etc.). Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. Committee Meeting Action: Accept American Petroleum Institute Delete "many of" in the second sentence. Recommendation: Revise text to read as follows: Committee Statement: The deleted words are superfluous. 4.3.6 When testing a tank or container prior to or during starting hot work, Number Eligible to Vote: 14 any indication of flammable gas or vapor in excess of the established allowable Ballot Results: Affirmative: 9 Abstain: 1 limits shall require additional ventilation, purging, re-cleaning or any additional Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH further safeguarding by one of the methods described in this standard, as Explanatin of Abstention: specified by the qualified person, prior to issuing a hot work permit. When WILLWERTH: See my Explanation of Abstention for Committee Proposal testing a tank or container during hot work, any indication of flammable gas or 326-3 (Log #CP1). vapor in excess of the established allowable limits shall require the immediate cancellation of the hot work permit. Additional ventilation, re-cleaning or ________________________________________________________________ any additional further safeguarding by one of the methods described in this 326-37 Log #34 Final Action: Accept standard, as specified by the qualified person, shall be conducted prior to ( 5.1.4 ) retesting and reissuing the hot work permit. ________________________________________________________________ Substantiation: This clarifies the requirements for prior to beginning hot Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. work and changes occurring during hot work. The requirements are in accord American Petroleum Institute with those of API 2015/2016. Recommendation: Revise text to read as follows: Committee Meeting Action: Accept 5.1.4 Prior to removing vapors from a tank or container, the appropriate Number Eligible to Vote: 14 regulations and the applicable codes and standards shall be reviewed by the Ballot Results: Affirmative: 9 Abstain: 1 qualified person to who shall identify any specific requirements for handling, Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH degassing or discharging vapors or liquids while conducting the activities Explanatin of Abstention: described in this standard and indicate appropriate requirements or controls on WILLWERTH: See my Explanation of Abstention for Committee Proposal the permit. Chapter. 326-3 (Log #CP1). Substantiation: Includes degassing (which is required in many jurisdictions) and specifies who shall identify and satisfy regulatory requirements. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 8 Negative: 1 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH

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Explanation of Negative: SIEGEL: I object to the term "degassing." See my Explanation of Negative for Proposal 326-5(Log #CP6). I also disagree with the comment in the substantiation that degassing, specifically, is required in many jurisdictions. Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-38 Log #31 Final Action: Accept in Principle ( 5.1.5 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Insitute Recommendation: Revise text to read as follows: 5.1.5 Where a tank is located indoors or in an enclosed or confined area, such as under a building, under a stairwell or in an open-sided shed, the qualified person shall stipulate on the permit the appropriate any measures to be taken to prevent the accumulation of flammable or toxic vapors and gases within the building or enclosed or confined area. Substantiation: Adds enclosed area to designate areas other than confined spaces. Requires control measures to be listed on the permit (such as LEL limits, permit cancellation, etc.) Committee Meeting Action: Accept in Principle Revise 5.1.5 to read: Where a tank is located indoors or in an enclosed or confined area, including but not limited to such as under a building, under a stairwell or in an opensided shed, the qualified person shall issue a permit which stipulates the appropriate any measures to be taken to prevent the accumulation of flammable or toxic vapors and gases within the building or enclosed or confined area. Committee Statement: Using "included but not limited" emphasises that the requirement is not limited to the just the examples cited. Other changes are for editorial clarity. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-39 Log #35 Final Action: Accept ( 5.2.1.1 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 5.2.1 Displacement with Air (Ventilation). 5.2.1.1 Where openings of sufficient size are available, approved air movers (eductors and blowers) that do not provide an ignition source shall be attached so that air is drawn through or pumped into one opening and the atmosphere within the tank or container is discharged through another opening, a sufficient distance away from the first opening to provide for allow cross ventilation in the tank. If openings cannot accommodate an air mover, the tank or container shall be thoroughly ventilated to remove flammable vapors by introducing fresh air that will circulate through the tank or container and be safely discharged to the outside or degassed. Precautions..." (Note: the remainder of the paragraph is not changed). Substantiation: The word "ventilation" is added to the section title to clarify that displacement with air IS ventilation. The changes to 5.2.1.1 require "approved" (steam, air or explosion proof electric driven) air moves, specify that air movers are either blowers or eductors, (note - air movers are not defined in this standard) removes the reference to purging and replaces it with "ventilation" and adds degassing which is a regulatory requirement in many areas. Approved air movers are required by API 2015/2016. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 8 Negative: 1 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanation of Negative: SIEGEL: See my Explanation of Negative for Proposal 326-37(Log #34). Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-40 Log #36 Final Action: Accept ( 5.2.1.2 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 5.2.1.2 Precautions shall be taken to control static electricity accumulation through proper bonding and grounding in order to prevent eliminate the

possibility of static electric discharge during gas freeing ventilation operations. Substantiation: The first change is made to correctly specify the actions needed to control static electricity during ventilation (this section is on ventilation), "ventilation" includes both gas freeing and vapor freeing and is therefore the correct term to be used. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

NFPA 326

________________________________________________________________ 326-41 Log #37 Final Action: Accept ( 5.2.1.3 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: 5.2.1.3 Replace the word "purging" with "ventilating" in this section. Substantiation: Purging is the use of water, steam, inert gas, etc. Ventilation is the use of air. This section (5.2.1) covers displacement with sir and not purging. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-42 Log #38 Final Action: Accept ( 5.2.1.4 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Change the last sentence as follows: 5.2.1.4 (a) A negative pressure...ventilatoin and removal. All equipment shall be properly bonded to prevent the generation of static electric discharge. 5.2.1.4 (b) A positive pressure... free of flammable or toxic vapors. The air diffusing pipe, if used, shall be properly bonded to the tank or container to prevent the generation of static electric discharge. Substantiation: The sentences are changed correctly portray the effect of bonding. Nothing prevents the generation of static electricity and bonding does not prevent static electric accumulation. Bonding provides an electrical conducting path between two objects so they have the same electrical potential and when they are separated, a spark will not jump from one to another. Grounding prevents accumulation of electrical charges. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 8 Abstain: 2 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: SIEGEL: I believe the argument in the substantiation misses the point. the original language does not state that bonding prevents static electricity; it says it will prevent a static electric discharge. This is understandable to all, and the substantiation statement seems to agree with it. I find the suggested wording change to be trivial, and I can neither support nor oppose it. I therefore abstain. WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). _______________________________________________________________ 326-43 Log #39 Final Action: Accept in Principle ( 5.2.2 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 5.2.2 Qualified persons shall be thoroughly familiar with the limitations and characteristics of the inert gas being used. Upon completion of inerting, the oxygen content shall be monitored frequently as often as necessary as determined by the qualified person, and maintained at less than 8 percent or less than 50 percent of the oxygen concentration required to support combustion, whichever is less, during the entire period that work is in progress and until the tank or vessel is returned to service or cleaned and taken out of service. Substantiation: It is impossible to maintain levels at 8 percent or below 50 percent during inerting. These are the levels to be maintained AFTER inerting process is completed. Since "frequently" is nebulous, monitoring intervals should be determined by the supervisor. Once work is completed, the tank MUST remain inerted until back into service or out of service.

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Committee Meeting Action: Accept in Principle Revise 5.2.2 to read: When a tank or container is to be inerted for purposes other than entry, the qualified person shall be thoroughly familiar with the limitations and characteristics of the inert gas being used. Upon completion of inerting, the oxygen content shall be monitored frequently as often as necessary as determined by the qualified person, and maintained at either less than 8 percent total oxygen content or less than 50 percent of the minimum oxygen concentration required to support combustion, whichever is less. This condition shall be maintained during the entire period that work is in progress and until the tank or vessel is returned to service or cleaned and taken out of service. Committee Statement: The changes made to the proposed text are editorial to ensure that the user can easily understand the requirement. Number Eligible to Vote: 14 Ballot Results: Affirmative: 8 Abstain: 2 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: SIEGEL: Again, the argument about whether the required concentrations are maintained "during" or "after" inerting is trivial, as the original language is understandable to anyone reading this standard. As with 326-42(Log #39), I find the suggested wording change to be trivial, and I neither support nor oppose it. I therefore abstain. WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-44 Log #40 Final Action: Accept ( 5.2.2.6 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 5.2.2.6 A sign shall be posted conspicuously posted that warns of the hazard of inert gas and forbids entry into the tank by unauthorized persons during the inerting process. Entry into inert confined spaces for inspection, testing and work shall only be allowed as authorized by a entry permit issued by the qualified person who has determined the hazards and provided for appropriate controls and protection. (See ANSI/API 2015/2016 and 2217A for specific requirements and procedures for entering and working in inert confined spaces). Substantiation: There is a need to provide for inspection, testing and work to be done within inert spaces. As written (originally) this would prohibit all such activities. Committee Meeting Action: Accept Move the parenthetical to the annex. Committee Statement: In this situation, the references more appropriately belong in the annex. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

________________________________________________________________ 326-46 Log #41 Final Action: Accept ( 5.2.3 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 5.2.3 Displacement with Water, Fuel Oil or Chemicals and insert the words "fuel oil or approved chemical" following the word "water" in all paragraphs of Section 5.2.3. Substantiation: Because of environmental and other concerns, water is no longer used (as much as in the past) to flush out tanks. In the petroleum industry, for example, fuel oil (which can be burned, recycled or re-refined) is used extensively and in some situations, chemical solvents are required to dissolve products or materials in the tank or container. Neither fuel oil or chemicals are covered in this standard. The requirements of the Section 5.2.3 would apply to these agents. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-47 Log #42 Final Action: Accept ( 5.2.3.2 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 5.3.2 Removal of vapors shall also be permitted to be accomplished by completely filling the tank or container with water, fuel oil or approved chemical. If this method is used, the tank or container shall remain be completely filled with water, fuel oil or approved chemical in order to remove all vapors. Extreme care shall be taken to eliminate any vapor spaces by providing proper venting and/or by properly positioning the tank or container during the filling operation. Substantiation: Fuel oil and chemical are also used for this purpose. The tank cannot "remain" completely filled unless the entrant(s) are qualified deep sea divers. Someone, sometime, may have to get into the tank. "And" is added as the tank may need to be both vented and positioned. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

NFPA 326

________________________________________________________________ 326-48 Log #43 Final Action: Accept ( 6.1 ) ________________________________________________________________ ________________________________________________________________ 326-45 Log #CP4 Final Action: Accept Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. ( 5.2.2.7 ) American Petroleum Institute ________________________________________________________________ Recommendation: Revise text to read as follows: Submitter: Technical Committee on Tank Leakage and Repair Safeguards 6.1 Once the applicable procedures in Chapters 2 through 5 have been Recommendation: Revise 5-2.2.7 to read: "When work is completed and followed satisfied, a qualified person shall test and inspect the tank or container prior to entry into the tank without restrictions, inerting media shall be removed and certify, in writing (usually by issuing a permit) that certain activities, such to achieve an oxygen, vapor, and toxic concentrations in accordance with 6-2.1. as entry, hot work or cold (safe) work can proceed using the designations If inerting media is to remain in the tank, the tank shall be secured and a sign in Section 6.2. The certificates (permits) shall include a description of the shall be posted in accordance with 5-2.2.6. work authorized to be performed and the criteria for protecting personnel and Substantiation: The proposed revision clarifes that this applies to maintaining safe conditions during work. entry without restriction and also adds needed references to toxic vapor In addition to the above, wherever the word "certification" appears in Chapter concentrations. 6, change it to "permit". Committee Meeting Action: Accept Substantiation: The term "permit" is standard usage in industry. I have not Number Eligible to Vote: 14 ever seen the term "certificate" used nor is it defined in NFPA 326. Permit is Ballot Results: Affirmative: 8 Negative: 1 Abstain: 1 defined in NFPA 1, and NFPA 51B. Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Applicable procedures should be "satisfied" prior to entry - not just followed. Explanation of Negative: Permits "authorize"; work to be performed and personnel protection is equally SIEGEL: The proposed wording on achieving acceptable "oxygen, vapor and as important as safe conditions. toxic concentrations" is inconsistent. I suggest the phrase be revised to read Committee Meeting Action: Accept "...inerting media shall be removed and oxygen concentrations and flammable Number Eligible to Vote: 14 and toxic vapor concentrations shall be in accordance with 6-2.1." Ballot Results: Affirmative: 9 Abstain: 1 Explanatin of Abstention: Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH WILLWERTH: See my Explanation of Abstention for Committee Proposal Explanatin of Abstention: 326-3 (Log #CP1). WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

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________________________________________________________________ 326-49 Log #44 Final Action: Accept ( 6.2 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 6.2 The following designations shall be consistent with 29 CFR 1910.146 Permit required Confined Spaces applicable regulatory requirements and industry standards. Add the following Appendix item: A.6.2 For information on entry designations, refer to OSHA 29CFR1910.46 and ANSI/API 20915 and ANSI/API 2016. Substantiation: See previous comment on reference to OSHA. This is an international document. OSHA and API 2015/2016 should be referenced in the appendix. Also, OSHA 29CFR 1910.146 has nothing called "entry without restrictions" (see Section 6.2.1) so it cannot be included as applicable to this section. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

cleaning to establish a safe condition. The nature, location, and extent of the hot work shall be listed on the qualified persons certification. (c) A portion(s) of the tank shall meet the requirements of 6-2.4. The nature or type of hot work shall be limited or restricted. Substantiation: The last sentence is actually the prime requirement and is n ow stated first . Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

NFPA 326

________________________________________________________________ 326-52 Log #46 Final Action: Accept ( 6.2.6(a) ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 6.2.6(a) Tanks or spaces with residues or preservative coatings whose flash points are 82.2C (180° F) or greater and that are free of flowing residues or coatings shall be permitted to be partially cleaned for limited hot work. The qualified person shall verify the flash points and the toxic and hazardous characteristics of the residues or coatings and implement the appropriate ________________________________________________________________ controls prior to issuing the hot work and entry permits certification. The 326-50 Log #45 Final Action: Accept in Principle qualified person shall also take into consideration and fumes or vapors that ( 6.2.4 ) may be emitted from residues and coatings that have subject to heat during hot ________________________________________________________________ work. Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. Substantiation: The changes provide for stricter and proper safety American Petroleum Institute requirements. The term certification in not used in any industry or regulatory Recommendation: Change 6.2.4(b) as follows: standards (including NFPA). The proper term is "permit". (b) The LFL shall be less than 10 0 percent Committee Meeting Action: Accept Add the following appendix item: Editorially revise the last sentence to read: ". . . any fumes or vapors that A.6.2.4(b) Before starting hot work, the LFL within the tank or container shall might be emitted from residues and coatings subject to heat during hot work. be 0 percent LFL. During the course of the hot work if the LFL rises to 10 Committee Statement: The changes to the proposed text are corrections of percent LFL, all work shall stop, personnel shall leave the tank and ventilation typographical errors. shall continue until the LFL is again at 0 percent. The permit shall then be Number Eligible to Vote: 14 reissued to continue the hot work. Ballot Results: Affirmative: 9 Abstain: 1 Substantiation: ANSI/API 2015 requires the LFL to be 0 percent before Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH issuing hot work permits. Explanatin of Abstention: Committee Meeting Action: Accept in Principle WILLWERTH: See my Explanation of Abstention for Committee Proposal Revise 6.2.4(b) to read: Before starting hot work, the LFL within the tank or 326-3 (Log #CP1). container shall be 0 percent LFL. During the course of the hot work if the LFL rises to 10 percent LFL, all work shall stop, personnel shall leave the tank and ventilation shall continue until the LFL is again at 0 percent. The permit shall ________________________________________________________________ then be reissued to continue the hot work. 326-53 Log #47 Final Action: Accept Committee Statement: The proposed annex text actually states the intended ( 6.2.6(c) ) requirement more clearly. ________________________________________________________________ Number Eligible to Vote: 14 Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. Ballot Results: Affirmative: 8 Negative: 1 Abstain: 1 American Petroleum Institute Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Recommendation: Revise text to read as follows: Explanation of Negative: 6.2.6(c) The portion of the tank or container subjected to hot work shall SIEGEL: The suggested statement that "The LFL shall be less than 0 percent" meet the requirements of 6.2.4(c). The entire tank or container shall meet the is impossible. Further, since the commenter differentiates between ventilation requirements of 6.2.4(a), (b) and (d). The nature and type of hot work shall be and purging, the appendix item should state "...ventilation or purging shall limited or restricted and shall be so indicated on the hot work permit. continue..." Substantiation: As originally written this would NOT require the tank to Explanatin of Abstention: be gas or vapor free prior to hot work. Flammable gas or vapors could easily WILLWERTH: See my Explanation of Abstention for Committee Proposal migrate from other areas of the tank to the area where the hot work is taking 326-3 (Log #CP1). place. The change is specific to this problem and addresses it by requiring that the entire tank meet the requirements of 6.4.2 except that the area being worked on is the only area requiring cleaning. ________________________________________________________________ Committee Meeting Action: Accept 326-51 Log #CP5 Final Action: Accept Number Eligible to Vote: 14 ( 6.2.6 ) Ballot Results: Affirmative: 9 Abstain: 1 ________________________________________________________________ Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Submitter: Technical Committee on Tank Leakage and Repair Safeguards Explanatin of Abstention: Recommendation: Revise to read: WILLWERTH: See my Explanation of Abstention for Committee Proposal 6-2.6 Limited Hot Work Allowed. 326-3 (Log #CP1). This designation shall include a statement that describes the exact location of the hot work, the nature and type of the hot work, and the limitations or restrictions of the hot work. This designation means that in a tank, attached ________________________________________________________________ piping, or a space so designated the following shall apply. 326-54 Log #CP7 Final Action: Accept (a) Tanks or spaces with residues or preservative coatings whose flash (7) points are 82.2°C (180°F) or greater and that are free of flowing residues or ________________________________________________________________ coatings shall be permitted to be partially cleaned for limited hot work. The Submitter: Technical Committee on Tank Leakage and Repair Safeguards qualified person shall verify the flash points of the residues prior to issuing the Recommendation: delete any reference to containers in Chapter 7. certification. Substantiation: Containers are not within the scope of Chapter 7. (b) To prevent the spread of fire, an area shall be cleaned a sufficient Committee Meeting Action: Accept distance in all directions, including below the area of the hot work, so that Number Eligible to Vote: 14 sparks or slag will not drop or be thrown into uncleaned areas of the space. The area shall be cleaned to meet the requirements of the standard safety designation "hot work allowed." A fire watch shall not be used in lieu of

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Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-55 Log #48 Final Action: Accept ( 7.1.1 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 7.1.1 Prior to performing issuing a permit for access to or entry into a tank, the qualified person shall assure that flammable vapors have been shall be controlled or removed from the tank in accordance with the procedures and requirements of outlined in Chapters 5 and 6 of this standard. Substantiation: Reinforces good safe work practices by specifying that the qualified person issues the permit for access or entry. Chapter 6 specifies the atmospheric limits for entry. Flammable vapors may be controlled by inerting (removing or reducing oxygen) and do not necessarily have to be "removed" for entry. In fact, this standard allows entry without "completely" removing all of the flammable vapors (10 percent LFL). Finally, there is no "outline" in Chapter 5. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

7.2.1* If excavation is necessary to gain access to the tank the access pit (or trench) shall be of sufficient size to allow entry and exit from the tank and to shall comply with the applicable US Occupational Safety and health (OSHA) regulations. The qualified person and personnel shall be familiar with and comply with all applicable regulations covering excavations and trenching such as those established by OSHA in 29CFR1926, Subpart P, "Excavations". A.7.2.1 See US Occupational Safety and Health Administration (OSHA) 29CFR1926 Subpart P, "Excavations" for trenching and excavation requirements in the U.S. Committee Statement: The scope of Chapter 7 does not include containers, only tanks. Also, the annex item is new text and should be underlined to so designate. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

NFPA 326

________________________________________________________________ 326-58 Log #51 Final Action: Accept in Principle ( 7.2.2 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 7.2.2 If a manway is to be used for access to the tank or container, exists, the bolts and lid cover shall be removed. When work is completed at the end of the shift or day, or any time when the tank or container is left unguarded prior to its being cleaned, vapor and toxic freed and classified as a non-permit required confined space (or a non-confined space), the manway shall be replaced using 1/2 of the number of bolts to protect the tank or container from unauthorized access. ________________________________________________________________ Substantiation: There is no need to remove covers (not lids) from manways 326-56 Log #49 Final Action: Accept that are not being used for access (or for ventilation). There is a need to protect ( 7.1.3 ) a tank from unauthorized access when it is left unguarded. ________________________________________________________________ Committee Meeting Action: Accept in Principle Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. Revise 7.2.2 to read: If a manway is to be used for access to the tank, exists, American Petroleum Institute the bolts and lid cover shall be removed. When work is completed at the end of Recommendation: Revise text to read as follows: the shift or day, or any time when the tank is left unguarded prior to its being 7.1.3 Applicable control measures for any other hazards or potential hazards cleaned, vapor and toxic freed and classified as a non-permit required confined that have been identified for the materials (products) previously stored in the space (or a non-confined space), the manway shall be replaced using 1/2 of the tank or container and for the materials to be used to purge and clean the tank or number of bolts to protect the tank from unauthorized access. container shall be indicated on the permit and appropriately monitored by the Committee Statement: The scope of Chapter 7 does not include containers, qualified person. only tanks. Substantiation: Adds requirements for other than just the materials stored in Number Eligible to Vote: 14 the tank and assign responsibility to the qualified person to recognize, control Ballot Results: Affirmative: 9 Abstain: 1 and monitor these hazards. Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Committee Meeting Action: Accept Explanatin of Abstention: Delete the words "or container". WILLWERTH: See my Explanation of Abstention for Committee Proposal Committee Statement: The scope of Chapter 7 does not include containers, 326-3 (Log #CP1). only tanks. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 ________________________________________________________________ Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH 326-59 Log #52 Final Action: Accept Explanatin of Abstention: ( 7.2.3 ) WILLWERTH: See my Explanation of Abstention for Committee Proposal ________________________________________________________________ 326-3 (Log #CP1). Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Delete the word "OSHA" from Section 7.2.3. ________________________________________________________________ Substantiation: As stated previously, this is an international code. The 326-57 Log #50 Final Action: Accept in Principle specific OSHA requirements may be included on the appendix if the committee ( 7.2.1 ) so desires. Just to reference OSHA is not a good practice, may as well ________________________________________________________________ reference all of the CFR. Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. Committee Meeting Action: Accept American Petroleum Institute Number Eligible to Vote: 14 Recommendation: Revise text to read as follows: Ballot Results: Affirmative: 9 Abstain: 1 7.2 Access to tanks and containers. Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH 7.2.1 If excavation is necessary to gain access to the tank or container the Explanatin of Abstention: access pit (or trench) shall be of sufficient size to allow entry and exit from the WILLWERTH: See my Explanation of Abstention for Committee Proposal tank (or container) and to shall comply with the applicable US Occupational 326-3 (Log #CP1). Safety and health (OSHA) regulations. The qualified person and personnel shall be familiar with and comply with all applicable regulations covering excavations and trenching such as those established by OSHA in 29CFR1926, ________________________________________________________________ Subpart P, "Excavations". 326-60 Log #53 Final Action: Accept in Principle A.7.2.1 See US Occupational Safety and Health Administration (OSHA) ( 7.2.5 ) such as 29CFR1926 Subpart P, "Excavations" for trenching and excavation ________________________________________________________________ requirements in the U.S. Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. Substantiation: The changes add containers (to cover vessels), includes the American Petroleum Institute qualified person and removes references to OSHA to the Appendix (as this is Recommendation: Revise text to read as follows and renumber the Caution an international standard, OSHA should not be in the mandatory text). to item 7.2.5. Committee Meeting Action: Accept in Principle 7.2.4 For Cutting shall not be permitted on tanks and containers containing Revise 7.2 and 7.2.1 to read: a flammable or combustible atmosphere, The tank or container shall first be 7.2 Access to Tanks purged or vented until the internal atmosphere is at or below 10 percent of the

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lower explosive limit. If this does not achieve a satisfactory atmosphere, the tank or container shall be inerted to eliminate or reduce the amount of oxygen in the atmosphere. A permit shall then be issued to cut the tank or container access opening shall be cut using an air driven saber saw or snipper, using a non-flammable lubricating material to reduce friction and heat and to prevent possible sparks. Prior to making the final cut, the plate shall be supported to prevent its falling into the tank or container. 7.2.5 CAUTION: The drilling and cutting operations have the potential to may create heat and possible sparks on the inner surface of the tank or container which could result in ignition if air and flammable vapors are present inside the tank in the explosive range or if flammable residue are present inside the tank or container. The tank or container shall be either inerted or made vapor freed prior to and maintained vapor free during cutting operations by ventilation. Substantiation: As written the two parts of this section conflict with one another. Part one allows cutting a tank that has a flammable atmosphere (This means the atmosphere in the tank is IN the flammable range!). That is what caused the fire that occurred some years ago in Arizona when a fire department cut into a tank that had not been vapor freed to rescue a worker. Then, conversely, the "Caution" part of the section says the tank shall be "vapor freed" before cutting. You cant have it both ways, in fact it should only be one way (FLAMMABLE vapor free). So I have amended the section to comply with petroleum industry safe practices. The CAUTION paragraph has been renumbered to be its own section as it applies to both the drilling and the cutting operations. As written it would only apply to cutting. Committee Meeting Action: Accept in Principle Replace 7.2.4 with the following: 7l.2.4 For Cutting shall not be permitted on tanks containing a flammable or combustible atmosphere, The tank shall first be purged or vented until the internal atmosphere is at or below 10 percent of the lower flammable limit. If this does not achieve a satisfactory atmosphere, the tank shall be inerted to eliminate or reduce the amount of oxygen in the atmosphere. A permit shall then be issued to cut the tank access opening shall be cut using an air driven saber saw or snipper, using a non-flammable lubricating material to reduce friction and heat and to prevent possible sparks. Prior to making the final cut, the plate shall be supported to prevent its falling into the tank . 7.2.5 CAUTION: The drilling and cutting operations have the potential to may create heat and possible sparks on the inner surface of the tank which could result in ignition if air and flammable vapors are present inside the tank in the explosive range or if flammable residue are present inside the tank. The tank shall be either inerted or made vapor freed prior to and maintained vapor free during cutting operations by ventilation. Committee Statement: The scope of Chapter 7 does not include containers, only tanks. Also, the more correct term is "lower flammable limit". Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanation of Negative: SIEGEL: I believe the terms "vented" and ventilated" are being used interchangeably, which is not correct. The standard should state that tanks "...shall be purged or ventilated..." Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-61 Log #54 Final Action: Accept in Principle ( 7.3.1 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 7.3.1 Before entering tanks, the qualified person issuing the entry permits and personnel assigned as entrants, attendants and rescuers, shall be familiar with the applicable procedures described in ANSI/API Standard 2015, Requirements for Safe Entry and Cleaning Petroleum Storage Tanks; ANSI/ API Recommended Practice 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks, ANSI/API Standard 2217 A, Guidelines for Work in Inert Confined Spaces Work in the Petroleum Industry; ANSI/ASSE Z117.1, American National Standard Safety Requirements for Confined Spaces and OSHA 29 CFR 1910.146, Permit Required Confined Spaces. Substantiation: Text has been revised to show correct numbers and titles of referenced ANSI standards. Committee Meeting Action: Accept in Principle Revise 7.3.1 to read: Before entering tanks, the qualified person issuing the entry permits and personnel assigned as entrants, attendants and rescuers, shall be familiar with the applicable procedures described in ANSI/API 2015, Requirements for Safe Entry and Cleaning Petroleum Storage Tanks; ANSI/API 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks, ANSI/API 2217 A, Guidelines for Work in Inert Confined Spaces Work in the Petroleum Industry; ANSI/ASSE Z117.1, American National Standard Safety Requirements for Confined Spaces and OSHA 29 CFR 1910.146, Permit Required Confined Spaces.

Committee Statement: Corrections to properly designate referenced documents. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

NFPA 326

________________________________________________________________ 326-62 Log #55 Final Action: Accept in Principle ( 7.3.2 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 7.3.2 The vent line(s) or manway shall remain clear and unobstructed to allow continuous ventilation and provide for the appropriate number of air changes during entry and work periods in accordance with the requirements of Section 3.3. All other lines and openings shall be plugged or capped off isolated in accordance with the facility or contractor isolation procedures to keep liquids and vapors from entering the tank or container in accordance with the requirements of section 3.3. If natural ventilation is inadequate to control the vapor in air levels within the tank or containers atmosphere within the permit limits or maintain the required air changes and air quality, continuous mechanical ventilation shall be used while the confined space is occupied. Substantiation: The proposal includes a requirement to provide required number of air changes. It also requires ventilation during entry and work not when the tank is closed up (i.e., for the night) and not being worked on. This section cannot require ALL other lines to be isolated as this would then include the fire protection system (foam lines) which are required to be left open and operational. Plugs and caps are not appropriate safeguards as line pressures may force them open. Depending on the service, the facility or contractor isolation procedure should be followed. OSHA and ANSI/API both require lines to be disconnected, blanked or double blocked and bled (not plugged and capped). Ventilation does more than control vapors. Committee Meeting Action: Accept in Principle Revise 7.3.2 to read: The vent line(s) or manway shall remain clear and unobstructed to allow continuous ventilation and provide for the appropriate number of air changes during entry and work periods in accordance with the requirements of Section 3.3. All other lines and openings shall be plugged or capped off isolated in accordance with the facility or contractor isolation procedures to keep liquids and vapors from entering the tank in accordance with the requirements of section 3.3. If natural ventilation is inadequate to control the vapor-in-air levels within the tanks atmosphere within the permit limits or to maintain the required air changes and air quality, continuous mechanical ventilation shall be used while the confined space is occupied. Committee Statement: The scope of Chapter 7 does not include containers, only tanks. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-63 Log #56 Final Action: Accept in Principle ( 7.3.3 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: The qualified person shall determine the potential hazard and stipulate on the permit, any additional precautions or controls that shall be taken if the tank or container bottom is perforated such that liquids or vapors that could be present in the soil under the tank or in the tank double bottom could enter through the perforation. If this condition exists the qualified person shall stipulate any additional precautions to be taken. The qualified person shall also determine and implement controls required to prevent liquids or vapors from entering into the tank from sumps, roof support columns, pontoons, internal piping, appurtenances or other means. Substantiation: The first part has to be rearranged for clarity. The second sentence is added to include other common hazards. Committee Meeting Action: Accept in Principle Revise 7.3.3 to read: The qualified person shall determine and stipulate on the permit, any additional precautions or controls that shall be taken if the tank bottom is perforated such that liquids or vapors that could be present in the soil under the tank or in the tank double bottom could enter through the perforation. If this condition exists the qualified person shall stipulate any additional precautions to be taken. The qualified person shall also determine and implement controls required to prevent liquids or vapors from entering into the tank from sumps, roof support columns, pontoons, internal piping,

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appurtenances or other means. Committee Statement: The scope of Chapter 7 does not include containers, only tanks. "Potential hazard" is ambiguous and has been deleted. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-64 Log #57 Final Action: Accept in Principle ( 7.4 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: If an access opening has been cut into a tank or container that is designated a confined or permit required confined space, the opening shall be closed or protected, either temporarily or permanently depending on the disposition of the tank such as at the end of the work period or whenever the tank is left unattended. Upon reopening the tank or container, atmospheric testing shall be conducted and the qualified person shall issue (reissue) permits for work and entry. Substantiation: The change specifies that this applied to confined spaces (as door sheets are not reattached each night when working in a tank). Requirements for retesting are based on experience as the atmosphere in a closed tank can change overnight, and over a longer period. Committee Meeting Action: Accept in Principle Revise 7.4 to read: If an access opening has been cut into a tank that is designated a confined or permit required confined space, the opening shall be closed or protected, either temporarily or permanently depending on the disposition of the tank such as at the end of the work period or whenever the tank is left unattended. Upon reopening the tank, atmospheric testing shall be conducted and the qualified person shall issue or reissue permits for work and entry. Committee Statement: The scope of Chapter 7 does not include containers, only tanks. Replacement of parenthetical is editorial correction. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-65 Log #58 Final Action: Accept in Principle ( 8.2.1 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise 8.2.1 as follows: Tanks or containers shall be cleaned prior to hot work and hot work shall be conducted in accordance with the requirements of this standard, ANSI/API Standard 2015, Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks; ANSI/API Recommended Practice 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks, ANSI/API Standard 2217A, Guidelines for Work in Inert Confined Spaces Work in the Petroleum Industry; API Recommended Practice 2207, Preparing Tank Bottoms for Hot Work; ANSI/API Standard 2027 Ignition Hazards and Safe Work Practices for abrasive Blasting of Atmospheric Storage Tanks in Hydrocarbon Service; API 2009, Safe Welding and Cutting Practices in Refineries, Gas Plants and Petrochemical plants; and NFPA 51B, Cutting and Welding Processes. Substantiation: The standards cited are all applicable to hot work in tanks and should be referenced in this standard so that industry and regulatory safe hot work practices are required in NFPA 326 to prevent accidents and injuries. Add referenced publications to Chapter 9. Committee Meeting Action: Accept in Principle Revise 8.2.1 to read: 8.2.1* Tanks or containers shall be cleaned prior to hot work and hot work shall be conducted in accordance with the requirements of this standard and other applicable standards and regulations, Add annex item to read: A.8.2.1 See also ANSI/API 2015, Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks; ANSI/API 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks, ANSI/API 2217A, Guidelines for Work in Inert Confined Spaces Work in the Petroleum Industry; API 2207, Preparing Tank Bottoms for Hot Work; ANSI/ API 2027 Ignition Hazards and Safe Work Practices for abrasive Blasting of Atmospheric Storage Tanks in Hydrocarbon Service; API 2009, Safe Welding and Cutting Practices in Refineries, Gas Plants and Petrochemical plants; and NFPA 51B, Cutting and Welding Processes, and OSHA 29 CFR 1910.147 Committee Statement: The references more properly belong in the annex. Number Eligible to Vote: 14

Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

NFPA 326

________________________________________________________________ 326-66 Log #59 Final Action: Accept ( 8.3.2 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: 8.3.2 Because residues can become trapped behind heavy scale or rust and not be easily detected or removed, it is sometimes impossible to remove all liquid or solid residue that could allow vapors to recur during work because residues can become trapped behind heavy scale or rust and not be easily detected. In such instances, the qualified person shall evaluate the potential hazard and determine the necessary control measures and assure that required additional precautions shall be taken. Substantiation: Rearranges for clarity and assigns responsibility. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-67 Log #61 Final Action: Accept in Principle ( A.1.1.2 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Correct name as follows: (5) ANSI/API 2015 Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks Add the following and renumber the remainder: (6) ANSI/API 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks (7) API 2217A, Guidelines for Work in Inert Confined Spaces in the Petroleum Industry Substantiation: API 2015 has now been split into two separate documents, 2015 and 2016. Adds API 2217A which is referenced in NFPA 326. Committee Meeting Action: Accept in Principle Revise A.1.1.2 to read: Procedures for making some of the tanks and containers vessels listed in 1-1.2 safe are covered separately in the following publications: (1) AGA, Purging Principles and Practices (2) ANSI Z117.1, American National Standard Safety Requirements for Confined Spaces (3) API 1631, Interior Lining of Underground Storage Tanks (4) API 2013, Cleaning Mobile Tanks in Flammable or Combustible Liquid Service (5) API 2009, Safe Welding and Cutting Practices in Refineries, Gas Plants and Petrochemical Plants (6) API 2015, Safe Entry and Cleaning of Petroleum Storage Tanks (7) ANSI/API 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks (8) ANSI/API 2217A, Guidelines for Work in Inert Confined Spaces Work in the Petroleum Industry (9) API 2207, Preparing Tank Bottoms for Hot Work; ANSI/API 2027 Ignition Hazards and Safe Work Practices for abrasive Blasting of Atmospheric Storage Tanks in Hydrocarbon Service (10) NFPA 51B, Cutting and Welding Processes (11) NFPA 306, Standard for the Control of Gas Hazards on Vessels (7) NLPA 631, Entry, Cleaning, Interior Inspection, Repair, and Lining of Underground Storage Tanks (12) 29 CFR 1910.146, "Permit-Required Confined Spaces (13) 29 CFR 1910.147, "Control of Hazardous Energy (Lockout/Tagout)" Committee Statement: Additional appropriate references have been added and one reference deleted because it is no longer available. Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

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________________________________________________________________ 326-68 Log #60 Final Action: Accept ( A.1.4 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Change the list of third party experts as follows: (a) American Petroleum Institute Certified Aboveground Storage Tank Inspectors (recognized for expertise in aboveground storage tank design, structure, function and operation as it relates to API 653, Tank Inspection, Repair Alteration and Reconstruction, and Certified Tank Entry Supervisor (recognized for expertise in tank entry and cleaning as it relates to ANSI/API 2015, Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks API 2016 Guidelines and procedures for Entering and Cleaning Petroleum Storage Tanks. Contact the American Petroleum Institute, Certification Programs Department, 1220 L Street, NW, Washington, DC, 20005. Substantiation: The proposed change provides information on the new API program to certify qualified persons as tank entry and cleaning supervisors. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Comment on Affirmative: SIEGEL: I believe the terms "vented" and "ventilated" are being used interchangeably, which is not correct. The standard should state that tanks "...shall be purged or ventilated..." Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-69 Log #62 Final Action: Accept ( A.2.2.5 and A.3.2.2 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Add the following to both paragraphs A.2.2.5 and A.3.2.2: API 2219, Safe Operating Guidelines for Vacuum Trucks in Petroleum Service ANSI/API 2015, Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks ANSI/API 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks Substantiation: These documents are the only ones that provide safe work procedures and fire prevention information related to static generation and control during tank ventilation and gas freeing, tank cleaning, pump out and vacuum truck operations. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-70 Log #63 Final Action: Accept ( A.4.1.1 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Delete text as follows: A.4.1.1 It is recommended that continuous monitoring be performed inside the tank or container when personnel are inside. Substantiation: See 4.1.2. Continuous atmospheric monitoring is not often required whenever persons are in the tank. This depends on the circumstances, work performed, hazards and potential hazards and should be determined by the qualified person. The requirements for continuous monitoring are covered thoroughly in NFPA 326 and do not need to be reiterated in the appendix. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

________________________________________________________________ 326-71 Log #64 Final Action: Accept ( A.4.3.1 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Add new text as follows: In addition, when the tank of container is oxygen rich (the oxygen level is above that of the ambient air outside the tank) the reading will be in error. The qualified person should determine and control the source of additional oxygen before proceeding with testing. Substantiation: High oxygen levels are even more dangerous than low levels. They affect readings by increasing the flammable range. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-72 Log #65 Final Action: Accept ( A.4.3.6 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: A.4.3.6 ANSI/API 2015 Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks and ANSI/API 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks contain specific hot work requirements and safe practices and requirement that are beyond the scope and intent of this standard should be considered by the qualified person when permitting hot work inside confined spaces. Substantiation: Why would NFPA 326 indicate that another ANSI tank cleaning standard contains requirements beyond the scope of the document. Does this mean that this document does not apply to petroleum storage tanks. If anything, the hot work requirements in ANSI/API 2015 and 2016 are necessary to prevent fires. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

NFPA 326

________________________________________________________________ 326-73 Log #66 Final Action: Accept ( A.5.1.1 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: A.5.1.1 Also refer to API 2217A, Guidelines for Work in Inert Confined Spaces in the Petroleum Industry, ANSI/API 2015, Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks and ANSI/API 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks for safe practices and requirements when using an inert gas to vapor free a tank or container. Substantiation: The specific requirements for the use of inert gas to vapor free a tank is fully covered in ANSI/API 2015 and 2016. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-74 Log #67 Final Action: Accept ( A.5.2.1.2 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Add the following text to the end of the paragraph as follows: A.5.2.1.2 Also see ANSI/API 2015, Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks and ANSI/API 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks for bonding practices and requirements.

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Substantiation: The specific requirements and procedures for bonding are fully covered in ANSI/API 2015 and 2016. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-75 Log #68 Final Action: Accept ( A.5.2.2.6 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Add the following new text at the end of paragraph as follows: A.5.2.2.6 Refer to API 2217A, Guidelines for Work in Inert Confined Spaces in the Petroleum Industry, ANSI/API 2015, Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks and ANSI/API 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks, for safe practices and requirements when using an inert gas to vapor free a tank or container. Substantiation: Listing the specific references to be consulted for the use of inert gas to vapor free a tank, such as ANSI/API 2015, 2016 and 2217A, is user friendly (instead of having to browse through the entire standard). Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-76 Log #69 Final Action: Accept ( A.5.2.4 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: A.5.2.4 See also ANSI/API 2015, Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks and ANSI/API 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks, and NFPA 77..." Substantiation: The specific safety requirements for inerting are fully covered in ANSI/API 2015 and 2016. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-77 Log #70 Final Action: Accept ( A.6.1 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Delete the following paragraph. Confined space entry permits and hot work permits are examples of certificates. Substantiation: I have proposed removing the term certifications from this as used to describe "permits", "permit" is the correct word. The word "permit" is used in all ANSI, OSHA, API, and other NFPA documents (NFPA 1, 51B, etc.) as related to entry, hot and safe work. Use of the term certification is confusing as related to qualified persons who are "certified". As related to tank inspection, certification is an approval document. Use of the term certification without defining it in this standard is confusing. I would not expect a certified tank entry supervisor to know what the term "certification" means. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

________________________________________________________________ 326-78 Log #71 Final Action: Accept ( A.6.2.3 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Add the following text to the last sentence. A.6.2.3 In atmospheric situations other than those in A.6.2.3(1) - (3) refer to ANSI/API 2015 Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks and ANSI/API 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks, for information on entering tanks with special precautions. Substantiation: The specific entry requirements are fully covered in ANSI/ API 2015 and 2016. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1). ________________________________________________________________ 326-79 Log #72 Final Action: Accept ( A.8.5 ) ________________________________________________________________ Submitter: Richard S. Kraus, Petroleum Safety Consultants / Rep. American Petroleum Institute Recommendation: Revise text to read as follows: A.8.5 See Section 4.7.2 of ANSI/API 2015 Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks and ANSI/API 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks..." Substantiation: The specific section has been changed. Additional requirements are covered in ANSI/API 2016. Committee Meeting Action: Accept Number Eligible to Vote: 14 Ballot Results: Affirmative: 9 Abstain: 1 Vote Not Returned: 4 REKUS, RIDDLE, SELISKER, SMITH Explanatin of Abstention: WILLWERTH: See my Explanation of Abstention for Committee Proposal 326-3 (Log #CP1).

NFPA 326

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