National Fire Protection Association

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1 National Fire Protection Association 1 Batterymarch Park, Quincy, MA Phone: Fax: MEMORANDUM To: From: NFPA Technical Committee on Liquefied Natural Gas Colleen Kelly, Administrator Technical Projects Date: September 4, 2015 Subject: NFPA 59A Proposed Tentative Interim Amendment (TIA) No.1187R The attached proposed Tentative Interim Amendment (TIA) is being submitted to you for letter ballot. This proposed TIA was submitted by Adnan Ezzarhouni of GTT and endorsed by Joel Madison of Ebara International Corporation, Richard Hoffmann of Hoffmann & Feige and Nicholas Legatos of Preload Incorporated. This proposed TIA will be published for public comment in the September 4, 2015 issue of NFPA News with a Public Comment Closing Date of October 16, Any public comments received will be circulated to the committee. The Standards Council will consider the issuance of this TIA at their December 8 9, 2015 meeting. In addition to being balloted on the technical merits of the proposed TIA, the Committee is also being balloted on whether or not this matter is of an emergency nature. Please see Section 5 (copy enclosed) regarding the processing of TIAs from the Regulations Governing the Development of NFPA Standards. Please complete and return your ballot as soon as possible but no later than September 18, As noted on the ballot form, please return the ballot to Colleen Kelly either via to ckelly@nfpa.org or via fax to You may also mail your ballot to the attention of Colleen Kelly at NFPA, 1 Batterymarch Park, Quincy, MA Note: Please remember that the return of ballots and attendance at committee meetings are required in accordance with the Regulations Governing the Development of NFPA Standards. Attachments

2 Section 5 Tentative Interim Amendments (TIAs). 5.1 Who May Submit a Tentative Interim Amendment. Anyone may submit a TIA and the submitter need not be a member of the NFPA. All TIAs must be submitted in the name of an individual with the individual s relevant organizational affiliation or representation noted separately. The individual shall be considered the submitter for the purpose of these Regulations. 5.2 Content of a Proposed Tentative Interim Amendment. Each TIA shall be submitted to the Standards Council Secretary and shall include the following: (a) Identification of the submitter and his or her affiliation (i.e., Technical Committee, organization, company), where appropriate (b) Identification of the NFPA Standard, edition of the NFPA Standard, and paragraph of the NFPA Standard to which the TIA is directed (c) Proposed text of the TIA, including the wording to be added, revised (and how revised), or deleted (d) Statement of the problem and substantiation for the TIA (e) The signature of the submitter or other means of authentication approved by the Standards Council Secretary (f) Statement of the basis of conclusion that the TIA is of an emergency nature requiring prompt action (g) The written agreement of at least two members of the involved Technical Committee or Correlating Committee to the processing of the TIA. The agreement to the processing of the TIA is for the sole purpose to allow the TIA to be processed and does not necessarily imply agreement with the merits or emergency nature of the TIA. 5.3 Preliminary Screening of Proposed Tentative Interim Amendment. The Standards Council Secretary shall review all Proposed TIAs and may return to the submitter, without processing, any submission that does not conform to Section 5.2. In addition, the Standards Council Secretary may reject for processing any proposed TIA that does not manifestly appear to be of an emergency nature requiring prompt action. In exercising his or her discretion to reject a proposed TIA for processing, the Standards Council Secretary may consult with the responsible Technical Committee/Correlating Committee chairs and may consider, without limitation, whether the TIA submittal, on its face, does not state any adequate basis on which to conclude that it is of an emergency, whether it is unduly repetitive of issues already considered and rejected by the Technical Committee/Correlating Committee, or whether it is plainly frivolous. Where, however, there exists any reasonable question about the emergency nature of the proposed TIA or where the Standards Council Secretary determines that it is otherwise advisable for the TIA to be processed, the Standards Council Secretary shall submit the TIA for processing, and the question of emergency nature shall be considered anew and determined by the responsible Technical Committee and Correlating Committee. The text of a proposed TIA may be processed as submitted or may be changed, but only with the approval of the submitter. 5.4 Evaluation of Emergency Nature. Determination of an emergency nature shall include but not be limited to one or more of the following factors: (a) The NFPA Standard contains an error or an omission that was overlooked during a regular revision process. (b) The NFPA Standard contains a conflict within the NFPA Standard or with another NFPA Standard. (c) The proposed TIA intends to correct a previously unknown existing hazard. (d) The proposed TIA intends to offer to the public a benefit that would lessen a recognized (known) hazard or ameliorate a continuing dangerous condition or situation. (e) The proposed TIA intends to accomplish a recognition of an advance in the art of safeguarding property or life where an alternative method is not in current use or is unavailable to the public. (f) The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. 5.5 Publication of Proposed Tentative Interim Amendment. A proposed Tentative Interim Amendment that meets the provisions of Section 5.2 shall be published indicating that the proposed Tentative Interim Amendment has been forwarded to the responsible Technical Committee and Correlating Committee for processing and that anyone interested may comment on the proposed Tentative Interim Amendment within the time period established and published. 5.6 Technical Committee and Correlating Committee Action. (a) The proposed Tentative Interim Amendment shall be submitted for Ballot and comment of the Technical Committee in accordance with The Technical Committee shall be separately Balloted on both the technical merits of the amendment and whether the amendment involves an issue of an emergency nature. Such Balloting shall be completed concurrently with the public review period. Any Public Comments inconsistent with the vote of any Technical Committee Member shall be circulated to the Technical Committee to allow votes to be changed. A recommendation for approval shall be established if three-fourths of the voting Members calculated in accordance with (c) have voted in favor of the Tentative Interim Amendment. (b) The proposed Tentative Interim Amendment shall be submitted for Ballot and comment of the Correlating Committee, if any, which shall make a recommendation to the Standards Council with respect to the disposition of the Tentative Interim Amendment. The Correlating Committee shall be separately Balloted on both the merits of the amendment (as it relates to the Correlating Committee authority and responsibilities in accordance with and 3.4.3) and whether the amendment involves an issue of an emergency nature. Any Public Comments inconsistent with the vote of any Technical Committee or Correlating Committee Member shall be circulated to the Correlating Committee to allow votes to be changed. A recommendation for approval shall be established if three-fourths of the voting Members calculated in accordance with (c) have voted in favor of the Tentative Interim Amendment. (c) All Public Comments, Ballots, and comments on Ballots on the proposed Tentative Interim Amendment shall be summarized in a staff report and forwarded to the Standards Council for action in accordance with Section Action of the Standards Council. The Standards Council shall review the material submitted in accordance with 5.6(c), together with the record on any Appeals (see Section 1.6, 1.6.1), and shall take one of the following actions: (a) Issue the proposed Tentative Interim Amendment. (b) Issue the proposed Tentative Interim Amendment as amended by the Standards Council. (c) Where acted on concurrently with the issuance of a new edition of the NFPA Standard to which it relates, issue the Tentative Interim Amendment as part of the new edition. (d) Reject the proposed Tentative Interim Amendment. (e) Return the proposed Tentative Interim Amendment to the Technical Committee with appropriate instruction (f) Direct a different action. 5.8 Effective Date of a Tentative Interim Amendment. Tentative Interim Amendments shall become effective 20 days after Standards Council

3 issuance unless the President determines, within his or her discretion, that the effective date shall be delayed pending the consideration of a Petition to the Board of Directors (see Section 1.7). The President may also, within his or her discretion, refer the matter of a delay in the effective date of the TIA to the Executive Committee of the Board of Directors or to the Board of Directors. 5.9 Publication of Tentative Interim Amendments. The NFPA shall publish a notice of the issuance of each Tentative Interim Amendment and may, as appropriate, issue a news release to applicable and interested technical journals. The notice and any news release shall indicate the tentative character of the Tentative Interim Amendment. In any subsequent distribution of the NFPA Standard to which the Tentative Interim Amendment applies, the text of the Tentative Interim Amendment shall be included in a manner judged most feasible to accomplish the desired objectives Applicability. Tentative Interim Amendments shall apply to the NFPA Standard existing at the time of issuance. Tentative Interim Amendments issued after the Public Input closing date shall also apply, when the text of the existing NFPA Standard remains unchanged, to the next edition of the NFPA Standard. Tentative Interim Amendments issued concurrently with the issuance of a new edition shall apply to both the existing and the new editions, unless the Standards Council determines otherwise Subsequent Processing. The Technical Committee responsible for the NFPA Standard or the part of the NFPA Standard affected shall process the subject matter of any Tentative Interim Amendment as Public Input for the next edition of the NFPA Standard (see Section 3.3). Such Public Input shall be accompanied by a notice indicating its origin as a TIA, including all necessary information as required in 4.3.4, and originally submitted in the TIA Exception. When the Standards Council authorizes other procedures for the processing and/or issuance of Tentative Interim Amendments, the provisions of this section shall not apply.

4 Section 5 Tentative Interim Amendments (TIAs). 5.1 Who May Submit a Tentative Interim Amendment. Anyone may submit a TIA and the submitter need not be a member of the NFPA. All TIAs must be submitted in the name of an individual with the individual s relevant organizational affiliation or representation noted separately. The individual shall be considered the submitter for the purpose of these Regulations. 5.2 Content of a Proposed Tentative Interim Amendment. Each TIA shall be submitted to the Standards Council Secretary and shall include the following: (a) Identification of the submitter and his or her affiliation (i.e., Technical Committee, organization, company), where appropriate (b) Identification of the NFPA Standard, edition of the NFPA Standard, and paragraph of the NFPA Standard to which the TIA is directed (c) Proposed text of the TIA, including the wording to be added, revised (and how revised), or deleted (d) Statement of the problem and substantiation for the TIA (e) The signature of the submitter or other means of authentication approved by the Standards Council Secretary (f) Statement of the basis of conclusion that the TIA is of an emergency nature requiring prompt action (g) The written agreement of at least two members of the involved Technical Committee or Correlating Committee to the processing of the TIA. The agreement to the processing of the TIA is for the sole purpose to allow the TIA to be processed and does not necessarily imply agreement with the merits or emergency nature of the TIA. 5.3 Preliminary Screening of Proposed Tentative Interim Amendment. The Standards Council Secretary shall review all Proposed TIAs and may return to the submitter, without processing, any submission that does not conform to Section 5.2. In addition, the Standards Council Secretary may reject for processing any proposed TIA that does not manifestly appear to be of an emergency nature requiring prompt action. In exercising his or her discretion to reject a proposed TIA for processing, the Standards Council Secretary may consult with the responsible Technical Committee/Correlating Committee chairs and may consider, without limitation, whether the TIA submittal, on its face, does not state any adequate basis on which to conclude that it is of an emergency, whether it is unduly repetitive of issues already considered and rejected by the Technical Committee/Correlating Committee, or whether it is plainly frivolous. Where, however, there exists any reasonable question about the emergency nature of the proposed TIA or where the Standards Council Secretary determines that it is otherwise advisable for the TIA to be processed, the Standards Council Secretary shall submit the TIA for processing, and the question of emergency nature shall be considered anew and determined by the responsible Technical Committee and Correlating Committee. The text of a proposed TIA may be processed as submitted or may be changed, but only with the approval of the submitter. 5.4 Evaluation of Emergency Nature. Determination of an emergency nature shall include but not be limited to one or more of the following factors: (a) The NFPA Standard contains an error or an omission that was overlooked during a regular revision process. (b) The NFPA Standard contains a conflict within the NFPA Standard or with another NFPA Standard. (c) The proposed TIA intends to correct a previously unknown existing hazard. (d) The proposed TIA intends to offer to the public a benefit that would lessen a recognized (known) hazard or ameliorate a continuing dangerous condition or situation. (e) The proposed TIA intends to accomplish a recognition of an advance in the art of safeguarding property or life where an alternative method is not in current use or is unavailable to the public. (f) The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. 5.5 Publication of Proposed Tentative Interim Amendment. A proposed Tentative Interim Amendment that meets the provisions of Section 5.2 shall be published indicating that the proposed Tentative Interim Amendment has been forwarded to the responsible Technical Committee and Correlating Committee for processing and that anyone interested may comment on the proposed Tentative Interim Amendment within the time period established and published. 5.6 Technical Committee and Correlating Committee Action. (a) The proposed Tentative Interim Amendment shall be submitted for Ballot and comment of the Technical Committee in accordance with The Technical Committee shall be separately Balloted on both the technical merits of the amendment and whether the amendment involves an issue of an emergency nature. Such Balloting shall be completed concurrently with the public review period. Any Public Comments inconsistent with the vote of any Technical Committee Member shall be circulated to the Technical Committee to allow votes to be changed. A recommendation for approval shall be established if three-fourths of the voting Members calculated in accordance with (c) have voted in favor of the Tentative Interim Amendment. (b) The proposed Tentative Interim Amendment shall be submitted for Ballot and comment of the Correlating Committee, if any, which shall make a recommendation to the Standards Council with respect to the disposition of the Tentative Interim Amendment. The Correlating Committee shall be separately Balloted on both the merits of the amendment (as it relates to the Correlating Committee authority and responsibilities in accordance with and 3.4.3) and whether the amendment involves an issue of an emergency nature. Any Public Comments inconsistent with the vote of any Technical Committee or Correlating Committee Member shall be circulated to the Correlating Committee to allow votes to be changed. A recommendation for approval shall be established if three-fourths of the voting Members calculated in accordance with (c) have voted in favor of the Tentative Interim Amendment. (c) All Public Comments, Ballots, and comments on Ballots on the proposed Tentative Interim Amendment shall be summarized in a staff report and forwarded to the Standards Council for action in accordance with Section Action of the Standards Council. The Standards Council shall review the material submitted in accordance with 5.6(c), together with the record on any Appeals (see Section 1.6, 1.6.1), and shall take one of the following actions: (a) Issue the proposed Tentative Interim Amendment. (b) Issue the proposed Tentative Interim Amendment as amended by the Standards Council. (c) Where acted on concurrently with the issuance of a new edition of the NFPA Standard to which it relates, issue the Tentative Interim Amendment as part of the new edition. (d) Reject the proposed Tentative Interim Amendment. (e) Return the proposed Tentative Interim Amendment to the Technical Committee with appropriate instruction (f) Direct a different action. 5.8 Effective Date of a Tentative Interim Amendment. Tentative Interim Amendments shall become effective 20 days after Standards Council

5 issuance unless the President determines, within his or her discretion, that the effective date shall be delayed pending the consideration of a Petition to the Board of Directors (see Section 1.7). The President may also, within his or her discretion, refer the matter of a delay in the effective date of the TIA to the Executive Committee of the Board of Directors or to the Board of Directors. 5.9 Publication of Tentative Interim Amendments. The NFPA shall publish a notice of the issuance of each Tentative Interim Amendment and may, as appropriate, issue a news release to applicable and interested technical journals. The notice and any news release shall indicate the tentative character of the Tentative Interim Amendment. In any subsequent distribution of the NFPA Standard to which the Tentative Interim Amendment applies, the text of the Tentative Interim Amendment shall be included in a manner judged most feasible to accomplish the desired objectives Applicability. Tentative Interim Amendments shall apply to the NFPA Standard existing at the time of issuance. Tentative Interim Amendments issued after the Public Input closing date shall also apply, when the text of the existing NFPA Standard remains unchanged, to the next edition of the NFPA Standard. Tentative Interim Amendments issued concurrently with the issuance of a new edition shall apply to both the existing and the new editions, unless the Standards Council determines otherwise Subsequent Processing. The Technical Committee responsible for the NFPA Standard or the part of the NFPA Standard affected shall process the subject matter of any Tentative Interim Amendment as Public Input for the next edition of the NFPA Standard (see Section 3.3). Such Public Input shall be accompanied by a notice indicating its origin as a TIA, including all necessary information as required in 4.3.4, and originally submitted in the TIA Exception. When the Standards Council authorizes other procedures for the processing and/or issuance of Tentative Interim Amendments, the provisions of this section shall not apply.

6 NFPA 59A-Proposed 2016 Edition Standard for the Production, Storage, and Handling of Liquefied Natural Gas (LNG) TIA Log No.: 1187R Reference: Various Comment Closing Date: October 16, 2015 Submitter: Adnan Ezzarhouni, GTT 1. Add new entry to Subsection to read as follows: EN through 5, (2006) Design and manufacture of site built, vertical, cylindrical, flat-bottomed, steel tanks for the storage of refrigerated, liquefied gases with operating temperatures between 0 C and -165 C PARTS 1 5. CEB Bulletin 187 (1988) Concrete Structures under Impact and Impulsive Loading. 2. Add new * and Annex to read as follows (renumber current as ): * Membrane Containment Tank System. A tank system consisting of a thin metal liquid barrier and load-bearing thermal insulation supported by a self-standing outer concrete container jointly forming an integrated composite tank structure designed to contain liquid and vapor during tank operation as well as LNG in the event of leakage from the liquid barrier, and where the vapor-containing roof of the outer container is either steel or concrete configured such that the excess vapor caused by a spill of LNG from the liquid barrier will discharge through the relief valves. A A membrane containment tank system consists of a thin metal liquid- and vapor-tight barrier resting against load-bearing thermal insulation and supported by a free-standing outer pre-stressed concrete container. In normal conditions, primary liquid and vapor containment is provided by a thin metallic barrier which is structurally supported via load-bearing insulation on an outer pre-stressed concrete container. Under these conditions primary vapor containment is provided by a thin metallic barrier which is connected to the metallic roof liner. In emergency conditions, the secondary liquid and vapor containment is provided by an outer pre-stressed concrete container and metallic roof liner. The outer container must be capable of both containing the liquid product and controlling the vapor resulting from evaporation. In this instance the vapor generated from the leakage is discharged through pressure relief valves located in the roof. Vapor losses due to permeability through the outer pre-stressed concrete are acceptable while the wall is containing liquid in the event of leakage from the thin metal barrier and insulation system. The roof of the outer pre-stressed concrete container may be concrete or steel. Significant design issues arise at the monolithic base-to-wall connection due to the mechanical restraint offered by the base. To mitigate these issues, a secondary liquid containment barrier inside the insulation system across the entire bottom and part of the wall in the vicinity of the base-to-wall joint is to be provided to protect and thermally isolate this area from the cold liquid and provide liquid-tightness. Other alternatives of the monolithic base-to-wall are described in ACI376.

7 * Single Containment Tank System. A single wall container or a double wall tank system in which only the self-supporting primary or inner container is designed to contain LNG. 3. Revise (4) to read as follows: Provisions shall be made to minimize the potential of accidental discharge of LNG at containers, pipelines containing LNG, and other equipment such that a discharge from any of these does not endanger adjoining property or important process equipment and structures or reach waterways. LNG containers shall be provided with one of the following methods to contain any release: (1) An impounding area surrounding the container(s) that is formed by a natural barrier, dike, impounding wall, or combination thereof complying with and (2) An impounding area formed by a natural barrier, dike, excavation, impounding wall, or combination thereof complying with and 5.3.3, plus a natural or man-made drainage system surrounding the container(s) that complies with and (3) Where the container is constructed below or partially below the surrounding grade, an impounding area formed by excavation complying with and (4) Secondary containment as required for double, or full, or membrane containment tank systems complying with and Revise * and Annex to read as follows: * Dikes and impounding walls shall meet the following requirements: (1) Dikes, impounding walls, drainage systems, and any penetrations thereof shall be designed to withstand the full hydrostatic head of impounded LNG or flammable refrigerant, the effect of rapid cooling to the temperature of the liquid to be confined, any anticipated fire exposure, and natural forces, such as earthquakes, wind, and rain. (2) Where the outer shell of a tank system double wall tank complies with the requirements of , the dike shall be either the outer shell or as specified in A Section requires compliance with API 625. API 625 paragraph 5.6 requires the selection of storage concept to be based on a risk assessment. API 625 Annex C discusses implications of a release of liquid from the primary liquid container and provides specific discussion related to each containment type. API 625 Annex D provides guidance for selection of storage concepts as part of the risk assessment including external and internal events and hazards to be evaluated. Paragraph D discusses the possibility of sudden failure of the inner tank and advises if extra protection from brittle fracture (or unabated ductile crack propagation) is desired, the general practice is to increase the primary container toughness. Available materials meeting the required specifications of API 620 Appendix Q (and this standard) for LNG service are considered to have crack-arrest properties at LNG service temperature and stress levels. Therefore, rapid failure of a steel primary container meeting this standard is not considered credible. In membrane containment tank systems, brittle fracture of

8 membrane material is typically not a pertinent hazard for membrane tanks. However, other hazards based on a risk assessment should be considered. 5. Revise to read as follows: Double, and full, and membrane containment tank systems shall be designed and constructed such that in the case of a fire in an adjacent tank, the secondary container shall retain sufficient structural integrity to prevent collapse, which can cause damage to and leakage from the primary container. 6. Revise to read as follows: Double, and full, and membrane containment tank systems shall have no pipe penetrations below the liquid level. 7. Revise and add new to read as follows: Double, ffull, and double membrane containment tank systems of greater than 70,000 gal (265 m 3 ) water capacity shall be separated from adjacent LNG storage containers such that a fire in an adjacent single or double containment impoundment or from a design spill will not cause loss of containment from adjacent containers. This shall be accomplished by ensuring that no part of the adjacent storage container roof, walls, or its impoundment structure reaches a temperature at which the strength of the material of the container roof, wall, or its impoundment is reduced to a level where the LNG tank, roof, or impoundment loses its structural integrity The outer concrete container shall be designed for the external fire in accordance with ACI 376 unless fire protection measures are provided. The outer tank thermal analysis shall be performed to determine temperature distribution for the heat flux and duration of exposure as specified in the fire risk assessment within API 625. (1) The applicable load components and the ultimate state load factors for the fire load combinations shall be in accordance with ACI 376 Table 7.3. For membrane tanks, an additional liquid pressure load in accordance with ACI 376 Table 7.2 shall be included. (2) The design of the outer concrete container shall take into account the following factors: (a) Reduction in the wall post-tensioning due to the difference in the coefficient thermal expansion of post-tensioning steel and wall concrete at the temperature to which the post-tensioning steel is exposed. The effects of the concrete aggregate type on the concrete coefficient thermal expansion shall be considered; (b) Reduction in strength and modulus of elasticity of the outer tank concrete, reinforcing and post-tensioning steel due to elevated temperature; (c) Reduction in the wall post-tensioning due to pre-stressing steel softening and relaxation at elevated temperature; (3) The concrete wall, including the wall concrete mix, shall be designed to avoid explosive spalling.

9 8. Revise to read as follows: Storage tank systems shall comply with the requirements of API 625, Tank Systems for Refrigerated Liquefied Gas Storage, including membrane containment tank systems, and the additional provisions of this chapter. The API 625 risk assessment shall be approved by the AHJ. 9. Add new and and renumber current to read as follows: The metallic membrane, load-bearing insulation, and the outer container moisture barrier specific to the membrane tank system shall comply with EN parts 1-5 for material selection, design, installation, examination, and testing and further requirements of 7.4. All other components of the membrane tank system shall comply with API625, API620, ACI376 and additional requirements in Section All the membrane system components, including insulation, primary membrane, and the secondary barrier of the thermal protection system, shall be designed in such a way that they can withstand all possible static and dynamic actions throughout the tank lifetime Should any conflict exist between the above requirements, the most stringent requirement shall apply. 10. Revise (A) to read as follows: All piping that is a part of an LNG tank system shall comply with requirements in this chapter and requirements within API 625. (A) Tank system piping shall include all piping internal to the container, within insulation spaces and within void spaces, external piping attached or connected to the container up to the first circumferential external joint of the piping, and external piping serving only tank instrumentation (including tank pressure relief valves). All liquid piping with a source of external line pressure shall be designed for the external line relief valve setting but not less than 50 psi (345 kpa). Double, and full, and membrane containment tank systems shall have no pipe penetrations below the liquid level 11. Revise , (A), and (C) and add new (D) to read as follows: The space between the inner container and the outer container shall contain insulation that is compatible with LNG and natural gas and that is noncombustible as installed for normal service and abnormal conditions. (A) A fire external to the outer tank shall not cause a reduction of the insulation thermal conductivity due to melting or settling to the internal containment system performance due to damage to any component of the insulation systems. (B) The load-bearing bottom insulation shall be designed and installed so that cracking from thermal and mechanical stresses does not jeopardize the integrity of the container.

10 (C) For tank systems other than membrane containment tank system, Oonly materials used between the inner and outer tank bottoms (floors) shall not be required to meet the combustibility requirements, where the material and the design of the installation comply with all of the following: (1) The flame spread index of the material shall not exceed 25, and the material shall not support continued progressive combustion in air. (2) The material shall be of such composition that surfaces that would be exposed by cutting through the material on any plane shall have a flame spread index not greater than 25 and shall not support continued progressive combustion. (3) It shall be shown by test that the combustion properties of the material do not increase significantly as a result of long-term exposure to LNG or natural gas at the anticipated service pressure and temperature. (4) The materials in the installed condition shall be demonstrated to be capable of being purged of natural gas. (5) The natural gas remaining after purging shall not be significant and shall not increase the combustibility of the material. (D) For membrane containment tank systems, the insulation system block shall include a non-foam cover (underneath the primary membrane) and shall include a welding thermal protection system in order to withstand all heat from welding during installation and during maintenance, if any. 12. Add a new to read as follows: For membrane containment tank systems, weld procedure and production weld testing shall comply with EN14620 part 2 and the following requirements: Qualification of Welders. All personnel associated with the welding fabrication of the membrane system shall be qualified by the manufacturer per an agreed upon schedule between the purchaser, the AHJ, and the fabricator. All records shall be available for review Inspection. 100% of all welding shall be visually examined for workmanship and conformance to the fabrication requirements. Bead placement and consistency shall be, at a minimum, documented by digital means for review by supervisory personnel. The personnel performing this visual inspection shall be qualified to an accepted standard for this inspection work. Upon cooldown of the welds to room temperature, provisions shall be made to perform a penetrant inspection (PT) of at least 5% of each weld type each day. The selection factors include orientation, welding direction, and complexity of welding being performed. a) All profiles and configurations of welds shall be subjected to this 5% requirement. The selection of this 5% sample shall be agreed upon by the fabricator, customer s representative, and the AHJ. b) The acceptance standard for this inspection technique shall be agreed upon by all parties. c) Any indication of a leak requires an additional 5% penetrant inspection of the total distance welded by each welder. Inspection after completion of membrane represents the last step prior to the cooldown of the tank to service temperature. After completion of the membrane, a leakage test shall be performed. Leakage shall be determined as agreed upon by the fabricator and customer.

11 Tracer gas for this leak test shall be in accordance with approved procedure. All areas where leakage exceeds limit shall be repaired and inspected per , and the manufacturer s approved procedure. In parallel, mechanical stress testing of the welding joints shall be performed by applying 3 cycles from atmospheric pressure to +20 mbarg inside the insulation space, with the pressure maintained, for a minimum time of 30 minutes. Data shall be recorded Post-Repair Inspection. Additional tracer gas testing shall be performed if more than 4 leaks per 1,000 m² of membrane are identified. All repaired areas shall be visually inspected (VT), vacuum box (VB) tested, and dye penetrant (PT) tested Final Global Test and Control During removal of construction equipment. This testing shall be in agreement with the approved test procedure and witnessed by all relevant parties. This represents the final acceptance testing of the completed membrane structure following completion of its installation in the structural outer shell / container. a) The overall tightness of the membrane shall be determined by establishing a pressure difference between the tank and the insulation space. b) This pressurization allows gas flow through the membrane representative of potential leaks on the membrane. c) The potential leak(s) shall be characterized by measuring the oxygen content increase in the primary insulated space as the tank is pressurized with dry air d) The primary insulated space shall be regulated slightly above the atmospheric pressure. e) All test data, all records, documentation, and witness records shall be submitted to all parties for their review and final acceptance. Daily tightness check/monitoring shall be performed during removal of construction equipment by pulling vacuum inside insulated spaces. Any pressure rise is indicative of a leak and must be reported and corrective action taken. 13. Revise (C) as follows: (C) The SSE design shall provide for no loss of containment capability of the primary container of single, double and full containment tank systems and of the metal liquid barrier of membrane tank system, and it shall be possible to isolate and maintain the LNG tank system during and after the SSE 14. Revise and add new as follows: The secondary liquid container or impounding system for single, double or full containment tanks shall, as a minimum, be designed to withstand an SSE while empty and an ALE while holding a volume equivalent to the primary containment liquid at the maximum normal operating level as defined in API For the membrane tank system, all components of the product-containing structure, including liquid barrier, insulation system, thermal corner protection system (see ), and the outer concrete tank, shall be designed to withstand without failure an SSE event with the tank filled to the maximum normal operating level. The outer concrete tank and the thermal corner protection shall be designed to

12 withstand an ALE with a tank full to the maximum normal operating level assuming that the membrane is failed and the outer tank wall and thermal corner protection system are exposed to LNG. 15. Add a new to read as follows: The outer concrete tank analysis and design for the leak and leak plus ALE aftershock event shall take into account any damage that may have occurred to the outer concrete tank due to prior events including the SSE earthquake. The outer concrete tank shall be considered as undamaged during the prior SSE event if the following conditions are met: (1) Tensile stresses in the reinforcing steel do not exceed 90% of the reinforcing steel yield (2) Maximum concrete compressive stresses do not exceed 85% of the concrete design compressive strength. Otherwise, the prior damage shall be taken into account in the spill analysis. 16. Add new and Annex to read as follows: * Membrane containment tank systems shall be tested in accordance with EN Part 5 Table 1. The leakage test, as defined in the Note under EN Part 5 paragraph 4.1.1, shall be performed. Leakage through the membrane to the insulation space during service shall be controlled in order to maintain gas concentration level below 30% of the LEL by sweeping the insulated space with an inert gas. If the gas concentration cannot be maintained below 30% LEL, the tank shall be decommissioned and retested. For purposes of evaluating this level, the flow of purge gas within the annular space shall not be increased above the normal operating rate. A EN Part 5 Table 1 requires the outer concrete tank to be hydrostatically tested prior to installing insulation and the membrane. The membrane is leak tested after all welding is completed. A retest is required following repairs to close leaks. An insulation space monitoring system is required by EN Part 1 paragraph which is intended to identify any leaks of LNG gas or vapor into the space between the membrane and the wall. 17. Add new to read as follows: Verification of all components of the membrane containment tank system design by experimental data from model tests shall be carried out. 18. Add a new Subsection to read as follows: Additional Requirements for Membrane Containment Tank Systems A thermal corner protection system functionally equivalent to the thermal corner protection system for concrete tanks (as defined in API625 Section 6 and if required by ACI 376) shall be provided for the outer concrete tank of the membrane tank system. The thermal corner protection shall protect the

13 outer tank entire bottom and at least lower 16.5 feet (5m) of the wall from thermal shock and shall be liquid tight when it is in contact with LNG and vapor tight in all conditions. The thermal corner protection system shall be permitted to be either metallic or from nonmetallic materials compatible with LNG and shall maintain structural integrity and liquid/gas tightness under all applicable mechanical and thermal loads. The membrane containment tank system supplier shall provide tests independently witnessed and verified by a third party agency clearly demonstrating the leak tightness of all the thermal corner system under spill conditions. Historical tests shall be acceptable provided that construction processes and materials of construction are the same as those proposed. Nondestructive examination (NDE) performed on the secondary barrier and NDE acceptance criteria shall ensure that provided tightness is equivalent to the tightness provided by the metallic thermal corner protection system of the full containment tank system The outer concrete container of the membrane containment tank system shall meet all requirements of ACI376 for the secondary concrete container including materials, design, construction, inspection, and testing and the additional requirements specified below: The product liquid pressure shall be a design load for the outer concrete tank. Liquid product pressure ultimate limit state (ULS) load factors for operating and abnormal loading conditions shall be in accordance with Table 7.2 of ACI The outer concrete container wall and slab-to-wall junction shall be checked for fatigue assuming four full load-unload cycles a week for the expected life of the tank. Performance criteria of ACI376 Appendix C shall apply The outer concrete container wall shall resist the specified impact load without perforation and scabbing. A) The concrete wall thickness shall be at least 40% greater than the scabbing depth calculated per CEB 187 Section B) The concrete wall thickness shall be at least 20% greater than the perforation thickness calculated per CEB 187 Section C) The concrete wall shall be designed so that either one of the following is satisfied; 1. The distance between the outer face of the concrete container measured to the centroid of the pre-stressing tendons shall be greater than the penetration depth calculated as per CEB 187 Section with the following allowances for uncertainty; 20 % thicker than the penetration depth when z > % thicker than the penetration depth when <= The concrete wall shall be designed to be able to resist normal operating loads with any one horizontal tendon completely ineffective. D) For concrete walls post-tensioned with a wire wrapping system, the wall shall be designed to resist normal operating loads with the wires affected by a specified impact load considered completely ineffective. No unwrapping of the post-tensioning wires shall be allowed At a minimum, the outer concrete container for the membrane tank system shall meet the construction tolerances specified in ACI376. Where more stringent tolerances are required by the membrane and insulation systems, the more stringent tolerances shall be specified by the membrane tank engineer and met by the tank contractor The outer concrete container shall be hydrotested prior to membrane and insulation installation following primary container hydrotest requirements of API625 Section 10.

14 19. Revise the title of Figure (e) to read as follows: FIGURE (e) Full and Membrane Containment Container Tank Systems. 20. Revise (3) to the Atmospheric Cryogenic Tanks section of Table to read as follows: Table Example Component Failure Database Component Atmospheric Cryogenic Tanks (1) Instantaneous failure of primary container and outer shell, release of entire contents (single containment tank) (2) Instantaneous failure of primary container and outer shell, release of entire contents (double containment tank) (3) Instantaneous failure of primary and secondary container, release of entire contents (full and membrane containment tank tanks) Annual Probability of Failure 5E E-08 1E Revise B.3.4 to read as follows: B.3.4 The impounding system must, as a minimum, be designed to withstand the SSE level of loading while empty (and while full if a membrane containment tank system) and the ALE level of loading while holding the volume, V, as specified in The rationale is that should the LNG container fail following an SSE, the impounding system must remain intact and be able to contain the contents of the LNG container when subjected to an aftershock. Substantiation: In terms of technical substantiation, membrane containment system tank is a full integrity system. This means the performance of the tank system shall be similar to what is required of a full containment system: Able to store LNG and natural gas inside the tank in all normal operating conditions. Able to retain LNG and natural gas inside the tank, in all abnormal design conditions (seismic, release of the LNG to the secondary container, external & internal hazards, etc.) In order to do so, all the safety and performance requirements for a full containment shall be also applicable to membrane containment system.

15 LNG tank storage has to comply with other tank design codes. Currently, NFPA59A refers to API625 for LNG tank overall design, ACI376 for civil tank design and API620 for mechanical design. Membrane containment tank systems are fully addressed in EN14620 and partially in ACI376. Relevant references to these standards have to be made in the proposed standards. Currently, ACI376 does not fully include the membrane containment system, so additional requirements have been added to close the gap. For membrane components exclusive to the technology, the language refers to EN14620, but additional prescriptive requirements are added as agreed within the task group, in order to be more conservative for membrane tanks in a first release. Finally, all components in membrane containment tank systems which are similar to other systems (roof, suspended deck, etc.) will be referred to the same American standard. PS : The Task Group members are (in addition to the submitter) : Brian Eisentrout, CB&I/ Global Venture LNG John Blanchard, CB&I Jeff Baker, CB&I Alex Cooperman, CB&I Don Coers, Coers and Company Andrew Kohout, Federal Energy Regulatory Commission Richard Hoffmann, Hoffmann & Feige Marian Krol, Linde Engineering Keith A. Mash, Shell Emergency Nature: During March 2014 NFPA 59A meeting, public inputs were reviewed. The Public Input No. 50-NFPA 59A-2013 put alert on Membrane containment tank system, which was addressed on the Definition clause only. During the meeting, TC agreed to remove the Membrane definition. However, in order not to send the wrong signal to the LNG industry (such as the technology is not allowed), the technical committee decided to create, on an urgent basis, a subcommittee (Task Group) to prepare wording for inclusion of a full treatment of membrane containment tank for issuance as a TIA coincidentally with the 2016 version. This subcommittee has now completed its work and agreed wording is proposed as a TIA. Acceptance of this TIA on an emergency basis is consistent with the following bases as prescribed in the standard: (f) The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. In the absence of a TIA, membrane containment systems will not be in NFPA 59A 2016 edition and will be deferred until the next revision in 2018 (or 2019). From a practical standpoint, the absence of a TIA will restrict competition in an important timeframe when LNG as fuel, particularly in marine applications, is driving the development of LNG distribution and delivery systems. Proponents who are seeking options are facing a significant barrier in terms of regulatory uncertain without specific treatment of membrane tanks in NFPA 59A. Moreover, the timeframe for project development is such that developers cannot practically consider membrane alternatives without using European Norms, Canadian or other standards for references to membrane tanks. PS: This TIA is an updated version of TIA 1187, following the review of TIA 1187 ballot comments from the NFPA 59A Technical Committee and TIA 1187 public comments.

16 Shapiro, Janna From: Sent: To: Cc: Subject: Joel Madison Tuesday, August 25, :19 PM Adnan Ezzarhouni Gorham, Daniel; Shapiro, Janna RE: Membrane proposed TIA endorsment Dear Adnan, Thanks for sending the updated TIA which includes committee comments. I am in agreement with the revisions and again endorse this TIA. Best Regards, Joel Madison > From: > To: > CC: dgorham@nfpa.org; JShapiro@nfpa.org > Subject: RE: Membrane proposed TIA endorsment > Date: Tue, 25 Aug :26: > > Dear Joel, > > This attached TIA is an updated version of TIA 1187, following the review of TIA 1187 ballot comments from the NFPA 59A Technical Committee and TIA 1187 public comments. The attached file is in track change version so that you can see the updates. > You have reviewed and endorsed the initial TIA. We would appreciate your review and endorsement again on this attached updated TIA. > Thank you in advance for your kind reply. > > Very best regards, > > Adnan Ezzarhouni > > Message d'origine > De : Joel Madison > Envoyé : jeudi 30 avril :14 > À : Adnan Ezzarhouni > Cc : Gorham, Daniel > Objet : RE: Membrane proposed TIA endorsment > > Dear Adnan, > > After review of the attached document I can confirm that I will endorse the proposed change. 1

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18 As I indicated in my substantiation notes, the sole purpose of the proposed wording was To account for the fact that there are other outer concrete wall types such as the free-base wall which behave differently than a monolithically-joined wall, and which do not require a thermal corner protection system. The in-service existence of this alternative type of base joint is a significant fact that belongs in any Code provisions that involve a prestressed concrete secondary container whether those provisions pertain to double-containment, full-containment or membrane type tanks. In my opinion, the absence of any reference to this alternative type of base joint from the membrane-tank provisions of the Code might easily be interpreted that, when it comes to membrane-type LNG tanks, a free-base wall (without the necessity for a TCP) is not an option and that there is some valid reason for this exclusion. [For example, see proposed new Subsection , which makes the use of TCP mandatory] 2. With respect to the open-top versus vapor-tight membrane: In this case, too, the purpose of the proposed wording was to account for the fact that there are actual, in-service membrane-type LNG storage tanks where the primary membrane container is open at the top to the insulation space. While future application of this particular variant of membrane container might be debatable, nonetheless the industry and the profession at-large would benefit from the knowledge that this represents a viable technology. In conclusion, I believe that unless there are specific objections or reservations with respect to these or any other - proven in-service alternative container designs, their inclusion in the Code should be encouraged as it enhances the Code s mission Following are also some additional comments on select Articles of the draft TIA for the TG s consideration: [Permit me to cut-and-paste these Articles here because I find it preferable to marking the comments on the full document.] (3) Concrete shall be designed specified to avoid explosive spalling Comment: The above wording is somewhat unclear because it might be interpreted as referring to the specification for the concrete mix design only. While the concrete mix design has some influence on the control of spalling, it is the structural design of the wall itself that plays a greater role. Therefore, the following rewording might be more appropriate: (3) The concrete wall, including the wall concrete mix, shall be designed to avoid explosive spalling All the membrane system components, including insulation, primary membrane, and the secondary barrier of the thermal corner protection system (when required), shall be designed in such a way that they can withstand all possible static and dynamic actions throughout the tank lifetime 2

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