Report on Comments Copyright, NFPA NFPA 52 Report of the Committee on Vehicular Alternative Fuel Systems

Transcription

1 Report of the Committee on Vehicular Alternative Fuel Systems Staff Liaison: Carl H. Rivkin Nancy C. Pehrson, Chair CenterPoint Energy, Inc., MN [U] Ronald C. Adcock, Marsh USA Inc., AZ [I] Denise Beach, National Propane Gas Association, DC [IM] C. Everett Brett, The University of Alabama, AL [SE] Herbert F. Burnett, Burnett and Burnette, CA [SE] Eugene Bushmelov, Nuvera Fuel Cells, MA [M] William P. Chernicoff, US Department of Transportation, DC [E] Ronald R. Czischke, Underwriters Laboratories Inc., IL [RT] Steven Dallman, US Department of Transportation, OK [SE] Larry L. Fluer, Fluer, Inc., CA [IM] Rep. Compressed Gas Association George Godson, Portland Bureau of Fire, OR [E] Stan R. Gornick, Autocar, LLC & Union City Body Company, IN [M] Richard A. Hoffmann, Hoffmann & Feige, NY [SE] Douglas B. Horne, DBHorne LLC, GA [M] Rep. Clean Vehicle Education Foundation Gary W. Howard, Stuart Energy Systems, Canada [M] Thomas Joseph, Air Products and Chemicals, Inc., PA [M] James P. Lewis, Project Technical Liaison Associates, Inc., TX [SE] Michael W. Mackey, General Physics Corporation, CA [SE] Robert E. Petsinger, CNG Services International Inc., PA [IM] Gary Pope, Hughes Associates, Inc., CA [SE] Ralph Rackham, FuelMaker Corporation, Canada [M] Prentiss Searles, American Petroleum Institute, DC [M] Michael Short, UTC Power, UTC Fuel Cells, CT [M] Michael R. Swain, University of Miami, FL [U] Rep. US Department of Energy Alternates Committee Scope: This Committee shall have primary responsibility for documents on fire and explosion hazards associated with compressed natural gas (CNG), liquefied natural gas (LNG) engine fuel systems, compressed hydrogen gas (GH2) engine fuel systems, and liquefied hydrogen gas (LH2) engine fuel systems on vehicles of all types and for refueling stations and associated storage. The Committee shall coordinate its documents with the Committee on the National Fuel Gas Code with respect to natural gas piping within the scope of that Committee; with the Committees on Industrial Trucks, Fire Safety for Recreational Vehicles, and Marine Fire Protection with respect to engine fuel systems and refueling stations within their scopes; and with the Liquefied Natural Gas Committee with respect to storage of LNG within its scope. 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. This portion of the Technical Committee Report of the Committee on Vehicular Alternative Fuel Systems is presented for adoption. This Report on Comments was prepared by the Technical Committee on Vehicular Alternative Fuel Systems, and documents its action on the comments received on its Report on Proposals on NFPA 52, Compressed Natural Gas (CNG) Vehicular Fuel Systems Code, 2002 edition, as published in the Report on Proposals for the 2005 June Meeting. This Report on Comments has been submitted to letter ballot of the Technical Committee on Vehicular Alternative Fuel Systems, which consists of 24 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report. Mervin E. Bohrer, Jr., Bauer Compressors, Inc., VA [M] (Alt. to Ralph Rackham) Thomas J. Forsythe, Hughes Associates, Inc., CA [SE] (Alt. to Gary Pope) Henry E. Seiff, Natural Gas Vehicle Coalition, DC [M] (Alt. to Douglas B. Horne) Roger A. Smith, Compressed Gas Association, Inc., VA [IM] (Alt. to Larry L. Fluer) Robert A. Zeman, Underwriters Laboratories Inc., IL [RT] (Alt. to Ronald R. Czischke) 52-1

2 in Part 52-1 Log #480 Final Action: Reject Revise text to read as follows: (Title) This code shall apply to the design and installation of compressed natural Vehicular Fuel Systems Code Natural Gas and Hydrogen Vehicular Fuel Systems Code SUBSTANTIATION: The title in the ROP is too broad. It gives the impression that NFPA 52 covers all fuels, which is incorrect. COMMITTEE STATEMENT: Does not cover full scope of document which addresses all gaseous and liquefied gas fuels. gas (CNG) and liquefied natural gas (LNG) engine fuel systems on vehicles of all types and for refueling stations and associated storage, including the following: (1) Original equipment manufacturers (2) Vehicle converters and integrators. COMMITTEE STATEMENT: See Committee Action on 52-6 (Log #319). FLUER: The several days time provided after receipt of this extensive ballot of over 800 comments, and the time necessary for its processing, was not adequate to allow for further response by the members and participants of the Compressed Gas Association (CGA). With the exception of the sixteen items referenced above which have been voted, and supported with technical comments as required, CGA is abstaining from voting on all other comments Log #366 Final Action: Reject (1.1) SUBMITTER: Tom Chrisfield, Northstar, Inc. RECOMMENDATION: Move Section after Delete Section SUBSTANTIATION: The order would then be CNG & LNG systems, followed by CNG exemptions, then LNG exemptions. Section is redundant to Section COMMITTEE STATEMENT: is needed because it is not redundant Log #813 Final Action: Accept in Part (1.1) SUBMITTER: Gary Pope, Hughes Associates, Inc This code shall apply to the design and installation of compressed natural gas (CNG) and liquefied natural gas (LNG) engine fuel systems on vehicles of all types and for refueling stations and associated storage, including the following: (1) Original equipment manufacturers (2) Vehicle converters and integrators Automobiles that are required to comply with applicable federal motor vehicle safety standards covering the installation of LNG fuel systems on automobiles and that are certified by the OEM manufacturer as meeting these standards shall not be required to comply with Chapter 11, except Unless otherwise specified, the provisions of this code are not intended to require upgrading facilities, equipment, structures, or installations that existed or were approved for construction or installation prior to the effective date of the code.up-grading installations or repairs shall meet the provisions of this code. Where specified, the provisions of this code shall be retroactive. Designated by representative symbol # Advancements in technology and improvements in system design and equipment can result in equipment fabrication methods, component design requirements, and installation and operating practices that differ from those specified in this code. The most current edition of documents specified within this document s requirements shall apply at the date of manufacture or installation. SUBSTANTIATION: integrators are responsible for whole systems approach and converters may only deal with an engine Vehicles is too broad and may incorporate trucks and buses, etc. (OEM certification assures that vehicle will meet all present day standards, etc) Designated by # Text needs to clearly point out items for immediate change Safety is a key consideration and there needs to be a designation Specified documents should always be the most current in order to take advantage of new technology-safety Log #365 Final Action: Reject (1.1 (New) ) SUBMITTER: Tom Chrisfield, Northstar, Inc. RECOMMENDATION: Add new text as follows: This code is intended to apply to vehicular-related uses of natural gas, hydrogen, and propane as listed below: SUBSTANTIATION: Introduces the material of Chapter 1. COMMITTEE STATEMENT: Existing text more clearly states the applicability Log #200 Final Action: Accept (1.1.1) SUBMITTER: Nancy C. Pehrson, Center Point Energy RECOMMENDATION: This code shall apply to the design, and installation, operation and maintenance of compressed natural gas (CNG) and liquefied natural gas (LNG) engine fuel systems on vehicles of all types and for vehicle re fueling (dispensing) systems stations and associated storage... SUBSTANTIATION: Sections 6.13, 8.14, 8.16, 12.13, cover operation or maintenance. Also includes operation and maintenance as part of scope. Inclusion will standardize text and minimize confusion. Refueling station or vehicle fueling/dispensing system should be referenced in a similar manner independent of fuel type Log #319 Final Action: Accept (1.1.1) SUBMITTER: Dick Kauling, General motors Corporation This code shall apply to the design and installation of compressed...including the following: (2) Vehicle converters ( 2) Final-Stage Vehicle Integrator/Manufactuer (FSVIM) SUBSTANTIATION: Provides consistency with Section which uses the term FSVIM for CNG engine fuel systems. (unless there is some defined distinction between a vehicle converter and a FSVIM).

3 52-7 Log #481 Final Action: Accept (1.1.1) RECOMMENDATION: Change the word refueling to fueling. SUBSTANTIATION: Use the word fueling rather then refueling for consistency throughout the document. For example, uses fueling Log #286 Final Action: Reject (1.1.2) SUBMITTER: Mark Richards, Gas Technology Institute Add Sections 4.3 and 4.5 and delete Chapter 5 exceptions. SUBSTANTIATION: Section 4.3 exempts FMVSS compliant vehicles. Add 4.5 because containers and PRDs are tested as a set. Chapter 5 exceptions don t exist. COMMITTEE STATEMENT: Document is clear in its current form. This change would not clarify applicability any more Log #482 Final Action: Reject (1.1.2) RECOMMENDATION: Delete the entire subsection. SUBSTANTIATION: As a general rule, if NFPA 52 s requirements are valid, they should be valid for all systems covered, not just those not built to FMVSS. Specifically, I don t believe the FMVSS covers the installation of CNG fuel systems. In any case, the exemption to section 4.8 is irrelevant, since that section requires compliance with FMVSS 304 which is required in any case. Systems should not be exempt from (fuel lines) since it provides safety requirements not in FMVSS. Chapter 5 concerns gaseous H2 so it is irrelevant to which concerns only vehicles built to CNG FMVSS. Therefore, since none of the exemptions are appropriate, the entire subsection should be stricken. COMMITTEE STATEMENT: Need to not conflict with federal regulations Log #26 Final Action: Accept (1.1.3) SUBMITTER: Gary W. Howard, Stuart Energy Systems COMMENT ON PROPOSAL NO: 52-1 RECOMMENDATION: Add at the end of sentence:...and facilities. SUBSTANTIATION: The statement only mentions dispensing but the code covers facilities for refueling Log #157 Final Action: Accept (1.1.3) SUBMITTER: Jesse Schneider, DaimlerChrysler Corporation This code shall apply to the design and installation of compressed hydrogen (GH2) and liquefied compressed hydrogen (LH2) vehicle fueling (dispensing) systems and engine fuel systems. SUBSTANTIATION: 1. Deletion of compressed is a clarification consistent with common language usage. 2. GH2 and LH2 fueled vehicles will be governed by US DOT FMVSS regulations for national consistency in vehicle use and operation. GH2 and LH2 vehicles are not being developed for use primarily limited to local fleets (unlike H/CNG blends for buses or alternate fuels purchased for fleet compliance with legislation). 3. Inclusion of deleted wording would have extended the purview of this document to include onboard hydrogen fueling systems for vehicles. These fueling systems are in early stages of development by vehicle manufacturers and will not become available to the general public for several years, which could amount to several code cycles. It is premature to include wording in this document that may inhibit advances to these developing systems. OEM engine designs are not regulated locally, vary as technology evolves, and are the purview of US DOT and UN ECE Log #201 Final Action: Accept (1.1.3) SUBMITTER: Nancy C. Pehrson, Center Point Energy This code shall apply to the design and installation, operation and maintenance of compressed hydrogen (GH2) and liquefied hydrogen (LGH2) vehicle (fueling dispensing) systems. SUBSTANTIATION: Sections 7.4, 9.13 and cover operation and maintenance includes operation and maintenance. Inclusion will minimize confusion as to scope Log #320 Final Action: Accept (1.1.3) SUBMITTER: Dick Kauling, General motors Corporation This code shall apply to the design and installation of compressed hydrogen (GH2) or and liquefied compressed hydrogen (LGH2) or blends of hydrogen up to 20 percent with the balance natural gas (NG) vehicle fueling (dispensing) systems. SUBSTANTIATION: There is no need to identify liquefied hydrogen as compressed. Wording change is consistent with next section While GM believes that the delivery of blended fuels might be a potential requirement, there is no intent at this time to be capable of blending hydrogen and CNG on board the vehicle.

4 52-14 Log #331 Final Action: Accept in Principle (1.1.3) SUBMITTER: Mike Steele, General Motors Corporation This code shall apply to the design and installation of compressed hydrogen (GH2) and liquefied compressed hydrogen (LH2) vehicle fueling (dispensing) systems and engine fuel systems Log #390 (1.1.3) Final Action: Accept in Principle SUBSTANTIATION: 1. Deletion of compressed is a clarification consistent with common language usage. 2. GH2 and LH2 fueled vehicles will be governed by US DOT FMVSS regulations so that vehicles will comply with regulatory requirements on a national basis to enable unimpeded movement across state and county lines. NFPA codes, when adopted by regional government agencies acquire force of law, so would effectively create differing vehicle regulations within the US and thereby impede transportation. Federal regulatory authorities, unlike local and regional officials, are equipped and funded to formally permit the hundreds of new vehicle types introduced into the US market each year. Requirements to permit new vehicles separately in individual states and counties would impose burdens on manufacturers that would likely result in all vehicles not being offered for sale in low volume markets within the US - a consequence that is not in the public interest for rural communities. These circumstances apply to vehicles aimed at the general public, as opposed to localized fleet applications that would likely be restricted to local regions. Hence, these circumstances apply strongly to gasoline-fueled vehicles and hydrogen-fueled vehicles - hydrogen-fueled vehicles are being developed for passenger transportation and large volumes to impact national use of foreign oil. Thus, gasoline and hydrogen fueled vehicles are appropriately regulated by US DOT with correspondence, where appropriate, to standards of Standard Developing Organizations (like SAE) that are not subject to being adopted by local government agencies and thereby not subject to being drawn into differing local legal requirements. This is a significant distinction from H/CNG blends for buses or alternate fuels purchased for local fleet applications. 3. Inclusion of deleted wording would have extended the purview of this document to include onboard hydrogen fueling systems for vehicles. These fueling systems are in early stages of development by vehicle manufacturers and will not become available to the general public for several years, which could amount to several code cycles. It is premature to include wording in this document that may inhibit advances to these developing systems. OEM engine designs are not regulated locally, vary yearly as technology evolves, and are the SUBMITTER: Ben Knight, Honda R&D Americas, Inc. This code shall apply to the design and installation of compressed hydrogen (GH2) and liquefied compressed hydrogen (LH2) vehicle fueling (dispensing) systems and engine fuel systems. SUBSTANTIATION: 1. Deletion of compressed is a clarification consistent with common language usage. 2. GH2 and LH2 fueled vehicles will be governed by US DOT FMVSS regulations for national consistency in vehicle use and operation. GH2 and LH2 vehicles are not being developed for use primarily limited to local fleets (unlike H/CNG blends for buses or alternate fuels purchased for fleet compliance with legislation). 3. Inclusion of deleted wording would have extended the purview of this document to include onboard hydrogen fueling systems for vehicles. These fueling systems are in early stages of development by vehicle manufacturers and will not become available to the general public for several years, which could amount to several code changes. It is premature to include wording in this document that may inhibit advances to these developing systems. OEM engine designs are not regulated locally, vary as technology evolves, and are the purview of US DOT and UN ECE. in Principle The Committee Action in (Log #157) addresses the intent of the comment. COMMITTEE STATEMENT: See Committee Action on (Log #157). purview of US DOT and UN ECE. in Principle This code shall apply to the design and installation of compressed hydrogen (GH2) and liquefied compressed hydrogen (LH2) vehicle fueling (dispensing) systems and engine fuel systems. COMMITTEE STATEMENT: See Committee Statement on (Log #157) Log #354 Final Action: Reject (1.1.3) SUBMITTER: Sheral Arbuckle, Ford Motor Company This code shall apply to the design and installation of compressed hydrogen (GH2) and liquefied hydrogen (LH2) vehicle fueling (dispensing) systems and engine fuel systems. SUBSTANTIATION: 1. Deletion of compressed is a clarification consistent with common language usage. 2. GH2 and LH2 fueled vehicles will be governed by US DOT FMVSS regulations for national consistency in vehicle use and operation. GH2 and LH2 vehicles are not being developed for use primarily limited to local fleets (unlike H/CNG blends for buses or alternate fuels purchased for fleet compliance with legislation). 3. Inclusion of deleted wording would have extended the purview of this document to include onboard hydrogen fueling systems for vehicles. These fueling systems are in early stages of development by vehicle manufacturers and will not become available to the general public for several years, which could amount to several code changes. It is premature to include wording in this document that may inhibit advances to these developing systems. OEM engine designs are not regulated locally, vary as technology evolves, and are the purview of US DOT and UN ECE. COMMITTEE STATEMENT: Text shown as deleted in comment does not appear in draft Log #410 Final Action: Accept in Principle (1.1.3) SUBMITTER: Michael Short, UTC Power/UTC Fuel Cells This code shall apply to the design and installation of compressed hydrogen (GH2) and liquefied compressed hydrogen (LH2) vehicle fueling (dispensing) systems and engine fuel systems. SUBSTANTIATION: a. Editorial deletion of compressed as it is implied with liquid systems. b. Designs of hydrogen fuel cells and other onboard hydrogen systems are not regulated by local authorities and are the regulated by US DOT. in Principle See Committee Action on (Log #157). COMMITTEE STATEMENT: See Committee Action on (Log #157) Log #483 Final Action: Accept in Part (1.1.3) RECOMMENDATION: Revise text as follows GH 2 CH 2 liquidified compressed hydrogen liquefied hydrogen LGH 2 LH 2 SUBSTANTIATION: CH 2 is more appropriate than GH 2 and is parallel to CNG liquefied compressed hydrogen is confusing and incorrect. You don t take compressed hydrogen and then liquefy it, you just liquefy it. LH 2 is more appropriate than LGH 2 and is parallel to LNG. in Part... liquidified compressed hydrogen liquefied hydrogen LGH 2 LH 2. COMMITTEE STATEMENT: The first part of the comment does not show

5 a change Log #752 Final Action: Accept in Principle (1.1.3) SUBMITTER: Brad Smith, Shell Hydrogen (U.S) This code shall apply to the design and installation of compressed gaseous hydrogen (GH2) and liquefied compressed hydrogen (L G H2) vehicle fueling (dispensing) systems. SUBSTANTIATION: Compressed is not necessary nor appropriate in this sentence. in Principle See Committee Action on (Log #437). COMMITTEE STATEMENT: See Committee Statement on (Log #437) Log #251 Final Action: Reject (1.1.3 and 1.1.4) SUBMITTER: Anthony Estrada, Pacific Gas & Electric Company RECOMMENDATION: Under Chaper 1, paragraphs 1.1.3, 1.4 and on Chapter 3 (Definitions), paragraph there is the reference to LGH2 as lquefied compressed hydrogen. However, in the rest of the document (including Chapter 13 and1. 14) the term LH2 is used extensively. Are the terms LGH2 and LH2 intended to mean the same? SUBSTANTIATION: There will be consistency of terms in the document if the problem is resolved. COMMITTEE STATEMENT: These terms are defined in Chapter 3 and used consistently Log #4 Final Action: Reject (1.1.4) SUBMITTER: Herbert F. Burnett, Burnett and Burnette RECOMMENDATION: Recommend increasing the fill pressure for GH2 to 5000 psig. SUBSTANTIATION: Hydrogen vehicles are being operated at fill pressures of 5000 psi. There are already over 10 H2 stations filling at this pressure. If the cylinder or container manufacturers have a certified cylinder to 5000 psi then the fueling station should be designed for this pressure. COMMITTEE STATEMENT: This section applies to mixtures and the current pressure is sufficient for mixtures Log #27 Final Action: Reject (1.1.4) SUBMITTER: Gary W. Howard, Stuart Energy Systems COMMENT ON PROPOSAL NO: 52-1 RECOMMENDATION: Change 20 to 30 percent. SUBSTANTIATION: Experiments are being run with up to 30 percent H2 in CNG buses COMMITTEE STATEMENT: The fact that 30 percent hydrogen is being used in experiments is not a basis for changing the mixture ratio to 30 percent Log #62 Final Action: Reject (1.1.4) This code shall apply to the design and installation of GH 2 and LGH 2 engine fuel vehicle fueling (dispensing) systems up to 3600 psi (25 mpa) on for vehicles operating on mixtures of GH 2 up to 20 between 16.4 and 49.5 percent with the balance natural gas (NG). SUBSTANTIATION: 16.4 and 49.5 added so that Code covers all recognized mixtures or blends of H2 and CNG. Blends less than 16.4% should be treated as CNG (Group D) per NFPA 70, section Material Groups, 16.5 to 49.5% should be treated as blends (Group C), and 49.5 percent should be treated as pure H2. The reference to the engine fuel system is suggested to be removed in order to eliminate it from the scope of this document. COMMITTEE STATEMENT: These blends would be outside of the scope of the current document. As more is known about the behavior of these blends they may be incorporated into subsequent editions Log #158 Final Action: Reject (1.1.4) SUBMITTER: Jesse Schneider, DaimlerChrysler Corporation This code shall apply to the design and installation of GH2 and LGH2 of dispensing systems and engine fuel systems up to 3600 psi (25 MPA) on for vehicles operating on mixtures of GH2 up to 20 percent with the balance natural gas (NG). SUBSTANTIATION: 1. GH2 and LH2 fueled vehicles will be governed by US DOT FMVSS regulations for national consistency in vehicle use and operation. Unlike blend CNG/H buses intended for local use, GH2 and LH2 vehicles are aimed at national driving governed by US DOT. 2. Inclusion of deleted wording would extend the purview of this document to include onboard hydrogen fueling systems for vehicles using ICEs or fuel cells. These fueling systems are in early stages of development by vehicle manufacturers and will not become available to the general public for several years, which could amount to several code cycles. It is premature to include wording in this document that may inhibit advances to these developing systems. 3. Statements contained in paragraph 1.4, Alternate Provisions, do not specify that vehicles certified for on road use by US DOT are automatically compliant with this code. COMMITTEE STATEMENT: This text does not improve the current text Log #287 Final Action: Accept (1.1.4) SUBMITTER: Mark Richards, Gas Technology Institute Delete and LGH2 Editorial: Change mpa to MPa General comment. Where is the blends Chapter? There are only CNG and H2 Chapters. Why is there a vehicular H2 chapter when only blends are covered?

6 SUBSTANTIATION: Delete LGH2 unless the intent is either to cover onboard mixing of vaporized LH2 and CNG or to cover cryogenic blends. EXPLANATION OF NEGATIVE: CHERNICOFF: Disagree that the language is not enforceable. SHORT: I am voting negative on this committee action because the idea of extending NFPA requirements to the vehicle may create confusion and issues of enforceability Log #332 Final Action: Accept in Principle (1.1.4) SUBMITTER: Mike Steele, General Motors Corporation This code shall apply to the design and installation of GH2 and LGH2 of dispensing systems and engine fuel systems up to 3600 psi (25 MPA) on for vehicles operating on mixtures of GH2 up to 20 percent with the balance natural gas (NG). SUBSTANTIATION: 1. GH2 and LH2 fueled vehicles will be governed by US DOT FMVSS regulations for national consistency in vehicle use and operation. Unlike blend CNG/H buses intended for local use, GH2 and LH2 vehicles are aimed at national driving governed by US DOT. 2. Inclusion of deleted wording would extend the purview of this document to include onboard hydrogen fueling systems for vehicles using ICEs or fuel cells. These fueling systems are in early stages of development by vehicle manufacturers and will not become available to the general public for several years, which could amount to several code cycles. It is premature to include wording in this document that may inhibit advances to these developing systems. in Principle Revise text to read as follows: This code shall apply to the design and installation of GH2 and LGH2 engine fuel systems up to 3600 psi (25 MPA) on for vehicles operating on mixtures of GH2 up to 20 percent with the balance natural gas (NG). COMMITTEE STATEMENT: This makes it clear that this section applies to blends Log #395 Final Action: Reject (1.1.4) SUBMITTER: Michael Short, UTC Power/UTC Fuel Cells This code shall apply to the design and installation of GH2 and LGH2 engine fuel systems up to 3600 psi (25 MPA) on vehicles operating on mixtures of GH2 up to 20 percent with the balance natural gas (NG). This code shall not apply to GH2 and LH2 engine fuel systems on board vehicles that meet appropriate product standards and recommended practices. The vehicle shall meet FMVSSs when applicable or the following when FMVSSs are not applicable or available: 1) All equipment operating at tank pressure including the tank, PRD, fuel receptacle, and valves are listed for the intended service. 2) Tanks are protected by an approved PRD that is installed per tank manufacturer s instruction. 3) The vehicle uses either fuel with odorant or has leak detection. 4) The tank system has a normally-closed shutoff that can either be activated automatically when leaks are detected or by driver command (or both). SUBSTANTIATION: a. US DOT regulates the designs of onboard vehicular hydrogen systems and are not within the scope of local authorities. b. The components in the high pressure fuel sections up to and including the first stage fuel regulator are listed components, to standards such as NGV2, HPRD, etc. c. Inclusion of deleted wording would extend the scope of this document to include onboard hydrogen fueling systems for vehicles. Developments by vehicle manufacturers include technologies that will increase stored pressures beyond 25 MPa. Further, the deleted text did not specify maximum hydrogen content in terms of volume or mass concentration, which may be interpreted as an extension of the scope of the document. It is premature to include wording in this document that may inhibit advances to these developing systems. d. Statements contained in Paragraph 1.4, Alternate Provisions, do not specify that vehicles meeting FMVSS are exempt from this standard. COMMITTEE STATEMENT: The recommendation is not enforceable. BALLOT RESULTS: Affirmative: 15 Negative: 2 Abstain: Log #484 Final Action: Reject (1.1.4) RECOMMENDATION: Add: using hydrogen stored at between systems and up. SUBSTANTIATION: The revision provides clarification of present wording. As it stands one might assume that the low-pressure part of a system (which is below 3600 psi) would be covered even though the tank was at 700 bar. COMMITTEE STATEMENT: The low pressure portion of the system is covered Log #743 Final Action: Reject (1.1.4) SUBMITTER: Kevin Brandner, HyRadix This code shall apply to the design and installation of GH2 and LGH2 engine fuel systems up to 3600 psi (25 mpa) on vehicles operating on mixtures of GH2 up to percent with the balance natural gas (NG). SUBSTANTIATION: As currently written, the code would not apply to most fuel cell vehicles. COMMITTEE STATEMENT: The current text states the requirements do not apply to mixtures of hydrogen above 20%. They are not prohibited but simply outside of the scope of the document. As more becomes known about these mixtures the scope statement that addresses mixtures and applicable requirements can be updated Log #CC8 Final Action: Accept (1.1.4) SUBMITTER: Technical Committee on Vehicular Alternative Fuel Systems RECOMMENDATION: Add the following sentence: These blends shall be treated as CNG. SUBSTANTIATION: Without this statement it is not clear which requirements apply Log #244 Final Action: Reject (1.1.4 and 1.1.5) SUBMITTER: Neal Mulligan, Collier Technologies, Inc. RECOMMENDATION: This code shall apply to the design and installation of engine fuel systems up to 3600 psi (25 mpa) on vehicles operating on mixtures of (HCNG) GH 2 and no more than 32 percent with the balance natural gas (NG).

7 SUBSTANTIATION: The draft version of NFPA 52 Vehicular fuel System Code, 2005 edition, did not address HCNG as a motor fuel. HCNG is a blend of hydrogen and natural gas that is stored in the same container. COMMITTEE STATEMENT: The scope statement covers the current technology. Mixtures outside of the range in are outside of the scope of the document but not prohibited by the document Log #485 Final Action: Reject (1.1.5) RECOMMENDATION: Delete this section and add the last phrase ( and to...) to In the last phase, add (LCNG) or (L/CNG) after LNG to CNG. SUBSTANTIATION: Most of this subsection seems to be redundant and somewhat confusing. For clarity, add (LCNG) or (L/CNG). COMMITTEE STATEMENT: This section is specific to LNG Log #435 Final Action: Reject ( (New) ) SUBMITTER: Larry Fluer, Fluer, Inc. RECOMMENDATION: Add new text as follows: This code shall include marine, highway, rail, off-road, and industrial vehicles Vehicles regulated by the US Department of Transportation (DOT) shall not be required to comply with this code. SUBSTANTIATION: The regulations of the US Department of Transportation under 49 CFR establish the requirements for the design of containers and container delivery systems where transportation is involved. The Federal regulations for design of containers and vehicles engaged in transportation of hazardous materials in commerce are preemptive. In addition, the National Highway Transportation Act (NHTSA) addresses design of vehicle components such as window glass, fuel tanks, tires, etc. NFPA involvement in areas regulated by the Department of Transportation will result in conflicts between the Federal regulations and the code that will result in confusion and issues of enforceability. NFPA must avoid the establishment of any requirements affecting commerce in the act of transporting dangerous goods or the design of vehicle components where the authority rests with the DOT. COMMITTEE STATEMENT: These vehicles may have to comply with parts of this document. BALLOT RESULTS: Affirmative: 13 Negative: 4 Abstain: 1 EXPLANATION OF NEGATIVE: CHERNICOFF: The committee explanation seems to indicate it is acceptable to conflict with or supercede Federal regulations. This is not true HOWARD: The committee explanation seems to indicate it is acceptable to conflict with or supercede Federal regulations. This is not true. JOSEPH: TAVFS shall accept the proposal as submitted to avoid conflicts with federal regulations. SHORT: I am voting negative on this committee action because the rejected text may result in conflicts between the federal regulations and the code that will result in confusion and issues of enforceability. The regulations of the US Department of Transportation under 49 CFR establish the requirements for the design of containers and container delivery systems where transportation is involved. The committee explanation seems to indicate it is acceptable to conflict with Federal regulations Log #486 Final Action: Reject (1.1.7) RECOMMENDATION: Delete this subsection. SUBSTANTIATION: I don t believe there are any FMVSS covering the installation of LNG fuel systems so it is unnecessary to consider any exemptions for vehicles meeting them. In addition, if NFPA 52 contains relevant safety requirements, it would not be appropriate to exempt any vehicles from following 52. COMMITTEE STATEMENT: Although there may not be FMVSS requirements, they may be developed which would prevent conflicting requirements Log #CC5 Final Action: Accept (1.1.8) SUBMITTER: Technical Committee on Vehicular Alternative Fuel Systems RECOMMENDATION: This code shall apply to testing, service, and maintenance of GH2 engine fuel systems. SUBSTANTIATION: This makes the engine fuel system s applicability clear Log #370 Final Action: Reject (1.2) SUBMITTER: Tom Chrisfield, Northstar, Inc. RECOMMENDATION: Purpose: (Reserved) - no suggestion. SUBSTANTIATION: With all due respect, it would seem crucial to the success of this document that a clear purpose be stated, analogous to a mission statement. This should be generated and agreed on by the committee. COMMITTEE STATEMENT: No specific recommendation was given Log #333 Final Action: Accept in Principle (1.4) SUBMITTER: Mike Steele, General Motors Corporation Vehicles certified for on-road use by the US DOT are compliant with this code at the point in time of original manufacture. SUBSTANTIATION: 1. US DOT has responsibility and federal authority to set national safety requirements for on-road vehicles and thereby enable national consistency for interstate transportation. (Correspondingly UN ECE will govern vehicles in signature countries). 2. Statements contained in Paragraph 1.4, Alternate Provisions, do not specify that vehicles certified for on-road use by US DOT are automatically compliant with this code. 3. Statements contained in Paragraph 1.4, Alternate Provisions, do not adequately specify a process whereby any advancements in technology and improvements in systems design and equipment (1.4.1) can be demonstrated to authorities having jurisdiction. Conduct of a special investigation of all factors ( ) is ambiguous. AHJs do not have expertise to evaluate thousands of passenger vehicle types for sale each year county by county in the USA or elsewhere 4. Substantiation for the suggested revision to Section applies to this suggested revision - refer to that text.

8 in Principle Vehicles compliant with USDOT (FMVSS) 303 and 304 for on-road use are compliant with this code at the point in time of original manufacture. COMMITTEE STATEMENT: The revised text identifies the FMVSS requirements. BALLOT RESULTS: Affirmative: 14 Negative: 3 Abstain: 1 EXPLANATION OF NEGATIVE: The Committee Action in (Log #333) addresses the intent of the comment. COMMITTEE STATEMENT: See Committee Statement on (Log #333). CZISCHKE: I agree with the rationale presented by the earlier commentors. HOWARD: The FMVSS 303 and 304 are CNG codes and as such can not be included in this definition. The definition should read Vehicles compliant with applicable US DOT (FMVSS) 303 and 304 requirements for on-road use Log #288 (1.4.2) Final Action: Reject are compliant with this code at the point in time of original manufacture. SEARLES: I agree with Mr. Howard s reasons. COMMENT ON AFFIRMATIVE CHERNICOFF: Editorial Error => FMVSS 303 and 304 are CNG codes and as such can not be included in this definition (hydrogen). The definition should read Vehicles compliant with applicable US DOT FMVSS and other r303 and 304 requirements for on-road use are compliant with this code at the point in time of original manufacture. JOSEPH: FMVSS 303 & 304 are CNG codes and so shall be replaced with more generic wording. PETSINGER: I agree with Mr. Howard s comment. SUBMITTER: Mark Richards, Gas Technology Institute RECOMMENDATION: Delete the paragraph. SUBSTANTIATION: Without specific guidelines for determining competence, this paragraph should be deleted. COMMITTEE STATEMENT: The AHJ will make the competence determination. BALLOT RESULTS: Affirmative: 16 Negative: 1 Abstain: 1 EXPLANATION OF NEGATIVE: Log #159 Final Action: Accept in Principle CHERNICOFF: It seems reasonable and appropriate to provide guidance or (1.4 Alternate Provisions) SUBMITTER: Jesse Schneider, DaimlerChrysler Corporation requirements for competence. RECOMMENDATION: Add new text as follows: Vehicles certified for on-road use by the US DOT are compliant with this code at the point in time of original manufacture Log #427 (1.4.2) Final Action: Reject SUBSTANTIATION: 1. US DOT has responsibility and federal authority to set national safety requirements for on-road vehicles and thereby enable national consistency for interstate transportation. (Correspondingly UN ECE will govern vehicles in signature countries) 2. Statements contained in Paragraph 1.4, Alternate Provisions, do not specify that vehicles certified for on-road use by US DOT are automatically compliant with this code. 3. Statements contained in Paragraph 1.4, Alternate Provisions, do not adequately specify a process whereby any advancements in technology and improvements in system design and equipment (1.4.1) can be demonstrated to authorities having jurisdiction. Conduct of a special investigation of all factors ( ) is ambiguous. AHJs do not have expertise to evaluate thousands of passenger vehicle types for sale each year county by county in the USA or elsewhere. in Principle See Committee Action on (Log #333). COMMITTEE STATEMENT: See Committee Statement on 52-37(Log #333). SUBMITTER: Michael Short, UTC Power/UTC Fuel Cells RECOMMENDATION: Delete the following text: Designers, fabricators, and construction of LNG and LGH2 LH2 fueling facilities shall be competent and have expertise in the design, fabrication, and construction of LNG and LGH2 LH2 containers, cryogenic equipment, loading and unloading systems, fire protection equipment, detection, siting, containment, piping systems, and other components of the facility. SUBSTANTIATION: a. The term LGH2 is erroneous. This requirement appears only in NFPA and therefore should not be extended to nonliquefied fuels. b. The original text specifies that designers, fabricators, and constructors of LNG and LH2 fueling facilities be competent and have expertise. These terms are subjective and therefore may be used as unfair technology barrier that adds costs without substantial safety benefit by creating mandatory third party review situations. There is no exception noted for listed equipment evaluated by an independent testing house. COMMITTEE STATEMENT: The AHJ will determine competence and expertise Log #389 Final Action: Accept in Principle (1.4 Alternate Provisions) SUBMITTER: Ben Knight, Honda R&D Americas, Inc. RECOMMENDATION: Add new text as follows: Vehicles certified for on-road use by the US DOT are compliant with this code at the point in time of original manufacture. SUBSTANTIATION: 1. US DOT has responsibility and federal authority to set national safety requirements for on-road vehicles and thereby enable national consistency for interstate transportation. (Correspondingly UN ECE will govern vehicles in signature countries) 2. Statements contained in Paragraph 1.4, Alternate Provisions, do not specify that vehicles certified for on-road use by US DOT are automatically compliant with this code. 3. Statements contained in Paragraph 1.4, Alternate Provisions, do not adequately specify a process whereby any advancements in technology and improvements in system design and equipment (1.4.1) can be demonstrated to authorities having jurisdiction. Conduct of a special investigation of all factors ( ) is ambiguous. AHJs do not have expertise to evaluate thousands of passenger vehicle types for sale each year county by county in the USA or elsewhere. in Principle Log #487 Final Action: Reject (1.4.2) RECOMMENDATION: Delete LNG and LGH 2 both times they are used. SUBSTANTIATION: By only mentioning those two fuels we infer that designers, fabricators and constructors of other fuels need not be competent and have expertise... COMMITTEE STATEMENT: The requirement is specific to cryogenic systems. There are several other parts of the document that call for expertise dealing with the specific application.

9 installations shall be permitted to use alternate site distances, operating Log #371 Final Action: Reject requirements, and equipment locations with validation by licensed qualified (1.4.2, and 1.4.5(6)) SUBMITTER: Tom Chrisfield, Northstar, Inc. RECOMMENDATION: Delete have expertise and proven expertise. SUBSTANTIATION: These phrases are too subjective. What agency becomes responsible for a determination that Engineer A has proven expertise and Engineer B does not? COMMITTEE STATEMENT: The AHJ determines whether someone has expertise. engineer(s) with proven expertise in mechanical systems, electrical systems, gaseous storage systems, cryogenic storage systems, fire protection, and gas detection. SUBSTANTIATION: Licensing is not within the norm for industrial gas system design; practical experience and education is of equivalent value to that of a PE license. Section establishes the basis for competency Log #409 Final Action: Accept (1.4.3) SUBMITTER: Michael Short, UTC Power/UTC Fuel Cells Supervision shall be provided for the fabrication, construction, and acceptable tests of facility components to the extent necessary to ensure that facilities are sound, suitable for the service, and otherwise in compliance with this code. The installation of GH2, LNG and LH2 systems shall be supervised by personnel familiar with proper practices with reference to their construction and use. SUBSTANTIATION: a. The deleted text in specifies the use of supervision as means of assurance of soundness of the facility design and construction, and compliance to the code. This approach is subjective and therefore may be used as unfair technology barrier that adds costs without substantial safety benefit. The revised text is consistent with 29CFR for hydrogen systems and adds LNG as previously prescribed in NFPA Log #431 Final Action: Reject (1.4.4) SUBMITTER: Michael Short, UTC Power/UTC Fuel Cells LNG, L/CNG, CNG, hydrogen GH2 and other gaseous/cryogenic LH2 installations shall be permitted to use alternate siting distances, operating requirements, and equipment locations with validation by licensed engineer(s). with proven expertise in mechanical systems, electrical systems, gaseous storage systems, cryogenic storage systems, fire protection, and gas detection. SUBSTANTIATION: a. Editorial change hydrogen to GH2 for consistency in the document. b. Other gaseous/cryogenic installations are not within the scope of this document, however LH2 is within the scope. c. The deleted text uses the term proven expertise. This term is subjective and therefore may be used as unfair technology barrier that adds costs without substantial safety benefit. COMMITTEE STATEMENT: Specifying the areas of expertise will make it easier to determine whether an individual is qualified Log #436 Final Action: Accept (1.4.4) SUBMITTER: Larry Fluer, Fluer, Inc. RECOMMENDATION: Revise text to read as follow: LNG, L/CNG, CNG, hydrogen, and other gaseous/cryogenic Log #772 Final Action: Accept (1.4.4) SUBMITTER: Stan Sinclair, Southern California Gas Company Qualified licensed engineer(s). SUBSTANTIATION: There are several qualified engineers who have been doing similar work for years. By requiring a licensed engineer, project cost will be increased, and projects will be delayed, because of scarcity of qualified registered engineers in the specific field Log #289 Final Action: Accept (1.4.5) SUBMITTER: Mark Richards, Gas Technology Institute Change the number from to SUBSTANTIATION: This section should be subordinate to Log #429 Final Action: Reject (1.4.5) SUBMITTER: Michael Short, UTC Power/UTC Fuel Cells The validation shall at a minimum include the following: (1) P process safety analysis and hazard and operability studies (HAZOPS). (2) Mitigating fire protection measures such as suppression systems (3) Aboveground or belowground systems or vaults for the containers (4) Fire and gas detection systems designed to interface with emergency shutdown device (ESD) (5) Ventilation and other facility features (6) Drainage and impounding for the individual site as administered by registered engineers with proven experience in those fields. SUBSTANTIATION: a. The validation techniques outlined in this paragraph are a result of alternate siting distances provision specified in Paragraph b. Items 2-6 are not validation techniques. The only item constituting a validation technique for alternate siting distances is Item 1. COMMITTEE STATEMENT: The listed items are all system components that must be reviewed or safety procedures that must be performed.

10 52-50 Log #488 Final Action: Reject (1.4.5) RECOMMENDATION: Add as appropriate at the end of the first line. SUBSTANTIATION: For example, requiring (6) ( drainage and impounding... ) for CNG cites is inappropriate. COMMITTEE STATEMENT: Without defining what appropriate is, it cannot be put into this requirement Log #773 Final Action: Accept ( ) SUBMITTER: Stan Sinclair, Southern California Gas Company Qualified registered engineer(s). SUBSTANTIATION: There are several qualified engineers who have been doing similar work for years. By requiring a registered engineer, project cost will be increased, and projects will be delayed, because of scarcity of qualified registered engineers in the specific field. COMMITTEE STATEMENT: Committee acceptance is not based on project cost and time Log #489 Final Action: Accept (1.7) RECOMMENDATION: Add L/CNG to the list. SUBSTANTIATION: This is a good catch-all requirement, but it could be construed to require training for someone pumping CNG (or CH2 for that matter) into their own car. That could be a real problem. However, I have no suggested solution. BALLOT RESULTS: Affirmative: 16 Negative: 1 Abstain: 1 EXPLANATION OF NEGATIVE: JOSEPH: The requirement as written, is technically flawed as container cooling during pause will make it look like a leak Log #250 Final Action: Reject (1.14) SUBMITTER: Anthony Estrada, Pacific Gas & Electric Company RECOMMENDATION: Paragraph 1.14 indicates that this proposed code shall apply to GH2 and LGH2 engine fuel systems on vehicles using mixtures of up to 20% GH2 mixture in compressed natural gas. More information is needed in this document to address the safe use of this blended fuel for vehicular application. The term HCNG should be added to the Definitions section of the document, Chapter 3. The suggested definition can be: HCNG is a blended fuel mixture of gaseous hydrogen (GH2) and compressed natural gas (CNG) with no more than 32 percent GH2 by volume blended with the CNG. SUBSTANTIATION: The document will be complete if more technical information relating to the GH2 and CNG blend is included in the document. COMMITTEE STATEMENT: There is not a specific recommendation given in the comment Log #321 Final Action: Reject (1.14) SUBMITTER: Dick Kauling, General motors Corporation This code shall apply to the design and installation of GH 2 and LGH2 engine fuel systems up to 3600 psi (25 mpa) on vehicles operating on mixtures of GH2/LGH2 up to 20 percent with the balance natural gas (NG). Vehicles complying with Federal Motor Vehicle Safety Standards (FMVSS) covering the installation of hydrogen fuel systems on vehicles certified by the respective manufacturer as meeting these standards shall be exempt from this code. SUBSTANTIATION: Vehicles complying with FMVSS for CNG and LNG were previously identified as exempt from certain NFPA 52 sections and similar provisions should be identified with hydrogen level (vs. 20%). COMMITTEE STATEMENT: is also rejected for the same reason. No standards exist Log #491 Final Action: Reject (Chapter 2) RECOMMENDATION: Add websites and phone numbers for all SDOs. Correct the addresses for CSA, CGA, etc. Note that IAS is now CSA America. SAE J2601 and J2579 have not been published and, I gather, probably won t be published soon. SUBSTANTIATION: None provided. COMMITTEE STATEMENT: Addressed in NFPA Manual of Style Log #490 Final Action: Accept (2.2) RECOMMENDATION: Reference the 2003 edition of NFPA 30A. SUBSTANTIATION: The 2003 edition is the latest Log #53 Final Action: Reject (2.2, 2.3.1) SUBMITTER: Jon Miller, Detector Electronics Corp. COMMENT ON PROPOSAL NO: 52-1 RECOMMENDATION: Add the following ANSI documents as referenced publications within NFPA 52: Clause 2.2: ANSI/NFPA 72 National Fire Alarm Code, 2002 Edition. Clause 2.3.1: ANSI/ISA , Performance Requirements for Combustible Gas Detectors, Clause 2.3.1: ANSI/ISA-RP , Recommended Practice for the Installation, Operation, and Maintenance of Combustible Gas Detection Instruments. SUBSTANTIATION: The above listed ANSI documents are used in practice for fire and gas detection equipment which are referenced within multiple