Your Hydrogen Guide to the 2006/2007 ICC Code Development Hearings
The A-B-Cs for voting ICC members, code officials and industry

Patrick Serfass, National Hydrogen Association

TABLE OF CONTENTS

1. Introduction
   
   
2. Why is this important?
   
   
3. Background
   
   
4. The "A-List"
   
   
5. The "B-List"
   
   
6. Other Resources
   
   

Introduction
This article is aimed at voting ICC members, code officials and any interested parties from the hydrogen industry who are in the process of evaluating whether a company representative is needed at the ICC Code Development Hearings near Orlando, FL, September 20-30, 2006. This article will address potential issues in each code change as objectively as possible so that you as a reader may form your own opinion about whether each code change proposal should be approved or disapproved.

Why should you care?
If you're in the hydrogen industry in short, these code changes, if adopted, could impact your business. The codes changes below might increase or reduce costs. They might make it easier or more difficult to install hydrogen equipment. They might enhance or reduce the level of safety in a public area. Obviously, each proponent and the group he or she represents feels that the proposed code change is an improvement over what exists in the most recent edition of the I-Codes. You may agree or disagree.

If you are a voting ICC member, code official, or authority having jurisdiction, you will need to formulate an opinion. This will help you to prepare near-term to interact with industry to alleviate any concerns you may have and eventually prepare for the Final Action Hearings where your vote will decide whether each change is adopted or thrown out.

To determine your position, NHA staff (with some help from ICC staff and the Hydrogen Industry Panel on Codes) has attempted to distill the importance of each code change in plain English. Please read-on, engage your colleagues in discussions about those that interest you, and if you feel the need to speak in favor or against any of the code changes, plan your travel to be at the Code Development Hearings on the appropriate days(s), this September 20-30 in Lake Buena Vista, FL. For a more in-depth look, click on the code changes below which will give you a link to a short pdf which includes the actual proposal and a "reason statement" (justification) submitted by each proponent.

Relevant resources for this section:

• Public Hearing schedule
  http://www.iccsafe.org/cs/codes/
  2006-07cycle/ProposedChanges/hearing_schedule.pdf
  
  
• Travel and other activity information
  http://www.iccsafe.org/news/annual/
  2006Conference/brochure.pdf

Background
As described during the last cycle of the I-Codes (the common name for the International Code Council's family of codes), the Code Development Hearings are the first of two stages to either approve or disapprove code changes. The second stage is the Final Action Hearings. All code proposals entered in the beginning of the 18-month cycle are heard during both stages unless withdrawn by the person who submitted the change, or "proponent."

The key differences between the two stages are that in the Code Development Hearings the code change proposals are heard by a committee and the result of their decision is a recommendation on how the ICC membership (code enforcement and fire officials, architects, engineers, builders, contractors, elected officials, manufacturers and others in the construction industry) might want to vote at the Final Action Hearings-approve or disapprove.

In the second stage, the Final Action Hearings, as you might expect, the proposals are heard by the ICC membership and their vote is the final decision on whether a code change proposal is approved or disapproved. At the Final Action Hearings, the same committee who recommended an outcome at the earlier Code Development Hearings will hear the proposals again, but this time in more of a moderating/advisory role.

At both the Code Development Hearings and Final Action Hearings, the proponent, supporters and opponents are allowed a short time to speak to the committee and ICC membership about any code change. Anyone, ICC members and non-members, may speak in favor of or opposition against a proposal, but only ICC members can vote at the later Final Action Hearings. Proposals can also be withdrawn by the proponent at any time.

Relevant resources for this section:

• Information on the ICC process (click on "Code Development Process"):
  http://www.iccsafe.org/cs/codes/
  
  
  
• "ICC Hearing Actions Result in Win-Win for U.S. Building Regulatory Community and Hydrogen Industry" (Mar-2005, Hydrogen Safety Report):
  http://www.hydrogensafety.info/archives/2005/mar/1.html

The "A-List" (8 proposals)
These are the eight code changes identified by the Hydrogen Industry Panel on Codes (HIPOC) which need a closer look at the proposed changes to identify any potential impact on the hydrogen industry. Click on each code change for the official proposal and reason statement.

How to interpret "F54-06/07"
Each change is identified by a name that combines the name of the specific I-Code, an identification number, and the code cycle when it is scheduled for review. Therefore, "F54-06/07" is the 54th code change submitted to the International Fire Code (if you're counting, there are 232 total proposed to just the fire code) during this 2006-2007 18-month code cycle. (All of these proposals will be heard during the 06/07 cycle.) This one was submitted by Lynne Kirkpatrick, representing the Seattle Fire Department. The actual code sections (i.e. 608.6.3) read like an outline. Section 608 is the eighth section of Chapter 6. The section 608.6 is the sixth subsection of 608, 608.6.3 is the third subsection of 608.6 and so on.

Here are the eight proposals (the description in quotes is simply a way for you to remember what subject goes with each code change):

1. F54-06/07 "Required automatic status monitoring of lead acid battery room ventilation systems"
   
   
2. F157-06/07 "Consistent 'listing' of lighter-than-air gas detection systems"
   
   
3. F172-06/07 "Addressing hydrogen cylinders stored in outdoor cabinets"
   
   
4. F175-06/07 "Diking around above ground LH2 storage"
   
   
5. F191-06/07 "Movement of LH2 language and new LH2 tank requirements from CGA"
   
   
6. F193-06/07 "Telecomm cabinets and transfer switches near outdoor hydrogen cabinets"
   
   
7. F194-06/07 "Guidance for metal hydride systems"
   
   
8. F229-06/07 (IFGC) "New requirements for indoor hydrogen storage"

1) F54-06/07
"Required automatic status monitoring of lead acid battery room ventilation systems"
Proponent: Lynne M. Kilpatrick, Fire Department, City of Seattle, WA

Summary: This code change is a new section proposed for 608.6 of the International Fire Code:
Chapter 6: Building services and systems.
Section 608: Stationary storage battery systems
Section 608.6: Ventilation

This change requires that the ventilation systems in 608.6.1 (room ventilation) and 608.6.2 (cabinet ventilation) which are required to insure that the concentration of hydrogen does not exceed 1% or present an explosion hazard. This proposal adds an additional requirement for supervision by an "approved central, proprietary, or remote station service" or the activation of "an audible and visual signal at a constantly attended on-site location." According to a discussion with the proponent, this proposal only applies to stationary lead-acid battery systems with an electrolyte capacity >50 gal. and would require status monitoring of the ventilation system (air flow - no air flow) already required by 608.5. This is typically accomplished with a vane-type paddle in the duct that changes position when there is no airflow and activates a position switch that can be monitored by the fire alarm system. Although this change will increase the cost of new installations, cost may not increase by much since the smoke detectors already required (by 608.8) will make sure a fire alarm system is present and a fire alarm circuit is nearby.

Interested parties should also take a look at F53 "Lithium Metal Polymer batteries" for any potential impact.

2) F157-06/07
"Consistent 'listing' of lighter-than-air gas detection systems"
Proponent: Greg Rogers, South Kitsap Fire & Rescue, representing ICC Joint Fire Service Review Committee

Summary: This code change proposes modifications to subsections 2211.7.2 and 2211.7.2.1 of the International Fire Code:
Chapter 22: Motor fuel-dispensing facilities and repair garages
Section 2211: Repair garages
Section 2211.7: Repair garages for vehicles fueled by lighter-than-air fuels
Section 2211.7.2: Operation
Section 2211.7.2.1: System design

The code change will change gas detection systems from requiring to be "approved" to requiring that they be "listed." The proponent says this change is needed because similar sections in other parts of Chapter 22 (See 2208.2.2 which deals with natural gas motor fuel dispensing facilities and 2209.2.2 which deals with hydrogen motor fuel-dispensing and generation facilities) also require gas detection systems to be "listed." Both 2208 and 2209 require that some types of equipment be "approved," some "listed" and others "listed and labeled." In sections, 2208.2.2 and 2209.2.2, gas detection systems are required to be "listed." This code change would require gas detection systems in repair garages for vehicles fueled by lighter-than-air fuels to be "listed."

Note: Just before publication, the NHA learned that some experts have suggested that this code language be modified to read "approved or listed" since today, there are few or no "listed" gas detection systems.

3) F172-06/07
"Addressing hydrogen cylinders stored in outdoor cabinets"
Proponent: Paul J. Buehler, Jr., Plug Power, Inc.

Summary: This code change has three parts. Part one proposes new sections 3003.7.11 through 3003.7.11.2. Part two proposes new section 3504.2.2. Part three proposes a new reference in Chapter 45. All parts pertain to sections of the International Fire Code.

Part One
Chapter 30: Compressed Gases
Section 3003: General requirements
Section 3003.7: Separation from hazardous conditions
Section 3003.7.11: Exposure to fire

Part Two
Chapter 35: Flammable Gases
Section 3504: Storage
Section 3504.2: Outdoor storage

Part Three
Chapter 45: Referenced standards

According to the proponent, this proposal revises outdated material because current International Fire Code and NFPA 55 sections do not deal with the storage of bottled hydrogen out of doors inside cabinets, but rather only consider "naked" cylinders or indoor gas cabinets per Sections 2703.8.6 "hazardous material gas cabinet construction requirements" and 3006.2.3 "medical gas system cabinets." This amendment pertains directly to the hydrogen storage and appears to facilitate the placement of bottled hydrogen in outdoor cabinets in proximity to low powered electrical equipment. Interested parties should view the actual code change by clicking the F172 link above to note the maximum allowed quantity of hydrogen that can be stored in an outdoor cabinet and separation distances to both combustible waste/vegetation and electrical equipment.

Note: A review of the proposed standard(s) will be posted on the ICC Website by August 20, 2006.

4) F175-06/07
"Diking around above ground LH2 storage"
Proponent: John C. Dean, The National Association of State Fire Marshals

Summary: This code change proposes additional language to the drainage subsection of the outdoor storage of cryogenic fluids section (3204.3.1.3) in the International Fire Code.
Chapter 32: Cryogenic Fluids
Section 3204: Storage
Section 3204.3: Outdoor storage
Section 3204.3.1: Stationary containers

According to the proponent:

There has been considerable discussion on the requirement for, or prohibition of, or restriction on, the use of diking around above-ground LH2 storage. The proposed language captures the intent to prevent liquid hydrogen from entering areas not zoned/rated for flammable gas, and to control the ground-level vapor cloud, to the extent possible, to within areas designed to address a flammable mixture.

There are advantages and disadvantages to diking. The disadvantage is that it may increase the resident time of a vapor cloud over the affected area. However, this is also considered a positive, as it reduces the total affected area. This may be particularly important if adjacent property is not properly zoned to address a hydrogen leak. The proposed language serves to minimize the affected area to the extent possible, while still preventing additional hazards from forming.

The disconnect switch is required for personnel protection while working on the circuitry between the fuel cell and the load. It is not a device which is activated for any other purpose. Therefore, the use of fuses in the disconnect switch is not required. Plus, fuses are placed inside the fuel cell and sometimes at the load, making disconnect fuses redundant and also a possible location for electrical faults. Fuses, unless they are potted, are a spark source, so it is best to avoid them in this application.

The disconnect switch would only be activated then by a workman. And, logically, the fuel cell would not be in operation when the switch is thrown for electrical reasons. So, the hazard in using an unfused switch is "close to nil."

Now, that then leads us to the next portion of the question, where should such a switch be located? It needs to be in close proximity to the fuel cell, like within 6 feet, delatest on how one interprets the National Electric Code. Using certain scientific studies, we know we want this switch to be located someplace where hydrogen gas normally cannot be present - below the ridge vent.

But, what if there is a low-pressure leak in the external tubing between cabinets? Could not that hydrogen collect in a bad place? The answer is that if a rupture occurs the excess flow valve in the fuel cell system operates and shuts off the flow of hydrogen from the tanks. Then the volume of expelled gas is essentially just that which is in the low pressure tubing, 6.1 cubic inches, which does not constitute a flammable mixture.

Therefore, this code change proposes that the unfused disconnect switch be allowed to be housed in a general purpose box, at an elevation not to exceed 48 inches above ground. This provides a small factor of safety with reference to the elevation of the ridge vent, 70 inches above ground.

7) F194-06/07
"Guidance for metal hydride systems"
Proponent: Larry Fluer, Fluer, Inc., representing Compressed Gas Association

Summary: This proposal adds new sections 3506 and 3502.1 dealing with metal hydride hydrogen storage systems in:
Chapter 35: Flammable Gases (F191 suggests a change to this chapter's title)
Section 3502: Definitions
Section 3506: Metal hydride storage systems

This proposal adds language relevant to metal hydrides. Part of the language had been a part of the fire code before, and was deleted during the last cycle. The committee approved the deletion of the above text based on the fact that it leads the code official to believe that there are listed systems available when, in fact there were none. In addition, standards for testing and listing of the systems were not yet final. In support of the action to strike the language from the code the committee suggested that until such time as there are listing standards… "it would be better if the code included, in codified form, the safeguards that are currently used by the industry for the systems that are currently in use in the field."

The code change now proposed by the Compressed Gas Association (CGA) is an effort to bring the parties to consensus in a manner that recognizes the presence of these unique systems, and to place fundamental requirements in the code to address their use.

Like the language approved and rejected before, this proposed language (with some additions) still proposes that the metal hydride container be treated as a flammable gas and not with any special treatment to whatever materials may make up the metal hydride mixture. The reason this is consider a safe practice is because the metal hydride tanks are designed to always contain the metal hydride. Since the metal hydride is expected to always remain in its tank, the thought is that only the substance entering and leaving the tank should be regulated-in this case, the flammable gas: hydrogen.

Absence of this language will give the code official no guidance on how to regulate metal hydride systems, but interested parties should look at the specific language proposed to identify any impacts to their business.

8) F229-06/07
"New requirements for indoor hydrogen storage"
Proponent: John C. Dean, The National Association of State Fire Marshals

Summary: This proposal suggests the creation of a new section on indoor hydrogen storage in Chapter 7 of the International Fuel Gas Code.
Chapter 7: Gaseous Hydrogen Systems
Section 706: Location of gaseous hydrogen systems
Section 706.4: Indoor storage of hydrogen

This proposal adds new language to the International Fuel Gas Code providing requirements for indoor storage of hydrogen. Interested parties should compare these requirements with other sections in the International Fire Code (Chapters 27, 30 and 35) for relevance to indoor hydrogen storage. According to the proponent, these additions differ from anything in existing code in that they stipulate pressure limits, not just quantities of hydrogen gas. Ventilation and alarms are required so that should there be a gas leak, it is detected and there is no chance of asphyxiation.

The "B-List" (8 proposals)
These are proposals that the Hydrogen Industry Panel on Codes feels are more likely to be approved without additional discussion. Of course, three of them (F154, F155 and F156) are HIPOC proposals. Of any of those three, F155 "Indoor fast-fill dispensing" is probably the most likely to attract additional discussion.

Here are the eight "B-List" proposals:

1. International Fuel Gas Code-Scoping Changes
   
   
2. FG54-06/07 "H2 Piping-Concealed Locations"
   
   
3. M56-06/07 "Ventilation requirement moved from exhaust to ventilation"
   
   
4. FS37-06/07 "Fire barrier definition"
   
   
5. F53-06/07 "Lithium Metal Polymer batteries"
   
   
6. F154-06/07 "Vehicle overpressure protection"
   
   
7. F155-06/07 "Indoor fast-fill dispensing"
   
   
8. F156-06/07 "Electrostatic discharge for fueling pads"

1) International Fuel Gas Code-Scoping Changes
Subject Section 2003 Scoping Assignment
2006 Scoping Assignment - Storage of hydrogen 706.4 will be heard by the International Fire Code Committee. This is a simple scoping change that is not expected to draw any discussion.

2) FG54-06/07
"H2 Piping-Concealed Locations"
Proponent: Guy Tomberlin, Fairfax County, Virginia, representing Virginia Plumbing and Mechanical Inspectors Association (VPMIA) and the Virginia Building Code Officials Association (VBCOA)

Summary: This code proposal suggests the deletion of a couple words in part of the International Fuel Gas Code
Chapter 7: Gaseous hydrogen systems
Section 704: Piping, use and handling
Section 704.1: Applicability
Section 704.1.2: Piping systems
Section 704.1.2.3 Piping design and construction
Section 704.1.2.3.5: Protection against physical damage

In the last cycle, it was approved to not permit hydrogen piping to be located inside in a concealed location. This will maintain clarity in a section affected by the previous decision. The rest of the text is important to remain because piping could potentially be installed that is exposed on one side of a wall ceiling or floor but could still have a covering installed on the other.

3) M56-06/07
"Ventilation requirement moved from exhaust to ventilation"
Proponent: Ronald Marts, Telcordia, representing AT&T, SBC, Ameritech, PacBell, Cincinnati Bell, BellSouth, Qwest and Southern New England Telephone

Summary: This proposal moves language from the exhaust section of Chapter 5 of the International Mechanical Code to the ventilation section. It appears that the ventilation requirement for stationary storage battery systems was inadvertently put in the "exhaust" chapter of the IMC instead of the ventilation chapter. Language appears to be unchanged during the relocation.

Chapter 5: Exhaust systems
Section 502: Required systems

Chapter 4: Ventilation Systems
Section 407 (New section): Ventilation of Stationary Storage Battery Systems

Analysis from Fire Code Committee: It is not clear why the proponent did not propose to relocate other sections of 502 that also address ventilation rather than exhaust. The code does not distinguish between ventilation by means of exhaust systems or by means of supply air systems

4) FS37-06/07
"Fire barrier definition"
Proponent: Philip Brazil, P.E, Reid Middleton, Inc., representing himself

Summary: The definition of fire barrier was revised last cycle from begin a vertical or horizontal assembly to being a wall assembly and by deleting the provisions for horizontal fire barriers. The proposal, however, did not make the necessary revisions to other sections of the International Building Code, which are needed in order for the concept to be fully incorporated into the provisions of the IBC. The purpose of this proposal is to make the necessary revisions to the provisions in those code sections.

This proposal recommends small changes to many different sections of several I-Codes.

5) F53-06/07
"Lithium Metal Polymer batteries"
Proponent: Ronald Marts, Telcordia Technologies, representing AT&T, SBC, Ameritech, PacBell, Cincinnati Bell, Qwest, Southern New England Telephone

Summary: This proposed change simply adds Lithium Metal Polymer (LMP) batteries to the following sections of the International Fire Code:
Chapter 6: Building services and systems
Section 602: Definitions
Section 608: Stationary storage battery systems

Interested parties should also take a look at F54 "Required attendant for battery storage ventilation systems" for any potential impact on this code proposal.

6) F154-06/07
"Vehicle overpressure protection"
Proponent: Thomas Joseph, Chair, Hydrogen Industry Panel on Codes

Summary: This proposal suggests the level at which the overpressure system on the dispenser side of the vehicle fueling system should activate to prevent overpressure of the vehicle fuel system. The level was chosen to be consistent with overpressure levels as determined by SAE. At the time of publication, SAE has recently tweaked their overpressure level from 140% to 138% to be consistent with other requirements. Safety-wise, this should be a negligible change. NHA staff understands that the proponent may suggest a modification of this proposal's overpressure level to retain consistency.

This proposal is for Chapter 22 (Motor fuel-dispensing facilities and repair garages) of the International Fire Code.

7) F155-06/07
"Indoor fast-fill dispensing"
Proponent: Thomas Joseph, Chair, Hydrogen Industry Panel on Codes

Summary: This proposal suggests new language for Chapter 22 (Motor fuel-dispensing facilities and repair garages) of the International Fire Code. Current provisions of the code do not address the requirements for indoor attended fast fill systems (systems designed to provide a fuel fill rate greater than or equal to 12 Standard Cubic Feet per Minute (SCFM)). According to the proponent, fast fill hydrogen fuel dispensing can be safely accomplished with the requirements added by this new section 2209.5.

8) F156-06/07
"Electrostatic discharge for fueling pads"
Proponent: Thomas Joseph, Chair, Hydrogen Industry Panel on Codes

Summary: This proposal suggests new language for Chapter 22 (Motor fuel-dispensing facilities and repair garages) and Chapter 45 (Referenced standards) of the International Fire Code as well as Chapters 4 (Special Detailed Requirements Based On Use And Occupancy) and 45 of the International Building Code. The current language does not address safety issues associated with electrostatic discharges (ESD). Fueling surfaces for hydrogen powered vehicles should be at least as protective regarding ESD issues as those fueling surfaces used for petroleum powered vehicles. This language is intended to reduce the probability of a static spark by requiring that the pad the vehicle sits on will effectively ground the vehicle.

A review of the proposed standard(s) will be posted on the ICC Website by August 20, 2006.

Other Resources
NHA presentation "2006/2007 Hydrogen I-Code Proposals" to the National Association of State Fire Marshal's Hydrogen Executive Leadership Panel (HELP)
August 12, 2006