use NFPA and NEC to reduce bldg from CID1 to CID2?

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Dale001289

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Location
Georgia
I want to change a building Area Classification from Class I, Division 1 to Class I Division 2 using Fans/Gas Detectors in accordance with NFPA 497 and NEC 500.7(K)(1).
Is this a viable solution?
 

petersonra

Senior Member
Location
Northern illinois
Occupation
engineer
I want to change a building Area Classification from Class I, Division 1 to Class I Division 2 using Fans/Gas Detectors in accordance with NFPA 497 and NEC 500.7(K)(1).
Is this a viable solution?

I have always thought the gas detection options were pretty limited in their utility. I think you probably will need to pay someone competant to make this call for you and come up with a design.
 

rbalex

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Location
Mission Viejo, CA
Occupation
Professional Electrical Engineer
I want to change a building Area Classification from Class I, Division 1 to Class I Division 2 using Fans/Gas Detectors in accordance with NFPA 497 and NEC 500.7(K)(1).
Is this a viable solution?
You need to answer two questions first:

  1. Why is the location classified as Division 1 in the first place?
  2. Which of the three Subsections of Section 500.7(K) are you applying - (1), (2), or (3)?
 

Strathead

Senior Member
Location
Ocala, Florida, USA
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Electrician/Estimator/Project Manager/Superintendent
From my understanding and a logic standpoint, it is always better to reduce the presence of explosive gasses to reduce the chance of ignition. So the short answer would be yes. However, designing the method and determining the classification is obviously better left to those educated and qualified to do this.
 

Dale001289

Senior Member
Location
Georgia
You need to answer two questions first:

  1. Why is the location classified as Division 1 in the first place?
  2. Which of the three Subsections of Section 500.7(K) are you applying - (1), (2), or (3)?

It’s an atypical scenario. The building has been designated simply as “Hazardous Materials Building” but no one is sure what exactly the materials will be housed within – one must assume both lighter than air as well as heavier than air hazardous vapors could be installed.

Using 500.7(K)(1)

 

rbalex

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Staff member
Location
Mission Viejo, CA
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Professional Electrical Engineer
It’s an atypical scenario. The building has been designated simply as “Hazardous Materials Building” but no one is sure what exactly the materials will be housed within – one must assume both lighter than air as well as heavier than air hazardous vapors could be installed.

Using 500.7(K)(1)
  1. This is not “atypical”. This is a WAG.
  2. If you were planning on ventilating it properly, why are you using 500.7(K)(1)?
Personally, I wouldn’t touch it.
 

Dale001289

Senior Member
Location
Georgia
  1. This is not “atypical”. This is a WAG.
  2. If you were planning on ventilating it properly, why are you using 500.7(K)(1)?
Personally, I wouldn’t touch it.

This client doesn't trust exhaust fan ventilation alone. He wants more assurance - a gas detection system along with alarms/shutdown of power to the building (its actually a single room) will provide that.
I don't see why everyone on this string is so apprehensive about doing this - its perfectly legal according to NFPA 497 and NEC.
 

petersonra

Senior Member
Location
Northern illinois
Occupation
engineer
The building has been designated simply as “Hazardous Materials Building” but no one is sure what exactly the materials will be housed within – one must assume both lighter than air as well as heavier than air hazardous vapors could be installed.

I don't see how you can assume anything and still get it right. I doubt anyone competent to do so would want to put his name or his PE seal on something with so little information.

I suppose you could classify the whole thing as Class I, Division 1, Groups A, B, C and D. Might find that a bit hard to make work though.

However, reading what 500.7(K)(1) says

(1) Inadequate Ventilation. In a Class I, Division 1 location
that is so classified due to inadequate ventilation, electrical
equipment suitable for Class I, Division 2 locations shall be
permitted. Combustible gas detection equipment shall be listed
for Class I, Division 1, for the appropriate material group, and
for the detection of the specific gas or vapor to be encountered.

It appears you can already use C1D2 stuff (other than the gas detection equipment) so what do you gain by reclassifying it?
 

Dale001289

Senior Member
Location
Georgia
I don't see how you can assume anything and still get it right. I doubt anyone competent to do so would want to put his name or his PE seal on something with so little information.

I suppose you could classify the whole thing as Class I, Division 1, Groups A, B, C and D. Might find that a bit hard to make work though.

However, reading what 500.7(K)(1) says



It appears you can already use C1D2 stuff (other than the gas detection equipment) so what do you gain by reclassifying it?

Well, reasonable assumptions are made all the time in this business. If one insisted solely on absolutes, nothing would get done on time and costs would go through the roof. Just like your comment "classify the whole thing as Class I, Division 1, Groups A, B, C and D". This philosophy will certainly work - but isn't very cost effective I'm afraid.
 

rbalex

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Staff member
Location
Mission Viejo, CA
Occupation
Professional Electrical Engineer
... - its perfectly legal according to NFPA 497 and NEC.
No, actually it isn't.

Read all of Section 500.7 carefully, then Section 500.7(K) even more carefully, then Subsection 500.7(K)(1) MUCH more carefully.

A Combustible Gas Detection System (CGDS) is a protection technique, not a basis for classifying a location. Subsection 500.7(K)(1) permits using Class I, Division 2 equipment/wiring methods but not "de-classifying" the location. The location is still Class I, Division 1.

From Section 500.8(K) main text:
The type of detection equipment, its listing, installation
location(s), alarm and shutdown criteria, and calibration
frequency shall be documented when combustible gas detectors
are used as a protection technique.
Do you plan to provide CGDS for every potential gas? It the client really prepared for all the documentation/maintenance a CGDS requires (for every potential gas)? See the first three Informational Notes. While they are not "Code", since the referenced documents are ANSI sanctioned, they are OSHA enforceable.

Proper ventilation is a recognized basis for classifying a location and is far more reliable and easier to maintain than a CGDS. EDIT ADD (after seeing your last response) It's more cost effective too.
 
> The building has been designated simply as “Hazardous Materials Building” but no one is sure what exactly the materials will be housed
> within – one must assume both lighter than air as well as heavier than air hazardous vapors could be installed.

Interesting scenario. I guess it's unspecified flammable liquids in unsealed tanks, and not cylinders of gas, LPG, or the like? (You didn't say.)

Based on what we know, I pretty much concur with everyone else - adequate ventilation would be the way to go. Since you mentioned ventilation alone is not acceptable, I assume ventilation must be possible. That would (hopefully) get you Div 2 without the need to worry about validity.

If the client "doesn't trust ventilation alone", and wants combustible gas detection on top, that's fine. But the gas detection would (ideally) have nothing to do with the area classification or the allowable equipment since it would not be needed as a protection method.

Having built gas detectors for some decades, I would not trust gas detection as a protection method unless I had at least some idea of the substances it's supposed to be detecting. Plus the sensitivity for heavy hydrocarbons is often poor, and T90 times are often long. But if it's only supplementary, gas detection would devolve from critical to merely important, lowering the burden of proof.

In a practical sense you'd still have to worry about how to detect the heavier hydrocarbons effectively. Plus, if you're expecting both lighter- and heavier-than-air, you'd probably have to have some detectors near the roofline and some near grade, increasing costs. Maybe even different calibrations / correction factors for the upper and lower detectors.

> Well, reasonable assumptions are made all the time in this business.

Doesn't make it right.
 

Dale001289

Senior Member
Location
Georgia
> The building has been designated simply as “Hazardous Materials Building” but no one is sure what exactly the materials will be housed
> within – one must assume both lighter than air as well as heavier than air hazardous vapors could be installed.

Interesting scenario. I guess it's unspecified flammable liquids in unsealed tanks, and not cylinders of gas, LPG, or the like? (You didn't say.)

Based on what we know, I pretty much concur with everyone else - adequate ventilation would be the way to go. Since you mentioned ventilation alone is not acceptable, I assume ventilation must be possible. That would (hopefully) get you Div 2 without the need to worry about validity.

If the client "doesn't trust ventilation alone", and wants combustible gas detection on top, that's fine. But the gas detection would (ideally) have nothing to do with the area classification or the allowable equipment since it would not be needed as a protection method.

Having built gas detectors for some decades, I would not trust gas detection as a protection method unless I had at least some idea of the substances it's supposed to be detecting. Plus the sensitivity for heavy hydrocarbons is often poor, and T90 times are often long. But if it's only supplementary, gas detection would devolve from critical to merely important, lowering the burden of proof.

In a practical sense you'd still have to worry about how to detect the heavier hydrocarbons effectively. Plus, if you're expecting both lighter- and heavier-than-air, you'd probably have to have some detectors near the roofline and some near grade, increasing costs. Maybe even different calibrations / correction factors for the upper and lower detectors.

> Well, reasonable assumptions are made all the time in this business.

Doesn't make it right.

Lots of great input on this string...thanks to all of you.

Consider the following excerpt from NFPA 497:
“When classifyingbuildings, careful evaluation of prior experience with the same or similarinstallations should be made.
It is not enough toidentify only a potential source of the combustible material within thebuilding and proceed immediately to defining the extent of the Class I,Division 1 or the Division 2; or Class I, Zone 1 or Zone 2 classified areas. Whereexperience indicates that a particular design concept is sound, a morehazardous classification for similar installations may not be justified.Furthermore, it is conceivable that any area be reclassified form either ClassI, Division 1 to Class I Division 2, or from Class I, Division 2 tounclassified, or from Class I, Zone 1 to Class I, Zone 2, or from Class I, Zone2 to unclassified, based on experience.”

If the building is well protected against hazardous vapors with ventilation,gas detectors, alarms etc and the equipment/wiring can therefore be ratedDivision 2, it seems borderline absurd to insist the Building is still Division1, other than to avoid some sort of litigation.

So how is this accurately communicated on an Area Classification drawing? Do I show the building as Division 1 with a note stating its really Division 2?


 

petersonra

Senior Member
Location
Northern illinois
Occupation
engineer
So how is this accurately communicated on an Area Classification drawing? Do I show the building as Division 1 with a note stating its really Division 2?

You can do it however your professional liability insurer says you can. When you put your PE seal on the drawing they are the ones holding the bag if you are wrong.
 
it seems borderline absurd to insist the Building is still Division1, other than to avoid some sort of litigation.

It's impossible to argue since you're the only one who knows what we're talking about. The rest of us are flying blind.

However, the conclusion should be scientifically and legally defensible. If you don't think you're on solid enough ground to convince an expert in the field, it's probably incorrect.

If the situation really is that absurd, you should have no difficulty listing 6-12 specific reasons why you think the area isn't Div 1. Or Div 2. Or whatever.

This phrase:

> Where experience indicates that a particular design concept is sound, a more hazardous classification for similar installations may not be justified.

This would be more defensible if the "experience" cited:

- Included specific experience with the actual design concept(s), construction, or other elements that make up this particular area; and
- Included experiments, measurements, or other empirical data; and
- The ventilation systems necessary for the area classification were redundant, alarmed, or otherwise failsafe; and
- Spanned a very long period of time; and
- so on and so on.

There are limits to experience as well. For example, it would be possible to take 10 years of gas detection measurements across a number of sites, plus a full review of the site records, and conclude the area(s) should be declassified from Div 2 to non-hazardous because there had never been a leak. And then go on to apply this to other similar sites.

But there still could be a leak in the future, making both the initial conclusion and the subsequent application to other sites incorrect. Meaning experience doesn't trump basic area classification principles.


The moral of the story is that you do have to work the worst-case situation. It's not just what should happen, nor what's intended to happen. It's what may happen. I'm not getting the right vibe in that respect, hence my concern.

In this context, what may happen is unusually broad. Pressurized pipelines are considered subject to leaks; containment systems are presumed to fail; ventilation systems could break down; malfunctions do occur; spillage and leakage during transfers does occur; mistakes and accidents are presumed to happen. Usually, none of these items are expected, routine, or intended, and we actively work to prevent them, but they must be taken into consideration nevertheless.

I would highly recommend you scour the various area classification standards for something that is more defensible than simply a gut feeling that it "feels borderline absurd".


So how is this accurately communicated on an Area Classification drawing? Do I show the building as Division 1 with a note stating its really Division 2?

Area classification drawings show conclusions, not explanations. You would classify it as Div 2.
 
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rbalex

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Location
Mission Viejo, CA
Occupation
Professional Electrical Engineer
,,,
If the building is well protected against hazardous vapors with ventilation,gas detectors, alarms etc and the equipment/wiring can therefore be ratedDivision 2, it seems borderline absurd to insist the Building is still Division1, other than to avoid some sort of litigation.

So how is this accurately communicated on an Area Classification drawing? Do I show the building as Division 1 with a note stating its really Division 2?
It's interesting you should cite NFPA 497 as you have. (You even kept my underlines) The obvious question is, "Do you have the experience to justify your evaluation?"

As we have already mentioned, if you are properly ventilated, it is already Division 2 and the CGDS is a waste of money when you consider the all documentation/maintenance required. Many CGDS often require retests every 3 - 6 months and recertification every 2 - 5 years. They really aren't all that cost effective to begin with. There will come a time someone in upper management will decide the documentation and maintenance isn't worth it (usually around the first recertification) and it will be abandoned.

If in fact you still choose to rely on the CGDS, it is still Division 1, You would note on your required documentation [Section 500.4(A)] that it Division 1 and you are using Section 500.7(K)(1) as one of your protection techniques.

Of course, you could use a redundant ventilation system with flow monitoring and all the alarms your heart could desire.
 

petersonra

Senior Member
Location
Northern illinois
Occupation
engineer
It's interesting you should cite NFPA 497 as you have. (You even kept my underlines) The obvious question is, "Do you have the experience to justify your evaluation?"

As we have already mentioned, if you are properly ventilated, it is already Division 2 and the CGDS is a waste of money when you consider the all documentation/maintenance required. Many CGDS often require retests every 3 - 6 months and recertification every 2 - 5 years. They really aren't all that cost effective to begin with. There will come a time someone in upper management will decide the documentation and maintenance isn't worth it (usually around the first recertification) and it will be abandoned.

If in fact you still choose to rely on the CGDS, it is still Division 1, You would note on your required documentation [Section 500.4(A)] that it Division 1 and you are using Section 500.7(K)(1) as one of your protection techniques.

Of course, you could use a redundant ventilation system with flow monitoring and all the alarms your heart could desire.

Just curious, if it is already ventilated adequately so it is a division 2 area, and you add gas detectors, are you saying that changes it back to a division 1 area? That seems counterintuitive to me.
 

rbalex

Moderator
Staff member
Location
Mission Viejo, CA
Occupation
Professional Electrical Engineer
Just curious, if it is already ventilated adequately so it is a division 2 area, and you add gas detectors, are you saying that changes it back to a division 1 area? That seems counterintuitive to me.
No, I said if that is what they are going to rely on. Technically, Section 500.7(K)(1) couldn't apply otherwise.
 
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