Excess Flow Valves and the International Fire Code (IFC)

This is my last article in my series regarding excess flow valves. I haveattempted to explain how these devices can aid in controlling a significant leak, as well as how these valves get abused in their design and maintenance. As I have stated before, these valves should NOT be considered a “safeguard” in our PHA’s until we have their design, operation, and maintenance under control. But through all of these articles, the one question I seem to get after each posting is… “Are these EFVs required?” The short answer is YES, but it depends on where the facility is located and which RAGAGEP the facility may be utilizing. I will use the International Fire Code as my basis to demonstrate that Excess Flow Valves are a DESIGN REQUIREMENT for many PSM/RMP covered processes.

International Fire Code (2012)

Chapter 50 – Hazardous Materials-General Provisions

SECTION 5003 GENERAL REQUIREMENTS

5003.2 Systems, equipment and processes.

Systems, equipment, and processes utilized for storage dispensing, use or handling of hazardous materials shall be in accordance with Sections 5003.2.1 through 5003.2.8.

5003.2.1 Design and construction of containers, cylinders, and tanks.

Containers, cylinders, and tanks shall be designed and constructed in accordance with approved standards. Containers, cylinders, tanks and other means used for containment of hazardous materials shall be of an approved type. Pressure vessels shall comply with the ASME Boiler and Pressure Vessel Code.

5003.2.2 Piping, tubing, valves and fittings.

Piping, tubing, valves, and fittings conveying hazardous materials shall be designed and installed in accordance with ASME B31 or other approved standards, and shall be in accordance with Sections 5003.2.2.1 and 5003.2.2.2.

5003.2.2.1 Design and construction.

Piping, tubing, valves, fittings and related components used for hazardous materials shall be in accordance with the following:

1. Piping, tubing, valves, fittings and related components shall be designed and fabricated from materials that are compatible with the material to be contained and shall be of adequate strength and durability to withstand the pressure, structural and seismic stress and exposure to which they are subject.

2. Piping and tubing shall be identified in accordance with ASME A13.1 to indicate the material conveyed.

3. Readily accessible manual valves or automatic remotely activated fail-safe emergency shutoff valves shall be installed on supply piping and tubing at the following locations:

3.1. The point of use.
3.2. The tank, cylinder or bulk source.

4. Manual emergency shutoff valves and controls for remotely activated emergency shutoff valves shall be identified and the location shall be clearly visible, accessible and indicated by means of a sign.

5. Backflow prevention or check valves shall be provided when the backflow of hazardous materials could create a hazardous condition or cause the unauthorized discharge of hazardous materials.

6. Where gasses or liquids having a hazard ranking of:

Health Class 3 or 4
Flammability Class 4
Instability Class 3 or 4

in accordance with NFPA 704 are carried in pressurized piping above 15 pounds per square inch gauge (PSIG) (103 kPa), an approved means of leak detection and emergency shutoff or excess flow control shall be provided. Where the piping originates from within a hazardous material storage room or area, the excess flow control shall be located within the storage room or area. Where the piping originates from a bulk source, the excess flow control shall be located as close to the bulk source as practical.

Exceptions:

1. Piping for inlet connections designed to prevent backflow.

2. Piping for pressure relief devices.

So as we can see the 2012 IFC does require the use of EITHER (emphasis added by me)

“an approved means of leak detection AND emergency shutoff or
excess flow control …”

The code goes on to say where this excess flow control MUST be located when used in lieu of the approved means of leak detection AND emergency shutoff…

the excess flow control shall be located within the storage room or area. Where the piping originates from a bulk source, the excess flow control shall be located as close to the bulk source as practical.

I should point out that if theexcess flow control option is NOT used, then the code requires BOTHan approved means of leak detection AND emergency shutoff.

We see this type design most often in mechanical refrigeration processes, where they have ammonia detectors in the engine room as well as those detectors are tied into emergency shutdown systems once the ammonia reaches a prescribed concentration in the engine room. These automatic ESDs are also on top of the MANUAL ESDs that are located outside each engine room door as required by the two (2) most recognized RAGAGEP for these processes. These ESDs CLOSE the “king valve” on the process which is often times the main liquid feed valve to the evaporators in the refrigerated spaces. With these “approved means of leak detection and emergency shutoff” systems in place, the process is NOT required to have excess flow valves… or are they?

One of the more common design flaws we come across is that ALL the “safety design” is centered around the bulk handling/storage areas. When asked “what happens when the 1.5″ pipe carrying XYZ hazardous material ruptures within the manufacturing area?” we tend to get a much different answer. The answer usually centers around their chosen PSM/RMP RAGAGEP not requiring this design; hence the purpose of this article.

It may be a true statement that their chosen RAGAGEP does not require such a design; however, a State adopted code will TRUMP any chosen RAGAGEP and PSM requirement(s) as these codes are a BASELINE design (i.e. minimum design) and PSM/RMP RAGAGEPs are meant to compliment these baseline designs. We’d have to ask a lawyer if your facility could be cited under PSM* for not meeting a state adopted code (e.g. OSHA referencing the state code as a RAGAGEP); but from a safety engineering perspective ANYWHERE and EVERYWHERE the “animal can get out of its cage” is an area that we need to ensure proper DESIGN of our process. Choosing to meet the IFC will add another layer of protection to our already robust PSM/RMP safeguards. And in some cases, these approved means of leak detection and emergency shutoff or excess flow control devices may be a start to getting those areas outside our bulk storage/handling areas into compliance and raising the bar for hazardous materials safety.

* PLEASE NOTE: Many hazardous material thresholds found in the IFC are considerably LESS THAN OSHA’s and EPA’s PSM/RMP thresholds. This means that although the “process” may not exceed OSHA/EPA PSM/RMP thresholds, they very well may exceed the IFC thresholds – thus making these requirements a necessity. EPA has referenced state/international codes in RMP General Duty Clause Citations and these state codes are almost always enforced by the state fire marshals (or some other state agency). These requirements should be viewed as the absolute BARE MINIMUM for “any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or a combination of these activities“.

So is an EFV a requirement? In my opinion, they are a baseline requirement for hazardous materials when the business does not want to invest in an approved means of leak detection AND emergency shutoff.

My other EFV articles:

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