Navigating the Maze:
Fire & Health Hazard
Regulations and Standards
for LFG/Biogas Facilities
Chris T. Lawn, P.E.
“The Maze”
• Regulations & Standards
• Numerous agencies & organizations
• Not tailored to LFG or Biogas
• Often misunderstood, misinterpreted, or neglected
• Liability concerns for designers, contractors and owners
PG&E Natural Gas Pipeline Explosion
San Bruno, CA
September 10, 2010
Regulations
FEDERAL
• United States Code of Federal Regulations (CFR)
• Administration and Enforcement by Agencies (EPA, OSHA, etc.)
STATE / LOCAL UNITS OF GOVERNMENT
• May have own rules/ordinances
• Sometimes administer/enforce Federal regulations
Standards
TRADE ASSOCIATIONS
• Develop / maintain technical standards & consensus codes
• International Building Code (IBC) is a standard that incorporates by reference many
other standards
STATES
• Generally adopt IBC
• Stand alone or State building code
LOCAL UNITS OF GOVERNMENT
• Generally adopt IBC of State version
• Provide plan review & enforcement
Applicability
WHAT MUST BE EXAMINED?
• Design/Operating Conditions (pressures, temperatures, etc.)
• Service Type (storage, fuel supply, etc.)
• Location (building occupancy types, proximity to other land uses, public rights-ofway, etc.)
• Size (quantity of material)
GENERAL DUTY CLAUSE
• Any facility producing, processing, handling, or storing regulated and other
hazardous substances
• More on this later…
Just because a regulation or standard may not apply to a
facility, does not mean these should be completely ignored…
WHY?
Standard of Care
(noun) the watchfulness, attention, caution and prudence that
a reasonable person in the circumstances would exercise.
• Failure to meet the standard of care is negligence
• Damages may be claimed in a lawsuit by the injured party
HOWEVER…
• The “standard” is a subjective issue upon which reasonable people can differ!
Source: law.com
LFG and Biogas
CHALLENGE:
• Most (if not all) applicable regulations and standards were written for the natural
gas industry
HOWEVER…
• Methane is an explosive gas
• Other compounds (e.g. H2S) can be harmful to human health
Regulations
Federal:
Three agencies administer regulations applicable to LFG/Biogas facilities:
• Each has enforcement power
• Citations for noncompliance could be issued by 1 or all 3 agencies
Regulations
Federal: USDOT
Pipeline and Hazardous Materials Safety Administration (PHMSA)
Administers:
 Pipeline Safety Regulations: 49 CFR Parts 190-199
 Hazardous Materials Transportation Regulations: 49 CFR Parts 171-177
 Shipment of Dangerous Goods (not covered in this presentation)
Regulations
Federal: USDOT: PHMSA
49 CFR Part 192 Transportation of Natural and Other Gas by Pipeline: Minimum
Federal Safety Standards
APPLICABILITY TO BIOGAS/LFG
 Transportation of Gas
 “gathering, transmission, or distribution of gas by pipeline or the storage
of gas, in or affecting interstate commerce”
 Gas = natural gas, flammable gas, or gas which is toxic or corrosive
GENERAL REQUIREMENTS
 Materials
 Pipe Design
 Design of Pipeline Components
 Welding of Steel in Pipelines
Regulations
Federal: USDOT: PHMSA
49 CFR Part 192 Transportation of Natural and Other Gas by Pipeline: Minimum
Federal Safety Standards
GENERAL REQUIREMENTS, CON’T
 Joining of Materials Other Than by Welding
 General Construction Requirements for Transmission Lines and Mains
 Customer Meters, Service Regulators, and Service Lines
 Test Requirements
 Uprating
 Operations
 Maintenance
 Qualification of Pipeline Personnel
 Gas Transmission/Distribution Pipeline
Integrity Management (IM)
Regulations
Federal: USDOT: PHMSA
49 CFR Part 192 Transportation of Natural and Other Gas by Pipeline: Minimum
Federal Safety Standards
TYPES OF PIPELINES
 Distribution
 Gathering
 Transmission
EXCLUSIONS
 Onshore “gathering” at less than 0 psig
 “Miscellaneous Group U”
 “Group H” (High Hazard)
Regulations
Federal: USEPA
40 CFR Part 68 Chemical Accident Prevention Provisions
THRESHOLD QUANTITY OF A REGULATED SUSBSTANCE
 Methane = 10,000 lbs
 @ 68F / 1 atm ≈ 480,000 ft3 of LFG (610,000 LF of 12”)
 @ 80F / 100 psig ≈ 63,000 ft3 of LFG (80,000 LF of 12”)
REQUIREMENTS
 Hazard Assessment
 Prevention Program
 Emergency Response
 Risk Management Plan (RMP)
Regulations
Federal: OSHA
29 CFR Part 1910 Occupational Safety and Health Standards
Subpart H – Hazardous Materials
SECTION 1910.110 – Process Safety Management of Highly Hazardous Chemicals
 Prevent or minimize the consequences of catastrophic releases of toxic,
reactive, flammable, or explosive chemicals
Section 1910.120 – Hazardous Waste Operations and Emergency Response
 Regulate employee exposure to safety or health hazards
Regulations
Federal: OSHA: PSM
29 CFR Part 1910.110 Process Safety Management of Highly Hazardous Chemicals
APPLICABILITY TO BIOGAS/LFG
 Process involving “Category 1 flammable gas”
GENERAL REQUIREMENTS
 Employee Participation
 Process Safety Information
 Process Hazard Analysis (PHA)
 Operating Procedures
 Training
 Contractors
Regulations
Federal: OSHA: PSM
29 CFR Part 1910.110 Process Safety Management of Highly Hazardous Chemicals
GENERAL REQUIREMENTS, CON’T
 Pre-Startup Safety Review
 Mechanical Integrity
 Hot Work Permit
 Management of Change
 Incident Investigation
 Emergency Planning and Response
 Compliance Audits
 Trade Secrets
Regulations
Federal: OSHA: HAZWOPER
29 CFR Part 1910.120 Hazardous Waste Operations and Emergency Response
APPLICABILITY TO BIOGAS/LFG
 Emergency response operations for releases of, or substantial threats of
releases of, hazardous substances…
GENERAL REQUIREMENTS
 Safety and Health Program
 Site Characterization and Analysis
 Site Control
 Training
 Medical Surveillance
Regulations
Federal: OSHA: HAZWOPER
29 CFR Part 1910.120 Hazardous Waste Operations and Emergency Response
GENERAL REQUIREMENTS, CON’T
 Engineering Controls, Work Practices, and Personal Protective Equipment for
Employee Protection
 Monitoring
 Informational Programs
 Handling Drums and Containers
 Decontamination
 Emergency Response by Employees at Uncontrolled Hazardous Waste Sites
 Illumination
 Sanitation at Temporary Workplaces
Regulations
Federal: OSHA: HAZWOPER
29 CFR Part 1910.120 Hazardous Waste Operations and Emergency Response
GENERAL REQUIREMENTS, CON’T
 New Technology Programs
 Certain Operations Conducted Under CERCLA
 Emergency Response to Hazardous Releases
Regulations
State and Local:
Must be as stringent as Federal regulations, but may be more stringent in some cases
Regulations
General Duty Clause
• Appears in both EPA and OSHA regulations
 OSHA Act of 1970
 “Each employer shall furnish each of his employees employment and a
place of employment which are free from recognized hazards that are
causing or are likely to cause death or serious physical harm to his
employees”
 Clean Air Act Amendments of 1990
 “The owners and operators of stationary sources producing, processing,
handling or storing such substances […] have a general duty […] to
identify hazards which may result from (such) releases using appropriate
hazard assessment techniques, to design and maintain a safe facility
taking such steps as are necessary to prevent releases, and to minimize
the consequences of accidental releases which do occur”
Standards
Two organizations maintain standards applicable to LFG/Biogas facilities:
International Code Council (ICC)
Mission: “to reduce the worldwide burden of fire and other hazards on the quality of
life by providing and advocating consensus codes and standards, research, training,
and education”
National Fire Protection Association (NFPA)
Mission: “to provide the highest quality codes, standards, products and services for all
concerned with the safety and performance of the built environment.”
Standards
Authority Having Jurisdiction “AHJ”
Any federal, state, local, regional or other organization having statutory authority to
regulate construction or approve equipment, materials, installation or a procedure
Standards
International Code Council (ICC)
International Fire Code (IFC)
International Fuel Gas Code (IFGC)
Regulations to safeguard life and property
from fire and explosion hazards
Addresses the design and installation of
fuel gas systems and gas-fired appliances
through requirements that emphasize
performance
Standards
ICC: IFC
• Published every 3 years (2012 is current version)
• Covers a wide range of situations concerning:
 Fire
 Life
 Property
• Requirements Vary According to IBC Occupancy Classification
 LFG/Biogas Facilities:
 Factory Industrial
 “Group F”
 “Miscellaneous Group U”
 “Group H” (High Hazard)
• AHJ may have final say on Occupancy Classification
Standards
ICC: IFC
Types of Requirements Contained in IFC:
•
Fire Protection
•
Fire Department Access
•
Construction Safety Measures
•
Mechanical Refrigeration
 Additional Requirements in International Mechanical Code (IMC)
•
Compressed/Flammable Gas Storage & Handling
•
Fuel Dispensing
Standards
ICC: IFGC
• Published every 3 years (2012 is current version)
• Covers:
 Fuel Gas Piping ≤ 125 psig Operating Pressure
 Appliances, equipment, related accessories
• Exceptions include:
 “Pipeline Compressor Stations”
 “Natural Gas Processing Plants”
• AHJ may have final say on applicability
• Code cites good design, construction & operation practices, including:
 Pipe Sizing Criteria
 Pipe Construction Standards
 Equipment & Accessories
Standards
NFPA:
NFPA 52: Vehicular Gaseous Fuel Systems Code
NFPA 54: National Fuel Gas Code
NFPA 56 (PS): Cleaning & Purging of Flammable Gas Piping Systems
NFPA 70: National Electrical Code (NEC)
Standards
NFPA: NFPA 52
• Published every 4 years (2010 is current version)
• Covers:
 CNG & LNG Engines
 Storage & Dispensing Systems
• Processing Equipment requirements, including:
 Storage location, ventilation & access
 Emergency shutdowns & other safety precautions
• Dispensing Equipment requirements, including:
 Valves, fill stops, overpressure protection
 Bleed connections, flow rate requirements
 Specific to Residential & Non-Residential
Standards
NFPA: NFPA 54
• Published every 3 years (2012 is current version)
• Closely resembles IFGC in scope & applicability
• 2012 version expanded on pipe purging requirements
 Details in NFPA 56 (PS)
Standards
NFPA: NFPA 56 (PS)
• New Provisional Standard issued August 2011
• Covers:
 Purging into and out of service
 Pipe cleaning, repair, replacement and removal procedures
• Applies to:
 New and existing flammable gas piping
 Industrial, institutional, commercial
• Specific Applicability:
 From the Point of Delivery (discharge isolation valve for the gas producing
equipment)
 To the Gas Consuming Equipment
 Vacuum or Pressure
Standards
NFPA: NFPA 70 (NEC)
• Published every 3 years (2011 is current version)
• Covers:
 All electric aspects of building construction
• Requirements include:
 Construction/Installation of:
 Wiring
 Grounding
 Equipment
 Enclosure Types (NEMA Standards)
• Design/Construction of Classified or Hazardous Locations
 Specific Requirements in NFPA 497
 Directed right at LFG/Biogas facilities
Standards
NFPA: NFPA 70 (NEC)
NFPA 497: Recommended Practice for the Classification of Flammable Liquids, Gases
or Vapors and of Hazardous (Classified) Locations for Electrical Installations in
Chemical Process Areas
Standards
NFPA: NFPA 70 (NEC)
ELECTRICAL ENCLOSURE NUMBERING SYSTEM (“TYPES”)
• Indoor / Outdoor Locations
• Hazardous / Non-Hazardous Locations
• Other Protections
 Corrosive Agents
 Oil and Coolant Seepage / Splashing
 Circulating / Settling Dust, Lint, Fibers, and Flyings
THANK YOU!
Navigating the Maze:
Fire & Health Hazard
Regulations and Standards
for LFG/Biogas Facilities
Chris T. Lawn, P.E.