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Highly ~,,,~i~
{)xidizcr.
(ol-ro>i\,..
Asphyxia**~
('arcinogemt
Radioactive.
With m a n y hax, illg tin,re than one of these hazards. With
the exception of Oxidizer ~tnd Radioactive, the ERCVs by
Solkatronic Chemicals Inc. can be used to safely con,am
all of these. Once contained in the ERCVs, the t,iS DOT
Exemptions g10323 for Model #5501 and #105t)4 for
Model #5502 allow these to be sent back to the gas
supplier or to a disposal c~mlpany via a contracted carrier
o r compan} Iruck f~,!-c~m~rolled leak mitigation
IIiiiiii iiiiiiiiill
Hydride Gases (ASH3, PH3),
Risk analysis Pyrophoric Gases (Sill4, B2Ho),
On the surface, these requirements appear to be realistic Oxidizing Gases (NO, NO2).
and will be of great value in minimizing public exposure to because they require different scrubbing solutions and/or
Haz Mat leaks. A risk analysis would reveal, however, that methods. It then must switch on the appropriate devices in
the requirements are justified only for manufacturing and a matter of seconds. If separate scrubbers are used for
use. These are the only times that the cylinder valve will be each, the capital and maintenance cost will be a severe
open, the cylinder cap removed and the vapor tight cap/ burden. More importantly, the installed systems can lead
plug removed. In this position, the valve is wide open and to a false sense of security since they may not work when it
failure of any one of the many pipe connections or is needed since all of the systems will require routine testing
components in a piping system from the cylinder to the and maintenance.
process could release significant quantities of gas. A gas cylinder would have 3-4 potential leak points, all
Statistically, the odds of a leak happening is increased of which in storage would be of a very low flow rate since
with the addition of more fittings or components. Article the cylinder valve is not open.
80 attempts to minimize the probability and impact of In the absence of the external events described earlier,
these events by requiring: the potential leaks are as follows:
Ventilated Enclosures, • A leak through the vapor-tight cap or plug would
Welded or other Approved Connections, require both the valve seat to be loose or damaged and
Coaxial Tubing for long runs, the vapor-tight cap or plug to be loose. It is unlikely that
Emergency Shut-off Valves, both could become fully loosened for a large leak to
Gas Detection, occur with the cylinder cap on.
Gas Treatment Systems. • For a packed valve, a leak could occur at the stem but,
again, this would also require the valve seat to be loose
Leaks or damaged.
• For valves with a pressure-relief device, a small leak
An informal review of gas industry data on leaks support
could occur through the threads if it is damaged or not
the conclusion that leaks, if they are to occur, happen
installed properly.
primarily in manufacturing and use. The remaining
• A thread leaker could develop at the valve threads into
incidents are almost all transportation incidents in which
the cylinder. A large leak could only occur if the valve is
cylinders have been violently tossed around because they
damaged or not properly installed. It is unlikely that this
were not properly secured or from vehicular accidents or
would go undetected in the filling process. The more
fires.
common event is a small leak ( < 10 cc/min.).
For many gas storage facilities at user and supplier sites,
All of these potential leaks would be detected immediately
the requirements for emergency scrubbing and power is
by the gas detection system required by the codes. The site
overkill for the potential risk. Of all the incidents, gas
ER Team would then use an ERCV to contain the leaking
storage accounts for < 1%. and these are generally small in
cylinder for shipment back to the supplier or disposal
nature. The catastrophic failure envisioned by Article 80 is
company for final leak mitigation procedures. If it is at a
an unlikely event without a severe external event such as a
gas supplier site, this would buy valuable time in setting up
fire or explosion. In either of these events, the scrubber
controlled disposal. This would be more effective than
would be rendered useless. The Washington State Article
having emergency scrubbers, cabinet and power in a
80 study group in 1989 also viewed the requirements to be
storage area.
costly and impractical.
Many of the Fire Codes are beginning to recognize this
For small storage facilities (typical electronic fab), the
alternative. The State of Oregon, during the adoption of
scrubbing system will become very complex if a variety of
Article 80 in 1989, added the exception (80.303.(a) 6.D.iv):
gases are stored. If only one scrubber is used, it must be
"Upon approval of the chief, it can be demonstrated that
capable of rapidly distinguishing between:
alternate means are capable of managing any release that
Alkaline Gases (NH3),
would not create an immediate threat to life or property"
Acid Gases (HC1, C12),
which would allow the substitution of ERCVs for
scrubbers.
Basic Building
More specifically, the Southern Building Code Congress
International in 1990 adopted the exception (408.4.2.7.2)
to the Southern Building Code:
"Cylinder containment device or system may be accepted
in lieu of the treatment system, for cylinder storage, when
approved by the Fire Official".
The State of Washington in adopting Article 80 added
the exception (80:303 (c) 3 B).
"A cabinet or exhausted enclosure need not be provided for
leaking cylinders if a US DOT approved cylinder contain-
ment vessel is provided."
In 1990 the Uniform Fire Code Committee of the
Western Fire Chiefs Association approved the following
Approximate areas of code influence exception to Article 80:(80.803 (c) 3 Special Provisions):
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<,] ~?
5'pecificaLions
DOT E x e m p h o n # [': 10504
>ff _. N<;,
Volume (without cylinder)
34 6 gallons (1:31 4 liters}
Width {overall) 28
Tube T u r n s
('a r bon Steel
Chain and S p r o c k e t DrF,'e
[)Hubie "O' Ring Seal
[nyqde Viton
Outside Bun~, N
~Ide vlc w
".., or approved containment vessels are provided that they cabinets or exhausted enclosures or where toxic gases are
are capable of fully containing a release". provided with:
In the July, 1991 meeting of the Western Fire Chiefs a. Approved containment devices that are capable of fully
Association, the following revision was approved for the containing a release are available at an approved location on
1991 Uniform Fire Code under 80.803 (c) 3 Special site.
Provisions: b. Trained personnel are available at an approved location on
E X C E P T I O N : A cabinet or exhausted enclosure need not site, and
be provided for leaking cylinders if all cylinders are stored c. Such containment devices are capable of being transported
within gas cabinets or exhausted enclosures, or if approved to the leaking cylinder.
containment vessels capable of fully containing a release and At the September, 1992, meeting, this was not approved:
trained personnel are available at an approved location. Such however, there were a number of challenges by members to
vessels shall be capable of being transported to the leaking adopt it. Areas of influence throughout the USA by the
cylinder locations. three model code associations are shown in the figure.
On March 27, 1991, the Santa Clara County Fire Chiefs The use of ERCVs is fast becoming recognized in the
Association Hazardous Materials Subcommittee adopted United States as being one of the important leak
consensus guidelines for the Toxic Gas Ordinance for containment devices available for compressed gases.
Section XI:
Encapsulating equipment designed to contain high-pres- Eugene Y. Ngai,
sure cylinders and their contents, as approved by the Fire VP Corporate Development Health, SaJety and Environment,
Chief, shall be acceptable in meeting the intent of providing a Solkatronic Chemicals lnc,
gas cabinet or exhausted enclosure for leaking gas cylinders. 30 Two Bridges Rd.,
At BOCA, the High Hazard Committee recommended Fai(/}eht,
the adoption of similar language in Article 23 Section F- NJ 07004-1530 USA.
2303.3.8.1 Exception 2: Telffhx: I l l (20])882 7900 / 7967.
A cabinet or exhausted enclosure is not required for
leaking cylinders where all cylinders are stored within gas