An In-Depth Look At NFPA Requirements
(unabridged version)

By Jim Rocco

I recently attended a meeting of the National Fire Protection Association (NFPA) Technical Committee on Automotive and Marine Service Stations to begin the next revision cycle for the NFPA 30A Code for Motor Fuel Dispensing Facilities and Repair Garages. At the meeting, issues were raised concerning the clarity of the electrical disconnect requirements of NFPA 30A and the extent to which these requirements were actually implemented at existing motor fuel dispensing facilities. As I thought about this discussion and had further discussions with contractors, suppliers and marketers, it became apparent to me that there are uncertainties and inconsistencies in the implementation of these requirements. These concerns raise questions about whether modification or further clarification of the electrical disconnect provisions of the code is needed.

NFPA 30A provides requirements for both emergency electrical disconnects and maintenance electrical disconnects. Most of the contractors, suppliers and marketers I have spoken with agreed that there are two basic reasons, from the perspective of NFPA 30A, for electrical disconnects:

1. To discontinue or prohibit the flow of motor fuel to the dispensers, and
2. To eliminate potential ignition sources.

Unfortunately, there was not agreement on what electrical circuits are controlled by either existing emergency electrical disconnects or maintenance electrical disconnects, nor what electrical circuits should be controlled by these electrical disconnects. While these provisions are generally written to address the electrical installation of dispensing systems, in order to accomplish some of the issues raised concerning the electrical disconnects, changes in the design of the dispensers may be necessary. This could also apply to the intercom systems and other ancillary devices.

The purpose of this article is to provide information on the electrical disconnect provisions of NFPA 30A, raise the issues that need to be addressed and solicit help in finding possible solutions that can be incorporated into the next revision of NFPA 30A.

Emergency Electrical Disconnects
The concept of an emergency electrical disconnect at a motor fuel dispensing facility is simple: to provide a switch in an accessible location, remote from the dispensers, that disconnects the power to the dispensers in the event of an emergency. The location of the emergency electrical disconnect, commonly referred to as the emergency shutoff, can vary based on the facility configuration and the authority having jurisdiction. However, it is generally located either within the building accessible by a facility attendant, at a location remote from the dispenser accessible to a customer, or a combination of the two. The current (eighth) edition of NFPA 30A (NFPA 30A-2008) provides in Section 6.7 that:

In addition to disconnecting the power to the dispensers and remote pumps, this provision requires that the power be disconnected to “all associated power, control and signal circuits.” This portion of the provision was added in the 6^th edition of NFPA 30A (NFPA 30A-2000) which provided a significant rewrite and reorganization of the code. By 2000, credit card readers, cash acceptors, intercoms and containment sump monitoring devices had become integral parts of the dispenser or contained in other devices on the islands adjacent to or under the dispensers. With these devices came additional circuits not only related to power, but also related to communication and data transfer. In some cases, data circuits such as telephone lines and communication cables are added to the dispenser, particularly in cases where a dispenser is used as a stand-alone point of sale device. It is these components and the more recent addition of video displays and Internet-accessible monitors that have generated the uncertainty and inconsistency that I spoke of earlier. Some of these components may require an uninterrupted circuit between the dispenser and its control source or transmission point where relays or other methods of disconnecting the circuit could interfere with proper operation of the device. While some of these circuits may be intrinsically safe, not all are. It is also unclear in this provision whether the actual power to these power, control and signal circuits needs to be disconnected or whether the circuit to the dispenser can be disconnected.

In a recent survey conducted by PEI concerning emergency shutoff devices, respondents were split 50/50 on whether existing emergency electrical disconnects are thought to meet the requirements of Section 6.7 of NFPA 30A-2008. All responses identified the AC circuits including lighting and dispenser power and remote pumping controls and DC circuits for dispenser control as circuits that were part of the emergency electrical disconnect. Intercom and other data-related circuits were typically not identified separately. However, I believe that many respondents include some of the data circuits within their definition of dispenser controls. The real questions seem to be the inclusion of intercom circuits and data circuits, whether these circuits are included in the scope of the emergency electrical disconnect requirements as “associated power, control and signal circuits,” whether the circuit can be disconnected between the dispenser and the control, or whether the power to the control itself needs to be disconnected.

This leads me to question the current language associated with the emergency electrical disconnects. Does it adequately describe the electrical circuits that should be disconnected to meet the requirements of discontinuing or prohibiting the flow of motor fuel and eliminate ignition sources? Have the devices and accessories included on today’s dispenser islands evolved beyond the original scope of this provision? If it does not adequately describe the requirements, what revisions should be made? What is included in “all associated power, control and signal circuits” and “all other electrical equipment”? Are there any circuits, in addition to intrinsically safe circuits, that should be specifically excluded from these requirements? It also raises a technical question: If additional disconnects should be implemented, technically how would that be accomplished? Is it important or necessary to disconnect any neutral lines associated with the power to the dispenser and controls to address potential feedback issues?

In earlier versions of NFPA 30A a distinction was made between attended and unattended self-service stations for purposes of the location of the emergency electrical disconnect. While the actual location is subject to the approval of the authority having jurisdiction, attended self-service stations typically had the emergency electrical disconnect located in close proximity to the attendant. Unattended self-service stations had the disconnect located in close proximity to the customer. This distinction is no longer present in the current emergency electrical disconnect provisions. As a result, the location of the emergency electrical disconnect is not always straightforward. In addition, as newer facilities have become larger, the issue of how many disconnects should be installed and their location in light of the minimum and maximum distance requirements seems to require clarification. In many cases, multiple controls are needed to meet the distance requirement where a dispenser at one end of the canopy is more than 100 feet from a dispenser at the other end of the canopy. Should the provisions address specific locations of emergency electrical disconnects, such as in close proximity to an attendant or exterior to a building in close proximity to a customer? Should the separation distance be greater than 100 feet? Also, where fuel islands are remote from one another such as a facility with diesel fueling areas separate from automotive fueling areas, should a single electrical disconnect be provided to disconnect power to multiple fueling areas if there is an emergency on one of them?

Maintenance Electrical Disconnects
The maintenance electrical disconnect is intended to disconnect the power to an individual dispenser or group of dispensers during maintenance activities to those dispensers. The maintenance electrical disconnect is generally in the back room of a facility and accessible only to employees or service contractors. This should not be confused with other requirements for electrical disconnects such as OSHA lockout/tagout or electrical code dispenser isolation, although there are substantial similarities among these requirements. The current edition of NFPA 30A (NFPA 30A-2008) provides in Section 6.3.6(2) that:

This provision has not changed significantly since it was initially introduced in the third edition of NFPA 30A (NFPA 30A-1990) with the exception of the inclusion of “all associated control circuits” in the fourth edition of NFPA 30A (NFPA 30A-1993). As with the emergency electrical disconnect, there seems to be considerable differences of opinion on what power should be disconnected, how that power should be disconnected, and when it should be disconnected. Some service contractors I have spoken with indicated that disconnecting the electrical power as described in this provision can only be done at some facilities by essentially shutting down the entire fueling operation.

As I have discussed this issue with others, a number of questions have been raised. First, the applicability of the provision can be interpreted very broadly as it relates to activities that may cause “an accidental release or ignition source.” Is the intent to ensure that the flow of motor fuel through a dispenser cannot occur while working on a dispenser, or is it also intended to include elimination of all potential ignition sources while working on a dispenser? What are the activities that may cause “an accidental release or ignition source”? Clearly working on the piping within or connected to the dispenser would trigger this provision. It could also be triggered by replacing a hose, nozzle or filter, or replacing a circuit board in a dispenser. If so, how is this different from the electrical code dispenser isolation or OSHA lockout/tagout requirements? In addition, depending on how broadly this provision is interpreted, replacing a nozzle on a dispenser could require that all other dispensers associated with a remote pumping system be taken out of service, since the provision requires the power to be disconnected to the “pump serving the dispensing device.”

The requirement for disconnecting the power at the main electrical disconnect panel seems to be a reference to the circuit breakers in the electrical panel. As I understand it, most isolation controls for dispensers are a group of relays between the main electrical disconnect panel and the dispenser. The use of circuit breakers to disconnect power may essentially provide the same result as an emergency stop, since it may be unrealistic in larger facilities to provide a sufficient number of breakers to individually isolate dispensers or groups of dispensers. The use of relays or other isolation type controls to control groups or individual dispensers seems to be the most likely method for meeting these disconnect requirements. It is unclear whether this provision precludes the use of relays or other isolation type controls to control groups or individual dispensers. It is also important to note that disconnecting power would include disconnecting any neutral lines associated with the power to the dispenser and controls to address potential feedback issues.

As with the emergency electrical disconnect, the extent of “all associated control circuits” is unclear. Does this refer only to controls that could authorize flow of product such as the point of sale device? Or is it intended to more broadly disconnect ancillary devices such as electronic line leak detectors that interact with the remote pumping systems, or credit card readers or intercoms that are integrated into or adjacent to the dispenser? Is it intended to be as broad as the requirements under the Section 6.7 emergency electrical disconnect provisions or limited to primary circuits that control the flow of motor fuel?

As the NFPA Technical Committee on Automotive and Marine Services Stations moves through the next revision cycle for NFPA 30A, the issues raised in this article need to be addressed. The key issues for both the emergency electrical disconnect and the maintenance electrical disconnect are whether existing installations comply or can realistically comply with the electrical disconnect provisions of NFPA 30A-2008 and what changes are needed to better describe the requirements. It is also important for the committee to understand the complexities of complying with these requirements and the potential alternatives, as well as the interaction similarities and differences between the electrical disconnect and dispenser isolation and lockout/tagout provisions of other codes. To that extent, comments and recommendations will be greatly appreciated. Bob Benedetti, NFPA’s principal flammable liquids engineer, has volunteered to collect and summarize comments for the committee. You can submit comments to Bob via e-mail at bbenedetti@nfpa.org.

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The PEI Journal • First Quarter 2009 • Volume 3, No. 1 • Contents are Copyright © Data Key Communications, Inc.
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