|Safety vs. Energy Efficiency
Help Us Justify Exemptions to ASHRAE 90.1 Requirements!
|With increasing emphasis on energy efficiency by State Regulators, growing numbers of OEMs, Engineering Firms and End Users are caught up in a desperate struggle. Overlooking or not being able to apply a 90.1 Scope provision, State Regulators are often requiring that Industrial HVAC Systems achieve mandated energy efficiency ratings, which can compromise compliance with NFPA 496 requirements or API 500 recommendations, and limit abilities to ensure the safety of facilities and protect refinery and chemical plant workers!
Your comments justifying exemptions to ANSI/ASHRAE Standard 90.1 energy efficiency requirements for applications such as pressurized and ventilated spaces are therefore urgently needed by June 22nd, for presentation to ASHRAE TC 9.2 - The Industrial Air Conditioning and Ventilation Technical Committee!
The issue of safety versus energy efficiency was first presented to SSPC 90.1 (the Standing Standard Project Committee for ASHRAE 90.1) 10 years ago at their 2009 Spring Meeting in Louisville, Kentucky. The presentation was made by Mr. Mike Baucom, then CEO of Bebco Industries, Incorporated. At that time, he was acting as representative of Technical Committee TC 5.8 for Industrial Ventilation, as co-sponsored by Technical Committee TC 9.2 for Industrial Air Conditioning, and as the Chairman of the TC 5.8 Subcommittee for the Ventilation of Hazardous Spaces.
He proposed ASHRAE Standard 90.1 Scope amendments to exempt Ventilation and HVAC equipment critical to the life-safety and protection of commercial and industrial manufacturing or processing spaces. Additionally, he proposed exemptions to Ventilation, Blower and HVAC equipment utilized within commercial and industrial manufacturing or processing operations.
Based on his recommendations, SSPC 90.1 added Section 2.4 to the 90.1 Scope, that actually expanded upon his recommendation, to ensure a comprehensive exemption. As written, Section 2.4 reads “This standard shall not be used to circumvent any safety, health, or environmental requirements.”
For those professionals who design and engineer Industrial HVAC equipment for use in Hazardous Spaces, this statement is correctly interpreted to exempt buildings and rooms protected by requirements of NFPA Standard 496 or the recommended practices of API RP 500.
However, in recent years many State Regulators at both Administrative Levels and Field Inspection Service Levels have repeatedly ruled against taking any specific exception to the application of ASHRAE 90.1 requirements, even if they conflict with the aforementioned NFPA or API pressurization, dilution or ventilation protection methods.
As a result, the integrity of buildings located within NEC (National Electric Code) Article 500 Hazardous (Classified) Areas that house metering equipment, process control analyzers and similar instrumentation is being compromised.
Essentially, this means some State Regulators are inadvertently or unknowingly placing an overriding emphasis on energy efficiency, as opposed to life safety. This emphasis is manifested as a strict interpretation and enforcement of ASHARE 90.1 requirements on Modular Building Manufacturers, Engineering Firms and End Users. It’s therefore clear that actions to supplement the initial efforts of ASHRAE SSPC 90.1 to add Section 2.4 is essential and of vital importance to life safety.
Additionally, another issue has come to light as State Regulators apply strict interpretation and enforcement of ASHARE 90.1 requirements for energy efficiency at Industrial Sites. This issue focuses around buildings that contain excessive heat sources, such as those generated by massive variable frequency drives (VFDs) and other power regulating and switching equipment that typically controls large motors, pumps and other equipment essential to the operation of refineries and remote pipeline compressor stations.
As power industry experts will confirm, this equipment requires significant volumes of ventilation and highly specialized HVAC equipment to ensure proper operation and prevent critical failure. It should be noted that while a limited number of HVAC equipment manufacturers have managed to meet current energy efficiency requirements for these unique applications, the more stringent energy efficiency requirements now pending will render their designs obsolete and ineffective within the coming year, further compounding the problem.
Simply stated, ASHRAE and State Regulator efforts to lead our Nations’ goals to attain maximum energy efficiency is noble and worthwhile. However, energy efficiency requirements should not take precedence in regard to our industrial workforce and highly essential equipment when they must both be protected by high volumes of air flow to prevent loss of life or critical equipment damage. Therefore, Mike Baucom, now acting as the CEO of Bebco Environmental Controls Corporation is leading an effort to rectify this dilemma. His goal is to persuade SSPC 90.1 to notify State Code Enforcement Regulators to recognize Section 2.4 as an exemption; and to permit requirements of NFPA 496 and recommendations of API 500 to take precedence over ASHRAE Standard 90.1 requirements. Furthermore, he is asking that SSPC 90.1 notify State Agencies to exempt enforcement of ASHRAE 90.1 requirements for buildings featuring extremely high heat loads.
He will begin efforts by presenting these concerns to ASHRAE’s recently merged Technical Committee 9.2 for Industrial Air Conditioning & Ventilation, as a current member in good standing, at the Spring 2019 Meeting in Kansas City on June 25th. Their endorsement will provide him with critical support for SSPC 90.1 to carefully consider before rendering a decision.
He is urgently requesting support for his TC 9.2 presentation in the form of comments or case study papers limited to one page each. Specifically, the submission should detail issues encountered with State Regulators in regard to their enforcement of ASHRAE 90.1 Standards. These issues should be limited to your inability to meet NFPA 496 requirements or API 500 recommendations, or any issues you could not resolve in regard to providing adequate temperature regulation in buildings with extremely high heat loads.
He believes the most effective results will be achieved if the SSPC 90.1 Chairman issues a publicly published clarification document to all State Regulatory Agencies. He proposes that the document clearly state that Buildings or Rooms protected by NFPA 496 requirements or API 500 recommendations are exempt from ASHRAE 90.1 energy efficiency requirements. He hopes the Chairman and his Committee Members may also be convinced by your supporting papers that buildings with excessive heat loads should also be exempted from ASHRAE 90.1 requirements; and the Chairman will then also elect to include that supplemental exemption in the document.
Given the delicate but significant nature of this issue, he asks that your comments be respectful of the original SSPC 90.1 efforts to address the issue by adding Section 2.4. He also asks that you respect the constraints faced by State Regulators, who are being held accountable to uphold a strict interpretation of ASHRAE 90.1, and therefore have no authority to apply Section 2.4 as a compliance exemption.
To submit your comments and participate in the resolution of this critical issue, please use the form submission button below, or send your comments directly to him at firstname.lastname@example.org.