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Safety vs. Energy Efficiency

Meeting with TDLR Representatives &
consultation with high ranking ASHRAE Associates


Mike Baucom, CEO Bebco Environmental Controls CorporationOn July 29th, Mike Baucom met with Donna Lipke, the Managing Director, along with Crisi Cooper and Kelly Kelly at the TDLR Industrialized Housing and Buildings Program Compliance Division Headquarters in Austin, Texas.

Donna and her associates shed much light on many issues, include key methods that licensed manufactures should exercise to gain exceptions to compliance with code requirements, as follows:

1. TDLR offers Texas Building Manufacturers the option to comply either with ASHRAE 90.1 or the International Energy Conservation Code (IECC).

2. They offer no special or up-front exceptions to industrial building manufacturers, who must comply with the same standards as all other building manufacturers.

3. They were not aware of ASHRAE 90.1 Section 2.4, but did note awareness of a similarly worded Section C101.3 in the IECC.

4. All States are mandated by the Federal Government to enforce energy conservation standards.

5. They therefore do not issue exemptions without extremely well documented justifications, regardless of what a building contains or where it is located.

Donna also noted that if an industrial building manufacturer provides a written justification, the TDLR may grant an exemption to energy conservation requirements on a case-by-case basis. The justification must include a reason for exemption, fully supported by engineering plans and details. Manufacturers must also cite specific Sections of ASHRA 90.1 or the IECC, because the TDLR cannot accept any requests for total exemption.

Over the past 5 days, Mike has consulted with key members of ASHRAE, including Mr. Deep Gosh from Southern Company, Mr. Michael Rosenberg from Pacific Northwest National Laboratory and Mr. Jeremiah Williams from the Department of Energy (the DOE), and learned the following details:

1. It is plausible to request an interpretation of the Scope Exception under Section 2.4 of ASHRAE 90.1, but the Authority having Jurisdiction (such as the TDLR) is not necessarily bound by such interpretations.

2. The DOE does not provide the energy efficiency requirements to ASHRAE or ICC. Instead, the DOE participates in the industry led consensus process used by the model code development organizations ASHRAE and ICC. Therefore, DOE control of what gets into those codes is really no greater than any other participant.

Donna then reached back to Mike this week to first confirm that NFPA 30 was a recognized Code in the IBC and IFC, but that NFPA 496 was not referenced in either document.

Going forward, Mike will begin efforts to have the ICC, IBC and IFC recognize and reference NFPA 496 as a safety standard that must take president over energy efficiency requirements. He will also continue effort with various State Regulatory Officials, including Donna and her Associates at the TDLR, to learn more about what forms of disclosures will be required to receive compliance exemptions.

Please note Bebco Environmental Controls Corporation supports the efforts of both ASHRAE and all State Regulatory Agencies to ensure the safe and practical application of essential codes, standards, recommended practices and guides to ensure the safety, welfare and health of our industrial workforce community. Our support is manifested by Mr. Baucom's voluntary participation in NFPA, ISA and ASHRAE Technical Committees over the past 30 years. It is further manifested by Bebco's ongoing efforts to advise and educate clients in the proper interpretation and application of Codes and Standards, and our ongoing research and development efforts to produce practical serviceable products that meet or exceed all applicable requirements. This is all made possible by your ongoing support of our company, our many highly motivated associates and by the purchase and use of the uniquely advanced environmental control products we manufacture.

In conclusion, it is clear that the effort to gain recognition of safety requirements by the Building Code Authorities and State Regulatory Agencies, coupled with efforts by Manufacturers to properly document exemption requests are the keys to success.


To submit initial or follow-up comments and participate in the resolution of this critical issue, please use the form submission button below, or send your comments directly to Mr. Baucom at mikeb@exphvac.com.

Submit A Comment


IMPORTANT DISCLAIMER
Please note this issue is presented for your consideration by Bebco Environmental Controls Corporation,
in an independent effort to serve our clients in the best manner possible and contribute to the
overall health and safety of the industrial workforce here in the USA.

This article is not sponsored by ASHRAE and viewpoints as herein expressed do not reflect any official position of the ASHRAE Society.

 
Jobsites of the American Petro-Chemical Industry
Safety vs. Energy Efficiency

Update regarding efforts to address
ASHRAE 90.1 Compliance Issues


Mike Baucom, CEO Bebco Environmental Controls CorporationWe're very pleased to report progress regarding the ongoing issue of compliance to ASHRAE 90.1 Standard requirements, as first announced last month, prior to the ASHREA Annual Meeting in Kansas City.

Utilizing numerous responses we received regarding the certification of Industrial Buildings that are Pressurized in accordance with NFPA Standard 496, that are ventilated in accordance with the recommended practices of API RP 500 and that contain extremely high heat load producing equipment, our CEO, Mr. Mike Baucom voiced your concerns in the course of a 20 minute presentation to the ASHRAE TC 9.2 Industrial Air Conditioning and Ventilation Committee.

As a result, the Committee Chair and Members unanimously agreed to re-affirm Mr. Baucom as the TC 9.2 Liaison to ASHRAE SSPC 90.1 (the Standing Standard Project Committee for ASHRAE Standard 90.1). He will now therefore initial immediate efforts with the assistance of fellow TC 9.2 Committee Members to present your concerns to the Chairman and Members of SSPC 90.1!

He will also initiate efforts to meet with various State Regulatory Officials, beginning with Ms. Donna Lipke, the Managing Director of the Texas Department of Licensing and Regulation on July 29th. His primary goal will be to determine what form of disclosure, mandate or advisement will be required from ASHRAE to attain waivers to compliance to ASHRAE 90.1, so that the original intent of SSPC 90.1 can be fully recognized, as noted in their Scope under Section 2.4 which reads “This standard shall not be used to circumvent any safety, health, or environmental requirements.”

Please note Bebco Environmental Controls Corporation supports the efforts of both ASHRAE and all State Regulatory Agencies to ensure the safe and practical application of essential codes, standards, recommended practices and guides to ensure the safety, welfare and health of our industrial workforce community. Our support is manifested by Mr. Baucom's voluntary participation in NFPA, ISA and ASHRAE Technical Committees over the past 30 years. It is further manifested by Bebco's ongoing efforts to advise and educate clients in the proper interpretation and application of Codes and Standards, and our ongoing research and development efforts to produce practical serviceable products that meet or exceed all applicable requirements. This is all made possible by your ongoing support of our company, our many highly motivated associates and by the purchase and use of the uniquely advanced environmental control products we manufacture.

In conclusion, thanks again to all clients who provided comments and feedback. Thanks to you, we can continue our efforts to resolve this matter!


To submit initial or follow-up comments and participate in the resolution of this critical issue, please use the form submission button below, or send your comments directly to Mr. Baucom at mikeb@exphvac.com.

Submit A Comment


IMPORTANT DISCLAIMER
Please note this issue is presented for your consideration by Bebco Environmental Controls Corporation,
in an independent effort to serve our clients in the best manner possible and contribute to the
overall health and safety of the industrial workforce here in the USA.

This article is not sponsored by ASHRAE and viewpoints as herein expressed do not reflect any official position of the ASHRAE Society.

 
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Safety vs. Energy Efficiency

Help Us Justify Exemptions to ASHRAE 90.1 Requirements!

Mike Baucom, CEO Bebco Environmental Controls CorporationWith 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 mikeb@exphvac.com.

Submit A Comment


IMPORTANT DISCLAIMER
Please note this issue is presented for your consideration by Bebco Environmental Controls Corporation,
in an independent effort to serve our clients in the best manner possible and contribute to the
overall health and safety of the industrial workforce here in the USA.

This article is not sponsored by ASHRAE and viewpoints as herein expressed do not reflect any official position of the ASHRAE Society.