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S&B Mechanical Refrigeration Advisory Council Meeting Summaries Meeting summaries are considered draft documents subject to review at a subsequent meetingMonday, November 30, 2009, 10 a.m., Room 3B, Thompson Commerce Center, 201 West Washington Ave., Madison, Wisconsin Council Member Attendance: Ralph Boldt - Present; Brady Farrell - P; Kevin LaMere - P; Randy Pucek - P ; Douglas Reindl - P; Steven Walter (Chairperson) - P; Jack Williams - P. Guests: Tom Riley - Prior Engineering Services Department of Safety and Professional Services Staff: Duane Leetch, Rick Merkle, James Quast, Sam Rockweiler, Mike Verhagen Steve Walter opened the meeting with a review of the agenda and a round of introductions. The council accepted the progress report from the preceding, October 21 meeting, after noting that Kevin LaMere was present rather than excused. Jim Quast asked the council to alert the department to any substantial costs that might result from any of the new requirements in the updated Comm 45. Department update Jim noted the department’s fees for permits to operate mechanical refrigeration systems will increase on January 1, 2010. Rick Merkle reported he is moving to the department’s Waukesha office before the end of the year. Draft changes for updating Comm 45 Duane Leetch distributed a summary of his review of addenda f to i for the 2007 edition of ASHRAE 15, which concluded that no detriment is foreseen in adopting them in conjunction with adopting ASHRAE 15-2007. Jim noted addendum i includes exceptions for laboratories and industrial occupancies - and ASHRAE 15 includes a definition for industrial occupancies, but not for laboratories. It was noted the addenda would also apply where the IIAR 2 standard is used for design. For discussing the updated draft rules that were mailed to the council prior to the meeting, Sam Rockweiler distributed a summary of the included changes - which were shown in red in the updated draft. In reviewing the draft requirements in Comm 41.02(1)(b)2. for repairs to pressure vessel components in a mechanical refrigeration system, Rick noted the corresponding inspections are performed by private-sector inspectors, who then attach an R tag to show their inspection has occurred. In reviewing the draft requirements in Comm 45.02(1)(c) and (d) for repairs and replacements, Doug Reindl questioned whether the work would need to comply with the rules in effect at the time of the repair or replacement, rather than with the rules that were in effect during the initial installation. Rick indicated the current rules would apply. There was concern that the current rules could be interpreted as also applying retroactively to the other elements in the system which are not being repaired or replaced. Randy Pucek and Duane recommended clarifying that only the repaired or replaced portion would need to comply with the current rules. Rick recommended clarifying that the department must be notified before a system is reactivated after a repair or replacement. Randy recommended clarifying the draft criteria in Comm 45.08(1)(b) relating to enforcement activities by a local agent occurring before those to be undertaken by the department. In reviewing the draft requirements in Comm 45.08 2)(c), Doug asked whether the department should inspect copper piping to the same degree that steel piping is inspected. Rick noted substantial additional resources would be needed for that inspection - and Randy explained that steel piping is used instead of copper for higher-hazard refrigerants, which justifies the higher level of inspection for steel piping. Doug questioned whether the reference in Comm 45.08(3)(a)2.b. to air-intake openings for exterior components would apply more broadly than desired, and there was agreement to change the draft text to instead refer to outdoor, self-contained systems because ASHRAE 15 includes a definition for those systems. In reviewing the draft requirements in Comm 45.509(1) for use of PVC piping for discharge from relief valves, Duane recommended limiting the use to a maximum design pressure rather than to a maximum operating pressure. In reviewing the draft requirements in Comm 45.611(1) for plate heat exchangers, Steve asked whether the alternate design formula could apply to coil exchangers, and Doug explained it is only for plate-type exchangers. Randy asked whether building-code requirements apply to mechanical rooms, and Rick explained that Note 2 under Comm 45.01(2) lists several administrative codes which may apply, including Comm 60 to 66, Commercial Building Code. Doug recommended clarifying that building code requirements may apply when alterations occur. There was agreement to expand the informational note under Comm 45.02(1)(d) to alert designers that some alterations to a mechanical refrigeration system may necessitate modifying other features of a building, such as an automatic fire sprinkler system, which must comply with requirements in Comm 60 to 66. Jim asked whether the proposed rule changes would result in increased costs, and Randy noted the primary effect would be to make the chapter and its adopted standards easier for contractors to understand. Jim asked whether any further energy-conservation requirements should apply. Jack Williams and Ralph Boldt indicated that both short-term and long-term economics adequately encourage use of equipment which is more energy-efficient. Tom Riley noted there is increasing interest in Leadership in Energy and Environmental Design (LEED) practices, but use of the LEED practices should not be mandated. Ralph asked whether the proposed rule changes would adequately address changing the type of refrigerant in an existing system. Mike Verhagen noted ASHRAE 34, as applied through ASHRAE 15, specifies acceptable characteristics for all refrigerants, and if a new refrigerant is added to an existing system, compliance with the ASHRAE 34 specifications would be needed. (Also, ASHRAE 15 sections 5.3 and 7.5.1.8 both require notifying the authority having jurisdiction when converting to a new refrigerant, and require evaluating the new refrigerant for conformance to applicable criteria.) Rick and Randy noted Comm 45.32 currently includes an informational note explaining the department’s use of ASHRAE criteria in approving use of refrigerants. The note is no longer needed because ASHRAE 15 adequately addresses approval of refrigerants – including use of single-compound refrigerants versus other refrigerants, as addressed in the addendum c changes for section 6.1 of ASHRAE 15. Next steps Jim explained the department would revise the draft rules to reflect the input from the meeting and could then advance them to the public hearing stage if the council was in favor of doing so, and the council agreed. Sam explained the revised draft would also include renumbering of the sections in subchapters I to III, so that they coincide with the subchapter numbering, which the draft already includes for subchapters IV to VII. Staff will send the hearing draft and hearing notice to the council. If substantial issues arise during the hearing process, the council could then reconvene to consider further changes in the draft rules. Wednesday, October 21, 2009, 9:30 a.m. to 2:30 p.m.; Room 3B, Thompson Commerce Center, 201 West Washington Avenue, Madison, Wisconsin Council Member Attendance: Ralph Boldt - Present; Brady Farrell (Greg Schnelle, Alternate) - P; Kevin LaMere - P; Randy Pucek - P; Douglas Reindl - P ; Steven Walter (Chairperson) - P; Jack Williams - P Guests: Tom Riley – Prior Engineering Services Department of Safety and Professional Services staff: Duane Leetch, Rick Merkle, James Quast, Sam Rockweiler, Mike Verhagen Rick Merkle prefaced the meeting with a synopsis of the need for updating Comm 45. Jim Quast opened the meeting with a welcome, a round of introductions, and a review of the agenda. Project and Council scope and duties Jim explained the department is updating Comm 45 in conjunction with a current update of the Wisconsin Commercial Building Code, Comm 60 to 66, that includes adopting the 2009 edition of the International Building Code and it’s related building-component codes, such as the International Mechanical Code. In reference to the Advisory Council Manual that was mailed to the council prior to the meeting, Jim noted that although the department values the input of the members, the responsibility for determining the actual changes to Comm 45 ultimately rests with the department. As with other rules administered by the department, this determination is expected to be somewhat subjective and to include minimizing risks to the public. Jim noted this rulemaking is currently in the rule-development stage, and will be followed by a public hearing stage and then legislative review before the rule changes are adopted. The rule changes primarily will include updating the chapter’s technical requirements – such as the included, referenced national standards in subchapters IV and V – and updating the administrative requirements, such as the inspection and permitting requirements in subchapter III. In updating the administrative requirements, the department will be particularly interested in input on whether its processes coordinate well with what happens at typical facilities. Council members are expected to provide applicable communication to and from any organizations they represent. Doug Reindl asked whether the department has a list of issues to address, and Rick noted the primary need is to reduce the current complexity that results from having to piece together various requirements from Comm 45 and from the publications it references. Division update Jim reported that updating Comm 60 to 66 is underway and includes review of the 2009 changes to the International Mechanical Code. Other activities include developing rules in response to 2009 Wisconsin Act 16 – which establishes licensing for thermal system insulation mechanics, and a corresponding governor-appointed advisory council. Beginning on July 1, 2011, the license will be needed for installing or maintaining thermal insulation systems in all public buildings other than residential buildings with three or fewer dwelling units. Jim also reported that rule changes which will increase the Safety and Buildings Division’s fees for permits to operate are in the legislative-review stage and are expected to become effective on January 1, 2010. Council issues or concerns Randy Pucek reported that the biggest current enforcement problem is having to piece together various requirements from Comm 45 and from the publications it references. Steve Walter suggested making ASME B31.3 more readily usable as a design alternative for process piping. Duane Leetch asked whether any design criteria in B31.3 would conflict with the ASME B31.5 criteria that are referenced in ASHRAE standard 15 and Comm 45, and Steve noted B31.3 does allow some higher pressures and other piping materials. Randy indicated the B31.3 criteria could be applied through the listing requirement in ASHRAE 15 section 9.10.1. Rick suggested adding an informational Note to Comm 45 for clarifying that B31.3 can be used in this manner. Randy asked where the requirements for machine rooms will be. Rick explained Comm 60 to 66 will continue to refer to Comm 45 for the equipment and piping requirements, and Comm 45 will continue to refer to Comm 60 to 66 for the building-construction requirements. Comparison of present-day standards to standards currently adopted in Comm 45 Jim reported that Duane and Mike Verhagen had extensively reviewed the updated standards referenced in the draft rule changes which were mailed to the council prior to the meeting, and detailed comparisons from the reviews can be provided if desired. Doug recommended expanding the review to include ASHRAE 15 addenda f to i. Duane and Mike distributed a summary of their comparisons of the updated standards to the current standards adopted in Comm 45. According to Duane, very few substantive changes have occurred. Doug asked whether the intent of the draft rules is to convert to using ASHRAE 15 as the base set of requirements instead of the IMC, and the answer was yes. Mike noted the summary of differences between the 1994 and 2007 editions of ASHRAE 15 do not address the 1994 ASHRAE 15 requirements that are excluded from the current Comm 45. Doug noted ASHRAE 15 addenda c reflects that ASHRAE 15 has been changed to refer to the refrigerant classifications in ASHRAE 34, rather than repeat those classifications. Doug recommended determining the appropriate criteria for a condensing unit that serves multiple refrigeration systems, because ASHRAE 15 may not adequately address those units. Draft changes to the technical requirements in Comm 45 In discussing the draft rule changes that were mailed to the council prior to the meeting, Jim started with the repeal and recreation of the technical requirements, as beginning with Comm 45.20. Jim noted the repeal and recreation replaces the IMC with ASHRAE 15, except the criteria in IIAR 2 can be used as an alternate design standard for closed-circuit ammonia systems. The new Comm 45 subchapters V and VI contain Wisconsin modifications of ASHRAE 15 and IIAR 2, respectively. Rick explained the draft requirements in Comm 45.509(1) are intended to codify the department’s current acceptance of a minimum grade of polyvinyl chloride for vent discharge piping that discharges outside a building. Jim noted an alternative to codifying the acceptance would be obtaining a variance for each project where the PVC is used – and codifying the acceptance could include further specifying the methodology or defining terms such as non-combustible. Doug noted concern for allowing PVC in ammonia systems. Ralph Boldt and Randy noted NFPA 54, which addresses piping and equipment for gaseous fuels, was modified recently to not allow PVC piping indoors for regulator vents. Duane suggested revising the draft requirements to limit the PVC to only low pressure systems, such as no more than 15 psi, and only for systems with type A1 and B1 refrigerants. The draft could also be revised to accept the PVC through an exception to ASHRAE 15 section 9.1.5, which requires discharge piping to be of the same material as the piping for the refrigerant, and an informational note could be added for listing the material the department currently accepts. Doug noted concern that although the sizing tables in IIAR 2 for discharge piping are based on the inside diameter of schedule 40 piping, IIAR 2 is inconsistent in allowing use of the tables for schedule 80 piping, which has a smaller inside diameter. In reviewing the draft requirements in Comm 45.509(2) for hydrostatic isolation, Doug explained the requirements would not be needed if ASHRAE 15 addenda g is adopted. In reviewing the draft requirements in Comm 45.511(2) for periodically replacing pressure relief valves, Jim noted the requirements would apply not only to newly installed valves, but also to all existing valves. Doug recommended not applying the requirements to relief valves that discharge internally to another part of a system. Doug explained that IIAR 2 includes some minor inconsistencies which should be corrected, such as having to design vent discharge piping as if it is pressurized, and he agreed to send staff draft text for the corrections. Election of chairperson Steve Walter was unanimously elected chairperson. Draft changes to the administrative requirements in Comm 45 Doug recommended defining what is included in additions and alterations for a refrigeration system. Jim commented the absence of a definition in Comm 45 to date has not been reported as causing problems, and in that absence the dictionary definition applies. Randy noted a definition might help contractors avoid proceeding too far with an inappropriate addition or alteration, because no plan review occurs prior to the installation – since Comm 45 does not require plan submittal and approval prior to any installation, including additions or alterations. Duane noted an informational note is included under Comm 45.02(1)(d), for explaining that an addition or alteration may result in needing other changes to a system. Doug indicated the note does not resolve his concern. Doug recommended updating the informational Note for Comm 45.07(1) to show that under addenda c for ASHRAE 15, the refrigerant classifications are now only in ASHRAE 34, rather than repeated in ASHRAE 15. In reviewing the draft requirements in Comm 45.08(3)(a)2. for air conditioning for human occupancy, Ralph noted that any exterior package unit that includes an intake opening for outside air cannot be located at least 20 feet from a building opening because the intake opening itself is a building opening. Doug indicated ASHRAE is reviewing the topic. In reviewing the draft requirements in Comm 45.09(2)(a) for completing inspection actions within 5 business days, Randy indicated longer periods may be needed in some cases. Next steps Mike and Duane agreed to review ASHRAE 15 addenda f to i, and Doug agreed to submit his revisions for the draft rule changes. The next meeting was set for November 30, 2009, at the same location and time, with a potential for attending by teleconference. Wednesday, October 21, 2009, 9:30 a.m. to 2:30 p.m., Room 3B, Thompson Commerce Center, 201 West Washington Ave., Madison, Wisconsin Council Member Attendance: Ralph Boldt - Present; Brady Farrell (Greg Schnelle, Alternate) - P; Kevin LaMere - Excused; Randy Pucek - P; Douglas Reindl - P; Steven Walter (Chairperson) - P; Jack Williams - P Guests: Tom Riley – Prior Engineering Services Department of Safety and Professional Services staff: Duane Leetch, Rick Merkle, James Quast, Sam Rockweiler, Mike Verhagen Rick Merkle prefaced the meeting with a synopsis of the need for updating chapter Comm 45. Jim Quast opened the meeting with a welcome, a round of introductions, and a review of the agenda. Project and council scope and duties Jim explained the department is updating Comm 45 in conjunction with a current update of the Wisconsin Commercial Building Code, Comm 60 to 66, that includes adopting the 2009 edition of the International Building Code and it’s related building-component codes, such as the International Mechanical Code. In reference to the Advisory Council Manual that was mailed to the council prior to the meeting, Jim noted that although the department values the input of the members, the responsibility for determining the actual changes to Comm 45 ultimately rests with the department. As with other rules administered by the department, this determination is expected to be somewhat subjective and to include minimizing risks to the public. Jim noted this rulemaking is currently in the rule-development stage, and will be followed by a public hearing stage and then legislative review before the rule changes are adopted. The rule changes primarily will include updating the chapter’s technical requirements – such as the included, referenced national standards in subchapters IV and V - and updating the administrative requirements, such as the inspection and permitting requirements in subchapter III. In updating the administrative requirements, the department will be particularly interested in input on whether its processes coordinate well with what happens at typical facilities. Council members are expected to provide applicable communication to and from any organizations they represent. Doug Reindl asked whether the department has a list of issues to address, and Rick noted the primary need is to reduce the current complexity that results from having to piece together various requirements from Comm 45 and from the publications it references. Division update Jim reported that updating Comm 60 to 66 is underway and includes review of the 2009 changes to the International Mechanical Code. Other activities include developing rules in response to 2009 Wisconsin Act 16, which establishes licensing for thermal system insulation mechanics, and a corresponding governor-appointed advisory council. Beginning on July 1, 2011, the license will be needed for installing or maintaining thermal insulation systems in all public buildings other than residential buildings with three or fewer dwelling units. Jim also reported that rule changes which will increase the Safety and Buildings Division’s fees for permits to operate are in the legislative-review stage and are expected to become effective on January 1, 2010. Council issues or concerns Randy Pucek reported that the biggest current enforcement problem is having to piece together various requirements from Comm 45 and from the publications it references. Steve Walter suggested making ASME B31.3 more readily usable as a design alternative for process piping. Duane Leetch asked whether any design criteria in B31.3 would conflict with the ASME B31.5 criteria that are referenced in ASHRAE standard 15 and Comm 45, and Steve noted B31.3 does allow some higher pressures and other piping materials. Randy indicated the B31.3 criteria could be applied through the listing requirement in ASHRAE 15 section 9.10.1. Rick suggested adding an informational note to Comm 45 for clarifying that B31.3 can be used in this manner. Randy asked where the requirements for machine rooms will be. Rick explained chapters 60 to 66 will continue to refer to Comm 45 for the equipment and piping requirements, and Comm 45 will continue to refer to Comm 60 to 66 for the building-construction requirements. Comparison of present-day standards to standards currently adopted in Comm 45 Jim reported that Duane and Mike Verhagen had extensively reviewed the updated standards referenced in the draft rule changes which were mailed to the council prior to the meeting, and detailed comparisons from the reviews can be provided if desired. Doug recommended expanding the review to include ASHRAE 15 addenda f to i. Duane and Mike distributed a summary of their comparisons of the updated standards to the current standards adopted in Comm 45. According to Duane, very few substantive changes have occurred. Doug asked whether the intent of the draft rules is to convert to using ASHRAE 15 as the base set of requirements instead of the IMC, and the answer was yes. Mike noted the summary of differences between the 1994 and 2007 editions of ASHRAE 15 do not address the 1994 ASHRAE 15 requirements that are excluded from the current Comm 45. Doug noted ASHRAE 15 addenda c reflects that ASHRAE 15 has been changed to refer to the refrigerant classifications in ASHRAE 34, rather than repeat those classifications. Doug recommended determining the appropriate criteria for a condensing unit that serves multiple refrigeration systems, because ASHRAE 15 may not adequately address those units. Draft changes to the technical requirements in Comm 45 In discussing the draft rule changes that were mailed to the council prior to the meeting, Jim started with the repeal and recreation of the technical requirements, as beginning with Comm 45.20. Jim noted the repeal and recreation replaces the IMC with ASHRAE 15, except the criteria in IIAR 2 can be used as an alternate design standard for closed-circuit ammonia systems. The new Comm 45 subchapters V and VI contain Wisconsin modifications of ASHRAE 15 and IIAR 2, respectively. Rick explained the draft requirements in section Comm 45.509(1) are intended to codify the department’s current acceptance of a minimum grade of polyvinyl chloride for vent discharge piping that discharges outside a building. Jim noted an alternative to codifying the acceptance would be obtaining a variance for each project where the PVC is used and codifying the acceptance could include further specifying the methodology or defining terms such as non-combustible. Doug noted concern for allowing PVC in ammonia systems. Ralph Boldt and Randy noted NFPA 54, which addresses piping and equipment for gaseous fuels, was modified recently to not allow PVC piping indoors for regulator vents. Duane suggested revising the draft requirements to limit the PVC to only low pressure systems, such as no more than 15 psi, and only for systems with type A1 and B1 refrigerants. The draft could also be revised to accept the PVC through an exception to ASHRAE 15 section 9.1.5, which requires discharge piping to be of the same material as the piping for the refrigerant, and an informational note could be added for listing the material the department currently accepts. Doug noted concern that although the sizing tables in IIAR 2 for discharge piping are based on the inside diameter of schedule 40 piping, IIAR 2 is inconsistent in allowing use of the tables for schedule 80 piping, which has a smaller inside diameter. In reviewing the draft requirements in Comm 45.509(2) for hydrostatic isolation, Doug explained the requirements would not be needed if ASHRAE 15 addenda g is adopted. In reviewing the draft requirements in Comm 45.511(2) for periodically replacing pressure relief valves, Jim noted the requirements would apply not only to newly installed valves but also to all existing valves. Doug recommended not applying the requirements to relief valves that discharge internally to another part of a system. Doug explained that IIAR 2 includes some minor inconsistencies which should be corrected, such as having to design vent discharge piping as if it is pressurized, and he agreed to send staff draft text for the corrections. Election of chairperson Steve Walter was unanimously elected chairperson. Draft changes to the administrative requirements in Comm 45 Doug recommended defining what is included in additions and alterations for a refrigeration system. Jim commented the absence of a definition in Comm 45 to date has not been reported as causing problems, and in that absence the dictionary definition applies. Randy noted a definition might help contractors avoid proceeding too far with an inappropriate addition or alteration, because no plan review occurs prior to the installation, since Comm 45 does not require plan submittal and approval prior to any installation, including additions or alterations. Duane noted an informational note is included under Comm 45.02(1)(d), for explaining that an addition or alteration may result in needing other changes to a system. Doug indicated the note does not resolve his concern. Doug recommended updating the informational note for Comm 45.07(1) to show that under addenda c for ASHRAE 15, the refrigerant classifications are now only in ASHRAE 34, rather than repeated in ASHRAE 15. In reviewing the draft requirements in Comm 45.08 (3) (a) 2. for air conditioning for human occupancy, Ralph noted that any exterior package unit that includes an intake opening for outside air cannot be located at least 20 feet from a building opening because the intake opening itself is a building opening. Doug indicated ASHRAE is reviewing the topic. In reviewing the draft requirements in Comm 45.09(2)(a) for completing inspection actions within five business days, Randy indicated longer periods may be needed in some cases. Next steps Mike and Duane agreed to review ASHRAE 15 addenda f to i, and Doug agreed to submit his revisions for the draft rule changes. The next meeting was set for November 30, 2009, at the same location and time, with a potential for attending by teleconference. |