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www.RichmondSystems.com
August 7, 2015
Revised February 2, 2016
Whole Cannabis, LLC
50 West Westfield Court
Shelton, WA 98584
AT Steve Chamberlain
Ref: Butane Refrigerant Use (Revision 1)
Extractor Room Building E
By: George M Richmond, P.E.
This letter summarizes the results of a code investigation for use of a Butane based
essential oils extractor application.
Assumptions:
The equipment contains 8 lbs of Butane used through the process equipment as a solvent
with transfer of the Butane between containers,accomplished via a refrigeration type
process. In other words, through phase changes. The Butane transfers as a gas and is
collected, condensed, and recovered as a liquid.
The code documents which appear to govern are:
• ASHRAE Standard 15-2013
ASHRAE Standard 34-2013
• 2012 International Building Code
• 2012 International Fire Code
• 2012 International Fire Code Washington State Emergency Rule — Chapter 38
• 2012 International Mechanical Code
• 2014 National Electrical Code
Below are my findings from the code documents.
Code Review
1. ASHRAE Standard 34; Designation and Safety Classifications of Refrigerants
a. ASHRAE standard 34 identifies Butane and Iso-Butane as refrigerants 600
and 600a respectively.
b. Both Butane refrigerants have safety classifications of A3. A indicates they
are not toxic to humans and 3 indicates they are at the highest flammability
classification for refrigerants.
8365 Hogum Bay Lane NE I Olympia,WA 98516 1 Office 360.956.0384 i Fax 360.352.1275
2. ASHRAE Standard 15; Safety Standard for Refrigeration
a. Section 4, Occupancy Classification: I interpreted this use as Industrial and
believe it falls under section 4.1 .6, Industrial Occupancy.
i. Not open to the public.
ii. Access by authorized persons only
iii. used to manufacture, process, or store goods.
b. Section 5; Refrigerating System Classification
i. Section 5.1.1 A direct system where the evaporator or condenser is
in direct contact with the space.
ii. Section 5.2.1 High Probability System. Any system where a leakage
of refrigerant will enter the occupied space.
c. Section 6; Refrigerant Safety Classification, Section 6.1, Single Compound
Refrigerant. Classification A3 as indicated above from Standard 34.
d. Section 7, Restrictions on Refrigerant Use
i. Section 7.2 limits Refrigeration Volumes based on table 4.1 and 4.2
in ASHRAE Standard 34. Table 4.1 limits Butane volumes to 0.15
Ibs / 1,000 cubic feet (Mcf). The processing space is 3.725 Mcf. This
section limits the allowable refrigerant to 0.55 Ibs of Butane.
ii. Section 7.2.2 Industrial Occupancies and Refrigerated Rooms
1. This section will allow higher volumes of refrigerant as long as
seven conditions are met.
a. The 31d condition requires the floor area per occupant of
not less than 100 square feet OR the space is provided
with egress directly to the outdoors or into approved
building exits.
b. The 6th condition requires Class I, Div 2 electrical
equipment if the volume will exceed 25% of the lower
flammability limit (LFL) for the flammable refrigerant.
iii. Section 7.4 Location in a Machinery Room or Outdoors
1. This section allows higher volumes of refrigerant as long as
ALL system components are located in a Machinery Room or
Outdoors.
a. The processing space appears to meet all code
requirements for a Machinery Room.
b. Section 7.4.2 Flammable Refrigerants requires
Machinery Rooms to be constructed to Sections 8.11
and 8.12.
i. Section 8.11 requires tight fitting, self closing
doors opening to the outdoors or to an exit
pathway. 8.11.2.1 requires a detector properly
located which will provide audible and visual
alarm in the event of refrigerant detection. More
requirements in this section.
RICHMOND ENGINEERING
8365 Hogum Bay Lane NE
Olympia,WA 98516
Phone(360)956-0384
Fax(360)352-1275 Page 2 of 6
ii. 8.11.5 requires mechanical ventilation to flush
the space should a leak be detected. Flushing
air rates were calculated at 282 cfm. Makeup air
source cannot be from an adjacent occupied
space. In addition to the air flush required
airflow, this section requires continuous airflow at
0.5 cfm per square foot or 20cfm per person
while occupied.
iii. Section 8.11.6 requires no open flames or
combustion equipment within the Machinery
Room.
2. Section 8.12 Machinery Room Special Requirements
a. All of the following are REQUIRED
i. No flame producing device or hot surface over
80OF installed in the room.
ii. Doors communicating with the building shall be
gasketed, labeled, fire doors.
iii. Walls, floor, and ceiling shall be tight and non-
combustible construction. One hour
construction.
iv. Must have a door that opens directly to the
outdoors or through an exit vestibule.
v. All pipes piercing the interior walls ceiling or floor
shall be tightly sealed.
vi. When refrigerants of class A3 are used, the
machinery room shall conform to Class I, Div 2
of the National Electric Code.
3. 2012 International Fire Code
a. Chapter 38, Marijuana Processing and Extraction Facilities (WAC
Emergency Ruling)
i. Location: Room dedicated to extraction process; not to be used for
any other use, including storage.
ii. Staffing: The space shall be continuously staffed by personnel
trained in the extraction process and all emergency procedures.
iii. Systems, Equipment and Process:
1. Listing/Certification: All equipment shall be listed for the
specific use. If it is not listed, the system shall have a
designer of record. If the designer of record is not licensed
Washington State professional engineer, the system shall be
peer reviewed by a licensed Washington professional
engineer.
iv. Construction Requirements:
1. Room Location and Egress: One or more exits shall be
provided, swinging in the direction of travel and provided with
an automatic closer and panic hardware. The room shall not
RICHMOND ENGINEERING
8365 Hogum Bay Lane NE
Olympia,WA 98516
Phone(360)956-0384
Fax(360)352-1275 Page 3 of 6
enter directly into an exit, exit passageway, horizontal exit or
along the sole egress path from another portion of the
building.
2. Ventilation: Room shall be provided with a dedicated
hazardous exhaust system complying with Section 5004.3 for
all solvents other than water. Operation of system shall be
continuous.
a. Ventilation rates shall limit concentration of solvents to
below 25% of the lower flammability limit (See
calculations below) OR Class I Division II electrical
requirements shall apply to the entire room.
3. Electrical:
a. All electrical components shall be interlocked with the
hazardous exhaust system and the gas detection
system. When system is not operational, all electrical
devices and lighting shall be disabled.
b. Emergency Power: Emergency power shall be provided
for lighting, ventilation, gas detection systems,
emergency alarm systems, and fire extinguishing
systems, when provided.
4. Alarms: A gas detection system shall be provided with a
threshold no greater than 25% of the lower flammability limit
(LFL) of materials (25% of the LFL for butane is 0.4%).
5. Fume Hoods: A fume hood is not required for this process.
Butane is not defined as a liquid per the IFC since it has a
boiling point below 68 OF.
b. Chapter 50, Hazardous Materials— General Provisions
i. Section 5003.1.1 limits the maximum allowable quantity per control
area to 150 pounds as liquefied flammable gas, or 1,000 cubic feet at
NTP as a gaseous flammable gas per table 5003.1.1(1). The
amounts used in this process are below these requirements and
must meet the requirements of sections 5001 and 5003.
1. Equipment Requirements:
a. Design Standards: 5003.2.1 and 5003.2.2 - All
containers, cylinders, tanks piping, tubing, valves and
fittings shall be designed and constructed in
accordance with approved standards. Pressure
vessels shall comply with ASME Boiler and Pressure
Vessel Code.
b. Installation: 5003.2.8 - Equipment shall be braced and
anchored in accordance with seismic design
requirements of the IBC. It is assumed no stationary
tanks will be utilized during this process.
c. Maintenance: 5003.2.6 - All equipment shall be
maintained in an operable condition. Any defective
RICHMOND ENGINEERING
8365 Hogum Bay Lane NE
Olympia,WA 98516
Phone(360)956-0384
Fax(360)352-1275 Page 4 of 6
devices or equipment shall be removed from service,
repaired or disposed of in an approved manner.
d. Testing: 5003.2.9.2 - All alarms and gas detection
systems shall be tested not less than annually.
2. MSDS Sheets: 5003.4— MSDS Sheets shall be readily
available on site.
3. Signage:
a. 5003.5 — Hazard Identification signs per NFPA 704 for
butane (Health Hazard: 1, Flammability: 4, Instability: 0)
shall be placed on all containers, tanks and at all
entrances to locations where butane is stored,
dispensed, used or handled.
b. 5003.7 — No smoking signs shall be placed in extraction
rooms.
4. Construction Requirements:
a. Fire Separation: 5003.8.3.1 and 5003.8.3.4 - Room
shall be separated from the remainder of the building by
Fire Barriers with 1-hour rating per the IBC Section 707
and 711. Floors shall have a 2-hour rating.
5. General Safety Requirements:
a. Specific safety and security requirements are listed in
section 5003.9
b. Electrical equipment is required to be installed and
maintained per NFPA 70.
6. Handling and Transportation:
a. Protective caps are required on all valves per
5003.10.1.
b. 5003.10.2 and 5003.10.3 - Whenever liquid containers
are transported that are over 5 gallons, a cart or truck
shall be used. Cart shall provide a stable base and
have a means of restraining each individual container.
Carts or trucks shall not be left unattended within any
part of a means of egress.
ii. Chapter 5004.3 (per section 3802.4.3):
1. Ventilation shall be 1 cfm per square foot, or 70 cfm
(minimum) for the storage area and operate continuously.
2. Ventilation system shall have a manual shutoff control outside
the room with a break-glass switch labeled "Ventilation System
Emergency Shutoff".
3. Exhaust intake shall be within 12 inches of the finished floor.
4. Make-up air discharge and Exhaust inlet locations shall be in
opposite corners of the room.
5. Exhaust air shall not be recirculated to occupied areas.
4. 2012 International Mechanical Code
a. Chapter 5: Exhaust Systems
RICHMOND ENGINEERING
8365 Hogum Bay Lane NE
Olympia,WA 98516
Phone(360)956-0384
Fax(360)352-1275 Page 5 of 6
i. Hazardous Materials System Requirements 502.8.1.1 — Same
requirements as listed in section 5004.3 of the 2012 IFC.
5. 2014 National Electrical Code
a. Chapter 500: Hazardous (Classified) Locations
i. 500.5 - Classifications of Locations.
1. This section specifically lists locations containing oil-extraction
equipment using volatile flammable solvents as being a Class
I, Division 1 .
ii. 500.7 — Protection Techniques.
1. This section lists explosion proof equipment and Intrinsic
Safety as a permitted protection techniques for this Class I
Division 1 locations.
Quick calculations for 8 Ibs of Butane in our 3275 cubic foot room and knowing that 1.6%
by volume is the Butane LEL, leads to; 8lbs of butane will occupy 52.4 cubic feet at
atmospheric pressure. 25% of 1.6% LEL = 0.4%. 0.4% of 3275 cubic feet = 13 cubic feet
of Butane allowable. The 8 Ibs of Butane is more than four times the allowable.
In summary, the space will be required to be constructed with 1-hour fire barriers with a 2-
hour floor. All doors for the room shall be gasketed and labeled fire doors. The egress
doors will need to open directly to the outdoors or into an exit vestibule. The space will be
required to exhaust 70 CFM (minimum) continuously with an intake on the opposite side
of the room as the exhaust and the exhaust intake shall be within 12 inches of the floor.
Upon detection of butane concentrations above 0.4%, exhaust shall increase to 282 CFM
(minimum) and all electrical devices shall be disabled. The exhaust system, alarm system
and lighting will be required to be on emergency power. All electrical systems are
required to be explosion proof or intrinsically safe.
RICHMOND ENGINEERING
8365 Hogum Bay Lane NE
Olympia,WA 98516
Phone(360)956-0384
Fax(360)352-1275 Page 6 of 6