Transition from Pennsylvania’s Labor and Industry Regulations to the International Series of Codes Implications for Ge

1. Transition from Pennsylvania’s Labor and Industry Regulations to the International Series of Codes Implications for Generating Facilities RR Schartel PA LeMenager WI PaulusPPL Generation, Allentown, PA

2. Components • Background • Highlights and Major Impacts • Comparison between L&I and International • L&I Responses to Questions • Overview of Codes: • International Building Code • International Fire Code • International Fuel Gas Code • ICC Electrical Code • International Mechanical Code • International Energy Conservation Code • International Plumbing Code • International Private Sewage Code

3. Background • Enacted as Act 45-1999 as the Pennsylvania Construction Code Act • Adopts the 2000 Edition of the International Building Code as promulgated by the International Code Council (successor code to 1999 BOCA Code) • ICC made up of BOCA, SBCCI, and ICBO groups.

4. FEATURES OF UCC ENABLING LEGISLATION: • Repeals most of the Fire and Panic Act, Act 222, most others addressing how buildings are built and operated. • Must be adopted and enforced at the local level • Requires adopting ordinance • Local municipalities can set own fee structures and interpret as they see fit. • Appeals handled at the local level by local Board of Appeals • Regulations go into effect in Spring 2003.

5. Adoption Options • Option 1---Local municipality adopts and enforces entirely • Option 2---Local municipality contracts with a third party agency • Option 3---Local municipality adopts and enforces jointly with intergovernmental agreement • Option 4---Local municipality contracts with another municipality • Option 5---Local municipality opts out and defers to L&I for all but 1 & 2 Family Dwellings • Local municipalities must have plans examiners and inspectors certified by L&I to perform work • State will provide state level variety

6. Highlights and Major Impacts • Generally any construction, alteration, enlargement, repair, movement, demolition, or occupancy change • A permit is not required for the installation, alteration or repair of generation, transmission, distribution, metering or other related equipment that is under the ownership and control of a public service utility by established right • Also any construction, alteration, enlargement, repair, removal, conversion of any electrical, gas, mechanical, or plumbing • If being done by the State, plan for 3 months minimum from application to approval to construct rather than the current one day plan approval

7. Highlights and Major Impacts • Fees established locally for local reviews and at the state level for state reviews. • Some relief provided for routine repairs and testing. • Annual permits allowed for corporations regularly employing qualified trade persons on the premises. Detailed records of all alterations under the permit must be maintained.

8. Highlights and Major Impacts • The new codes do not require that systems be installed by a certified electrician or plumber; however, townships and cities occasionally add that requirement to their standards. This should be monitored for townships where the plants are located – can be a training /certification need in the future. • Electric Light and Powerhouses classified as Group F-1 —Moderate Hazard Factory Occupancy. Special classifications allowed for areas handling hazardous materials, including combustible dusts (Group H).

9. Highlights and Major Impacts Inspections • Inspectors (state and local) have access to the property virtually on demand whenever required to enforce the code or if there is suspicion of a violation or dangerous condition. • CONCERN: Most of the power plant electrical systems have not been inspected to comply with national codes – excessive cables in cable trays is an exposure item. Some panels are not FM approved or offered that way. • If access is denied, the inspector has recourse to any remedies allowed by law, generally a warrant or a police order.

10. Highlights and Major Impacts Adoption by Reference • International Plumbing Code • International Mechanical Code • International Fire Code • ICC Electrical Code (References NEC as part of NFPA) • International Fuel Gas Code • International Property Maintenance Code • International Energy Conservation Code

11. L&I RESPONSES TO QUESTIONS • Have other electric utilities within Pennsylvania discussed compliance with these new standards for power generating buildings (as opposed to office areas)? If so which companies? • None to my knowledge. • How are other heavy industries handled - such as the steel industry? • All industries will be handled as required in the IBC. • Are there grandfather provisions for obtaining variances for accessibility standards for power generating plants designed and built prior to the promulgation of the International Building Code as a statewide building code? • The UCC will not apply to existing buildings approved prior to the effective date. Only alterations or additions will have to comply with the UCC. The existing portion will remain under the codes in effect at the time of approval. • If so, can a determination be made for the entire power generating building (i.e. the turbine building and boiler without the need for a number of individual variances? • Individual variances will be required when necessary. • How long do you expect an average variance request take to process? • In areas where the Department is enforcing, the PA Industrial Board will continue to hear variance requests. They usually work on a 45 day turn around. In areas where municipalities are enforcing, local Boards of Appeal will handle the processing of variance requests.

12. L&I RESPONSES TO QUESTIONS • Currently an existing facility must comply 100% with accessibility standards after a ratio of accumulated modification construction costs meet or exceed 51% of the current Means estimated worth of the facility, will that be enforced again? • No. The percentage of compliance under Act 235 is repealed. Only alterations or changes to existing buildings will have to comply with the UCC. • It would appear that the following International codes will be adopted by reference: • Mechanical code • Plumbing code • Fire Code • Fuel Gas code • Will L&I enforce these additional codes? • Yes.

13. 2001 INTERNATIONAL BUILDING CODE Chapter Title Chapter Title 1 Administration 18 Soil & Foundations 2 Definitions 19 Concrete 3 Use & Occupancy Classification 20 Aluminum 4 Special Req’mts Based on Use and Occupancy 21 Masonry 5 General Building Heights and Areas 22 Steel 6 Types of Construction 23 Wood 7 Fire Resistance-Rated Construction 24 Glass and Glazing 8 Interior Finishes 25 Gyp Board & Plaster 9 Fire Protection Systems 26 Plastic 10 Means of Egress 27 Electrical 11 Accessibility 28 Mechanical Systems 12 Interior Environment 29 Plumbing Systems 13 Energy Efficiency 30 Elev & Convng Sys 14 Exterior Walls 31 Special Construction 15 Roof Assembly & Rooftop Structures 32 Encroachments 16 Structural Design 33 Safgds during Constr. 17 Structural Tests & Special Inspections 34 Existing Structures 35 Referenced Standards

14. INTERNATIONAL FIRE CODE Scope—establishes requirements to safeguard society from unwanted fires, explosions and hazardous conditions in new and existing premises. 45 Chapters and 7 Appendices Typical chapters affecting generation sites: Chapter Title Chapter Title 3 General Prec. Against Fire 26 Welding and other Hot Work 4 Emergency Planning & Preparedness 27 Hazardous Materials--General 5 Fire Service Features 34 Flammable & Comb. Liquids 9 Fire Protection Systems 35 Flammable Gases 13 Comb. Dust Producing Sys. 38 LP Gases 23 High Piled Storage 40 Oxidizers

15. Examples of Operations Permits: Aerosol Stg Cutting & Welding Battery Systems (50+gal soln) Combustible dust producing operations Repair Garage Hazmat Storage Explosives Compressed Gas Storage Misc. and High Storage Examples of Construction Permits: Automatic Fire Prot. Systems Fire Alarm Systems Compressed Gas Systems Fire Pumps Flammable & Comb. Liquid Systems Fire Hydrants Haz Mat Facilities INTERNATIONAL FIRE CODE PERMITS Operational—may be either for a finite period, or in effect until revoked or renewed Construction—to install or modify systems and equipment

16. INTERNATIONAL FIRE CODE Inspections Inspectors have access to the property virtually on demand whenever required to enforce the code or if there is suspicion of a violation or dangerous condition. If access is denied, the inspector has recourse to any remedies allowed by law, generally a warrant or a police order. Emergency Access Fire Chief has authority to direct operations required to control fires or other hazardous conditions, and can have removed anyone getting in his or her way.

17. INTERNATIONAL FUEL GAS CODE Scope-Fuel gas piping from point of delivery to utilization equipment. Scope does NOT apply to “fuel gas piping in power and atomic energy plants”. May still apply to fuel gas systems on site for reasons other than generation of power (heat, duct igniters, etc…) • Systems with pressures of 125 psi or less • Piping system design, materials, testing, components, fabrication, assembly, installation, inspection, operation, testing, and maintenance • Gas utilization equipment installation combustion, ventilation air and venting.

18. International Fuel Gas Code Chapter Title 1 Administration 2 Definitions 3 General Regulations 4 Gas Piping Installations 5 Chimney and Vents 6 Specific Appliances 7 Referenced Standards Appendix A Sizes and Capacities of Gas Piping (IFGS) Appendix B Sizing of Venting Systems Serving Appliances Equipped with Draft Hoods, Category 1 Appliances, and Appliances Listed for use and Type B Vents (IFGS) Appendix C Exit Terminals of Mechanical Draft and Direct-Venting Systems (IFGS) Appendix D Recommended Procedure for Safety Inspection of an Existing Appliance Installation (IFGS)

19. ICC ELECTRICAL CODE-- ADMINISTRATIVE PROVISIONS • Scope—All new electrical systems, repairs and alterations. • Existing systems do not require removal or alteration; however, must be maintained to meet code in effect at time of approval. • Inspectors have authority to require systems to be reinspected. • Code refers to other International Codes and following Standards: • ANSI - American National Standards Institute • ICC – International Code Council • NFPA – National Fire Protection Association (References NEC as part of NFPA) • UL- Underwriters Laboratories

20. ICC ELECTRICAL CODE

21. INTERNATIONAL MECHANICAL CODE • Scope—All new buildings and additions must meet code • Existing systems do not require removal or alteration; however, must be maintained to meet code in effect at time of approval, if there is no current hazard to life, health or property. • Inspectors have authority to require systems to be re-inspected. • Permits for emergency repair or replacements shall be submitted within the next business day. • The code is geared toward building size boilers, but if we comply with AWS requirements we should be okay. • Reference to Fuel Oil Piping and Storage items is referenced to the International Fire Code for larger capacity systems.

22. INTERNATIONAL MECHANICAL CODE

23. INTERNATIONAL ENERGY CONSERVATION CODE(TAKES THE PLACE OF L&I ACT 222 FOR ENERGY CONSERVATION) • Scope—Thermal design of new buildings and additions, and the associated mechanical and electrical systems. • Allows for unconditioned buildings that are not heated and cooled. • Existing buildings and ongoing work must meet code in effect at time of approval.

24. INTERNATIONAL ENERGY CONSERVATION CODE

25. INTERNATIONAL PLUMBING CODE • Scope—All new buildings and additions must meet code • Existing systems do not require removal or alteration; however, must be maintained to meet code in effect at time of approval, if there is no current hazard to life, health or property. • Inspectors have authority to require systems to be re-inspected. • Modifications/repairs to existing systems work may be permitted in the same manner if they meet code in effect at time of approval.

26. INTERNATIONAL PLUMBING CODE

27. INTERNATIONAL PRIVATESEWAGE DISPOSAL CODEScope—All new systems and failed systems