Thread: Combined Sediment Traps

What are your thoughts on this installation?

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AD,

Can't see why it would be a problem. I do not recall the specific code wording, but I do not recall anything about a dedicated sediment trap, just a sediment trap located close to the appliance.

Seems good to me except the trap is upstream of the valves. But then I can't ever remember one that is correct in that respect.
Of course if you put the trap downstream of the equipment shut-off valve then it would not pass muster since you would also have two pieces of utilization equipment controlled by one valve.

I am wondering if each appliance requires its own trap.

I am wondering if each appliance requires its own trap.

Not specified in the IRC, but the placement of the trap is and the need for individual valves would by default mean there would be a requirement for separate traps.

Originally Posted by Jim Luttrall

Not specified in the IRC, but the placement of the trap is and the need for individual valves would by default mean there would be a requirement for separate traps.

JL: My thoughts too.

Code says downstream of the shut off valve.

Dennis is correct. And if you look at the code commentary (if adopted in your area), there are more specifics.

installed downstream of the equipment shutoff
valve as close to the inlet of the equipment as practical.

The sediment trap shall be either a tee fitting with a capped nipple in
the bottom opening of the run of the tee or other device
approved as an effective sediment trap.

Appears to be within code.

The picture supplied shows it upstream of the shut off valve. Code says downstream

I stand corrected!

The code also says...

Where a sediment trap is not
incorporated as part of the gas utilization equipment,

There may be a sediment trap as part of the equipment. Doubt it though!

There needs to be an additional valve installed upstream of the sediment trap for the sediment trap.

The code requires those appliances to have a sediment trap but not their own sediment trap, thus one sediment trap can serve two appliances.

There needs to be an additional valve installed upstream of the sediment trap for the sediment trap.

JP: Say what?

This is scary! I understand what he's saying!!

Originally Posted by Wayne Carlisle

This is scary! I understand what he's saying!!

WC: OMG!

Originally Posted by Jerry Peck

There needs to be an additional valve installed upstream of the sediment trap for the sediment trap.

The code requires those appliances to have a sediment trap but not their own sediment trap, thus one sediment trap can serve two appliances.

Tsk, tsk. This seems like a logical solution but strict interpretation of the rule
"installed downstream of the equipment shutoff"
disallows that solution, IMO.

That new valve would allow service of the trap, which is likely the intent, but it is not the equipment shutoff. Or if it is, then why those other 2 valves downstream?

Originally Posted by John Kogel

Tsk, tsk. This seems like a logical solution but strict interpretation of the rule
"installed downstream of the equipment shutoff"
disallows that solution, IMO.

That new valve would allow service of the trap, which is likely the intent, but it is not the equipment shutoff. Or if it is, then why those other 2 valves downstream?

Tsk, tsk, John, read that code section again.

Here is a hint:
- G2420.5 (409.5) Equipment shutoff valve. Each appliance shall be provided with a shutoff valve separate from the appliance. The shutoff valve shall be located in the same room as the appliance, not further than 6 feet (1829 mm) from the appliance, and shall be installed upstream from the union, connector or quick disconnect device it serves. Such shutoff valves shall be provided with access.
- - Exception: Shutoff valves for vented decorative appliances and decorative appliances for installation in vented fireplaces shall not be prohibited from being installed in an area remote from the appliance where such valves are provided with ready access. Such valves shall be permanently identified and shall serve no other equipment.

Question: There are two appliances there in that same room, how many shut off valves are *REQUIRED* by the above code section for those two appliances?

Not how many you would like for convenience, but how many are "required"?

Answer hint: The answer is somewhere less than 2 shut of valves are "required" for that installation, but more than none.

Originally Posted by Jerry Peck

Tsk, tsk, John, read that code section again.

Here is a hint:
- G2420.5 (409.5) Equipment shutoff valve. Each appliance shall be provided with a shutoff valve separate from the appliance. The shutoff valve shall be located in the same room as the appliance, not further than 6 feet (1829 mm) from the appliance, and shall be installed upstream from the union, connector or quick disconnect device it serves. Such shutoff valves shall be provided with access.
- - Exception: Shutoff valves for vented decorative appliances and decorative appliances for installation in vented fireplaces shall not be prohibited from being installed in an area remote from the appliance where such valves are provided with ready access. Such valves shall be permanently identified and shall serve no other equipment.

Question: There are two appliances there in that same room, how many shut off valves are *REQUIRED* by the above code section for those two appliances?

Not how many you would like for convenience, but how many are "required"?

Answer hint: The answer is somewhere less than 2 shut of valves are "required" for that installation, but more than none.

Yeah but ........ You are suggesting a third valve be installed, not a single for two appliances.

Put it this way. If I hired you to repair the installation in the pic, would you install a third valve, or 2 downstream traps?

Originally Posted by John Kogel

Yeah but ........ You are suggesting a third valve be installed, not a single for two appliances.

Put it this way. If I hired you to repair the installation in the pic, would you install a third valve, or 2 downstream traps?

JK: It appears to me that he has no intention of answering this question where us mere mortals can grasp the meaning of the answer.

From 2003 IRC IFGC Commentary 409.5 "Each appliance, regardless of type, size, or location, must have its own dedicated shutoff valve to isolate the appliance from its gas supply. It is not the intent of this section to allow a single shutoff alve to control more than one appliance."....

Wish they had put that part into the code itself....

So, if you read the minds of the code authors, you would need to branch off with separate shutoffs to separate traps to separate connectors.

The problem with the setup shown is there is no way to service the trap without shutting down the meter.

Do you have pics of the flex connectors attachment to the appliances?
What are the input BTU ratings? Could be under gassed with that reduction from a 3/4" plus two ells + tee + connectors.
Bob

Originally Posted by Bob Harper

From 2003 IRC IFGC Commentary 409.5 "Each appliance, regardless of type, size, or location, must have its own dedicated shutoff valve to isolate the appliance from its gas supply. It is not the intent of this section to allow a single shutoff alve to control more than one appliance."....

Wish they had put that part into the code itself....

So, if you read the minds of the code authors, you would need to branch off with separate shutoffs to separate traps to separate connectors.

The problem with the setup shown is there is no way to service the trap without shutting down the meter.

Do you have pics of the flex connectors attachment to the appliances?
What are the input BTU ratings? Could be under gassed with that reduction from a 3/4" plus two ells + tee + connectors.
Bob

I understand the idea of the trap downstream but realistically if you have to "service" or clean a trap, you have much bigger problems than the inconvenience of shutting down the meter. But code is code...

So, if you read the minds of the code authors, you would need to branch off with separate shutoffs to separate traps to separate connectors.

BH: That particular set of minds has never been on my reading list.

Sorry, I did not photograph the appliance connections. Maybe next time.

Originally Posted by John Kogel

Yeah but ........ You are suggesting a third valve be installed, not a single for two appliances.

A single valve for each appliance is not required, only requires that each appliance HAVE a shut off valve.

Put it this way. If I hired you to repair the installation in the pic, would you install a third valve, or 2 downstream traps?

Being as you are asking *ME* how *I* would do it, and I am not a "minimum code" person, *I* would go beyond what is the required minimum and *I* would install two shut off valves (for *MY* convenience of shutting off one appliance and not both) and two sediment traps (would need to as the sediment traps is to be downstream from the shut off valve, of which there is now one for each appliance).

Again, that is how *I* would do it, BUT NOT how I would be *required to do it*.

Originally Posted by Bob Harper

From 2003 IRC IFGC Commentary 409.5 "Each appliance, regardless of type, size, or location, must have its own dedicated shutoff valve to isolate the appliance from its gas supply. It is not the intent of this section to allow a single shutoff alve to control more than one appliance."....

Wish they had put that part into the code itself....

Same here, but only a very few places adopt the commentary along with the codes, which makes the commentary enforceable along with the code.

Most use the commentary to help explain what the code is meaning to say, but, as the commentary is not adopted, the commentary is not enforceable.

Most use the commentary to help explain what the code is meaning to say, but, as the commentary is not adopted, the commentary is not enforceable.

JP: I must respectfully disagree. It makes sense to me that. as the commentary is a document published not only by the ICC, but also within their same publications as the IRC (et al.), and is intended to expound upon the code for the purposes of further defining and directing the application and enforcement of the code, it is also enforceable. If the code commentary is not being published with the purpose of providing more insight into the intent of the code authors, then WTF is it for? To take up space?

But, I might be otherwise convinced if you were to produce for me something in writing from the ICC to the contrary.

Originally Posted by A.D. Miller

JP: I must respectfully disagree. It makes sense to me that. as the commentary is a document published not only by the ICC, but also within their same publications as the IRC (et al.),

While that part is true, the ICC *CODES* are not even enforceable UNLESS ADOPTED, and, likewise, the commentary is not enforceable UNLESS ADOPTED also.

Originally Posted by Jerry Peck

While that part is true, the ICC *CODES* are not even enforceable UNLESS ADOPTED, and, likewise, the commentary is not enforceable UNLESS ADOPTED also.

JP: So then, am I hearing you say that the intent of the code is not enforceable?

From the Preface of the code commentary:"Commentary is to be used in conjunction with the IFGC and not as a substitute for the code. The COMMENTARY IS ADVISORY ONLY; the code official alone possesses the authority and responsibility for interpreting the code."

HTH,
Bob

Originally Posted by Bob Harper

From the Preface of the code commentary:"Commentary is to be used in conjunction with the IFGC and not as a substitute for the code. The COMMENTARY IS ADVISORY ONLY; the code official alone possesses the authority and responsibility for interpreting the code."

HTH,
Bob

BH: Ah, but that is the IFGC brought to us by the NFPA, and not the IRC.

Originally Posted by A.D. Miller

JP: So then, am I hearing you say that the intent of the code is not enforceable?

Aaron,

THE INTENT of the code is enforceable THROUGH THE *CODE* and the *AHJ*, NOT through the *Commentary*.

Originally Posted by Jerry Peck

Aaron,

THE INTENT of the code is enforceable THROUGH THE *CODE* and the *AHJ*, NOT through the *Commentary*.

JP: Be that as it may, the commentary is stating the intent of the code in a clearer fashion than in the code and is then clearly enforceable.

Originally Posted by A.D. Miller

JP: Be that as it may, the commentary is stating the intent of the code in a clearer fashion than in the code and is then clearly enforceable.

Aaron,

I'm not sure how to make this any clearer than "clearly" NOTHING WHATSOEVER is enforceable unless adopted as law by the entity.

With that entity being a governmental jurisdiction (also known as "political entity") and with them adopting the code be enactment of an ordinance, that code becomes enforceable within that governmental jurisdiction and is enforced by the AHJ retained by that governmental jurisdiction along with the enforcement powers given to the AHJ by the political entity are the interpretive powers given by and within the adopted code.

Being as the Commentary itself is not adopted (except the few areas which have actually adopted the Commentary too) and, being as the Commentary has not been adopted it cannot be used as an enforcement tool, however, the Commentary can be used by the AHJ as a reference for interpretations, and said interpretations are then enforceable - provided, of course, that the interpretations DO NOT VIOLATE THE CODE ITSELF as the code itself states same.

JP: It is, in this particular case, not my intent to be intentionally argumentative. I understand, though vehemently disagree with, the ICC's decision (if it indeed exists in writing anywhere) that the commentary is neither adoptable nor enforceable. Why publish the GD thing if it is not intended to be part and parcel of the code itself. There may indeed be morons at work there.

There is a method in my madness here. The TREC, with its usual bulldozer finesse, is rumored to be adopting a commentary to the already totally flawed Texas SOP. I am attempting to hone my argument against it being adopted as gospel that must be adhered to.

Originally Posted by A.D. Miller

I understand, though vehemently disagree with, the ICC's decision (if it indeed exists in writing anywhere) that the commentary is neither adoptable nor enforceable.

Aaron,

Your argument is flawed by not understanding what is being, and has been, stated, to wit: "that the commentary is neither adoptable nor enforceable"

The Commentary *IS* "adoptable" and some AHJ *HAVE* adopted it.

The Commentary, *once ADOPTED* *IS* "enforceable".

The Commentary is not enforceable if it has not been adopted.

If TREC wants to adopt the Commentary, there are no conditions (other than common sense - which seems to be lacking in TREC) which would prohibit TREC from adopting the Commentary any more than there are conditions which would prevent TREC from adopting the CFR (Code of Federal Regulations), and, adopting the Commentary to the IRC makes as much sense as adopting the CFR would.

Stupid people do stupid things, and it seems (from my distance and from what I have read about TREC) that each new set of stupid people on TREC try to out-do the last set of stupid people on TREC.

When will TREC get common sense? When people with common sense are on the governing board of TREC. When will that be? I have no idea.

Your argument is flawed by not understanding what is being, and has been, stated, to wit: "that the commentary is neither adoptable nor enforceable"

The Commentary *IS* "adoptable" and some AHJ *HAVE* adopted it.

The Commentary, *once ADOPTED* *IS* "enforceable".

JP: Maybe. But these guys will differ with you:

ICC Bulletin Board: Attic Ventilation / IBC Code Commentary

(other than common sense - which seems to be lacking in TREC)

JP: It is not even in their vocabulary.

Stupid people do stupid things, and it seems (from my distance and from what I have read about TREC) that each new set of stupid people on TREC try to out-do the last set of stupid people on TREC.

JP: The scary part is, at least to date, they have been quite successful at this.

When will TREC get common sense? When people with common sense are on the governing board of TREC. When will that be? I have no idea.

JP: Well, considering that most of the board consists of brokers and their attorneys, I would guess NEVER.

Originally Posted by A.D. Miller

JP: Maybe. But these guys will differ with you:

ICC Bulletin Board: Attic Ventilation / IBC Code Commentary

Aaron,

They are actually not disagreeing with me.

One said "The code commentary is NOT intended to be adopted ... ", which is NOT the same as saying the code commentary "is not adoptable" - your words.

Then that person reaffirms what I stated (further AGREEING with me ): " ... but it is produced to aid in understanding and comprehension ... " of the code, which means that " ... the Commentary can be used by the AHJ as a reference for interpretations, and said interpretations are then enforceable ... " - my words.

Originally Posted by Jerry Peck

A single valve for each appliance is not required, only requires that each appliance HAVE a shut off valve.



Being as you are asking *ME* how *I* would do it, and I am not a "minimum code" person, *I* would go beyond what is the required minimum and *I* would install two shut off valves (for *MY* convenience of shutting off one appliance and not both) and two sediment traps (would need to as the sediment traps is to be downstream from the shut off valve, of which there is now one for each appliance).

Again, that is how *I* would do it, BUT NOT how I would be *required to do it*.

Thanks, JP. That's what I would expect to see and that is what I would tell a client, they should have two downstream traps, traps close as possible to the equipment.

I suggest we recommend the better way the first time, instead of recommending the minimal code requirement, (which in this case is downright goofy .)

Originally Posted by Jerry Peck

Aaron,

They are actually not disagreeing with me.

One said "The code commentary is NOT intended to be adopted ... ", which is NOT the same as saying the code commentary "is not adoptable" - your words.

Then that person reaffirms what I stated (further AGREEING with me ): " ... but it is produced to aid in understanding and comprehension ... " of the code, which means that " ... the Commentary can be used by the AHJ as a reference for interpretations, and said interpretations are then enforceable ... " - my words.

JP: So then, it is still only your opinion, so far. I have rung the ICC bell for an interpretation. I'll let you know what they say.

Originally Posted by A.D. Miller

I have rung the ICC bell for an interpretation. I'll let you know what they say.

I'm guessing they will back up what they said in the commentary ... "not intended" to be adopted and enforced.

With any sense they will realize that THEY ... CANNOT ... STOP ... anyone from adopting their published material. And, once adopted, it can be enforced.

My question to TREC would be this: Why are you adopting "the Commentary" when you have not adopted the code they are commenting on?

But I guess that is just "common sense" ... which is lacking in TREC.

You will find on occasion, places where the code contradicts itself. There are task forces that write each section of the code such as IFGC vs. IMC vs IRC, etc. They try to proofread them to ensure harmonization but things slip through the cracks all the time. For instance, one minute the code tells you to size venting according to the appliance collar then later it gives you sizing tables, which often allow smaller vents.

FYI, a Code Supplement is simply those changes voted on by the ICC annually in between code cycles. They do not carry the force of law unless adopted by local law same as the code itself. It's a way of acknowledging upcoming changes in the next code cycle.

A Code Commentary typically contains the text of the entire code plus clearly delineated comments explaining the motives or objectives behind a particular section of code. Often, it is desireable to explain in language free from the legaleese of code as to just what they want to accomplish. Unfortunately, often the Commentator finds himself explaning matters that really should have been addressed more clearly in the code text itself. In fact, the Commentary is an essential tool in evaluating changes in successive code cycles. Also, the ICC tracks inquires for clarifications and rulings. If the present text does not clearly address an issue or causes more confusion, then it gets reviewed in the annual meetings for the Supplements.

FYI, anyone can submit suggestions for code changes. If you frequently run into a recurring issue with your local AHJ, I would suggest you write it up and present it to the appropriate ICC Cmte.

Aaron, I like to think of the Commentary as things you always wanted to say out loud but couldn't, sorta like the evidence not presented in court because the prosecutor knew it would get suppressed for technicalities but still you know it points a finger at the accused.

Also, keep in mind actions vs. reactions. Often taking one position will rain on someone else's parade. Back to my example: the appliance mfr.s may get a broad requirement in an effort to CYA, yet it presents problems for others. Case in point, oil burner venting. The IMC points you to NFPA 31 for oil. Yet all '31 and the IMC tell you about sizing the venting is to go by the appliance collar and mfrs. instructions. Since the instructions get lost after a few years and the mfr. drops these instructions from their website, where do you turn? You can contact the mfrs technical services and will probably get that old CYA appliance collar answer or you could refer to the Annex in the back of '31, which is not part of the code but there for your fun and amusement. You see, the typical oil fired boiler may have a 7" collar but fired at only 0.85 GPH at 130 psi for an input rate around 160,000 BTU/hr. At 30 feet, a 5" smooth-walled flue wouild probably suffice. So, with nominal 8x8" flue tiles with a 6.5" square ID, how are you going to reline this chimney? If you break out flue tiles to make room for that whopping 7" liner, you'll go broke becase few homeowners are willing to pay you what it should cost to perform this horrible task. Or, you can drop a 5.5" liner that draws like DaVinci and call it a day but be technically 'illegal'. Now, I could start an ad campaign telling homeowners the evils of certain brands with oversized flue collars and not the buy those boilers and opt instead for a more efficient brand, such as Buderus, that requires a 5" liner for that same input firing rate and purrs like a kitten. When faced with a brand new boiler with an oversized collar, I can reline it to work or reline it to code for double the money (if I can get it from the client).

How many other issues with the codes are there? A bunch. Interesting discussion.

JP and All:

Here is the ICC's official response:

September 2, 2009
Aaron
RE: International Code Commentaries.
Commentaries are not code or standard but are intended to provide guidance for the interpretation and application of the provisions that are in the code. They are not intended to be adopted as regulation. Many sections of the commentary language are not written in an enforceable format.
Further the commentaries are developed by staff based on years of experience in interpreting the code provisions as well as the development history of the various provisions. While individual sections have been reviewed by a few members - and sometimes by the proponent of a successful code change, the commentaries have not been vetted or approved by the ICC membership as the codes are approved.
The commentaries are intended to help the local code official understand the reason behind a code section, its development history, how it relates to other code provisions as well as providing some practical examples of the application of the code. As it is the duty and responsibility of each local code official charged with the administration of the code to provide interpretation of the code in their jurisdiction, the local code official can use the commentary as he/she sees fit, including ignoring it and interpreting the code in a different direction.
Therefore in direct answer to your questions.
Are they adoptable? A jurisdiction could adopt anything as local ordinance that it sees fit. The commentaries are not intended to be adopted as local law.
Are they enforceable by municipalities? If adopted as law, then they must be enforced based on local law. If a building official says that he/she is using the commentaries as the strict interpretation of their adopted International Code, then in a way they are being enforced.
Are they enforceable if not specifically adopted? Same answer as above.
If you have any additional questions please do not hesitate to contact us.


Kermit C. Robinson, CBO
Senior Technical Staff
5360 Workman Mill Rd
Whittier, CA 90601-2298
Phone: (562) 699-0541 ext 3317
Fax: (562) 699-4522
krobinson@iccsafe.org
www.iccsafe.org


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And, I concede. Argh!

Originally Posted by A.D. Miller

JP and All:

Here is the ICC's official response:

September 2, 2009
Aaron
RE: International Code Commentaries.
Commentaries are not code or standard but are intended to provide guidance for the interpretation and application of the provisions that are in the code. They are not intended to be adopted as regulation. Many sections of the commentary language are not written in an enforceable format.

Blah, blah, and blah.

More blah, blah, and blah.

Originally Posted by Jerry Peck

I'm guessing they will back up what they said in the commentary ... "not intended" to be adopted and enforced.

With any sense they will realize that THEY ... CANNOT ... STOP ... anyone from adopting their published material. And, once adopted, it can be enforced.

Gee ... ... and I said the same thing in a lot fewer words too.

Originally Posted by Jerry Peck

Gee ... ... and I said the same thing in a lot fewer words too.

JP: Yes, but at least they answer me . . .

Whew, long read... changing the configuration would've taken less time....did enjoy the read tho. Friendly bantor is always healthy.