Public Input No. 23-NFPA [ Section No. 1.1 [Excluding any

Transcription

1 of 222 1/26/2017 2:37 PM Public Input No. 23-NFPA [ Section No. 1.1 [Excluding any Sub-Sections] ] This standard shall apply to Class A, Class B, Class C, and Class D ovens, dryers, and furnaces; thermal oxidizers; and any other heated enclosure systems and related equipment used for processing of materials and related equipment. The term heated enclosures was too broad and could be interpreted to mean the building that the process equipment is located in. Related Public Inputs for This Document Related Input Public Input No. 24-NFPA [Section No. A.1.1] Relationship Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Sun May 01 18:46:12 EDT 2016 Resolution: FR-28-NFPA Statement: The term heated enclosures was too broad and could be interpreted to mean the building that the process equipment is located in. NFPA 86 Public Inputs with Responses Report Page 1 of 230

2 of 222 1/26/2017 2:37 PM Public Input No. 47-NFPA [ Section No ] Unless otherwise specified, the provisions of this standard shall not apply to facilities, equipment, structures, or installations that existed or were approved for construction or installation prior to the effective date of the standard. Where specified, the provisions of this standard shall be retroactive. Nowhere in NFPA 86 does the standard specify when the provisions of the standard are retroactive. Submitter Full Name: Kevin Carlisle Organization: Industrial Heating Equipment Association Affilliation: Industrial Heating Equipment Association Submittal Date: Fri Jun 03 14:39:39 EDT 2016 Resolution: FR-1-NFPA Statement: The language has been updated to remove redundancy. NFPA 86 Public Inputs with Responses Report Page 2 of 230

3 of 222 1/26/2017 2:37 PM Public Input No. 48-NFPA [ Section No ] In those cases where the authority having jurisdiction determines that the existing situation presents an unacceptable degree of risk, the authority having jurisdiction shall be permitted to apply retroactively any portions of this standard deemed appropriate. A A modification that does not alter the logical, mechanical, electrical, or pneumatic function or system capacity are considered maintenance, and thus retroactivity is not intended to apply. It might not be technical feasible to upgrade all elements of the oven to most recent edition of NFPA. Such determination is made by the AHJ. In addition, permit to use is site specific. If the oven is moved do a different location that is a place within the same building/site, it would be the decision of the AHJ whether or not to apply retroactivity in 1.4, but in general, the same building would normally be the same site/location. When equipment is moved to a new site/location, a new permit would be required, thus, retroactivity in 1.4 would normally apply. We recommend that the committee provide some guidance to address the ambiguity of this requirement. Submitter Full Name: Kevin Carlisle Organization: Industrial Heating Equipment Association Affilliation: Industrial Heating Equipment Association Submittal Date: Fri Jun 03 14:43:27 EDT 2016 Resolution: FR-24-NFPA Statement: This provides guidance to address the ambiguity of this requirement. NFPA 86 Public Inputs with Responses Report Page 3 of 230

4 of 222 1/26/2017 2:37 PM Public Input No. 8-NFPA [ Chapter 2 ] Chapter General. Referenced Publications The documents or portions thereof listed in this chapter are referenced within this standard and shall be considered part of the requirements of this document. 2.2 NFPA Publications. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA NFPA 10, Standard for Portable Fire Extinguishers, 2013 edition. NFPA 11, Standard for Low-, Medium-, and High-Expansion Foam, 2010 edition. NFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 2011 edition. NFPA 13, Standard for the Installation of Sprinkler Systems, 2013 edition. NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection, 2012 edition. NFPA 17, Standard for Dry Chemical Extinguishing Systems, 2013 edition. NFPA 17A, Standard for Wet Chemical Extinguishing Systems, 2013 edition. NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, 2014 edition. NFPA 30, Flammable and Combustible Liquids Code, 2015 edition. NFPA 31, Standard for the Installation of Oil-Burning Equipment, 2011 edition. NFPA 54, National Fuel Gas Code, 2015 edition. NFPA 55, Compressed Gases and Cryogenic Fluids Code, 2013 edition. NFPA 58, Liquefied Petroleum Gas Code, 2014 edition. NFPA 68, Standard on Explosion Protection by Deflagration Venting, 2013 edition. NFPA 70, National Electrical Code, 2014 edition. NFPA 79, Electrical Standard for Industrial Machinery, 2015 edition. NFPA 87, Recommended Practice for Fluid Heaters, 2015 edition. NFPA 91, Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Noncombustible Particulate Solids, 2010 edition. NFPA 750, Standard on Water Mist Fire Protection Systems, 2015 edition. 2.3 Other Publications ANSI Publications. American National Standards Institute, Inc., 25 West 43rd Street, 4th Floor, New York, NY ANSI Z50.1, Bakery Equipment Safety Requirements, NFPA 86 Public Inputs with Responses Report Page 4 of 230

5 of 222 1/26/2017 2:37 PM API Publications. American Petroleum Institute, 1220 L Street, NW, Washington, DC API STD 560, Fired Heaters for General Refinery Services, API RP 556, Instrumentation and Control Systems for Fired Heaters and Steam Generators, API RP 2001, Fire Protection in Refineries, ASME Publications. American Society of Mechanical Engineers, Three ASME International, Two Park Avenue, New York, NY Boiler and Pressure Vessel Code, ASME B31.1, Power Piping, ASME B31.3, Process Piping, ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA ASTM D 396 D396, Standard Specifications for Fuel Oils, b CGA Publications. Compressed Gas Association, 4221 Walney Road, 5th Floor George Carter Way, Suite 103, Chantilly, VA CGA G-4.1, Cleaning Equipment for Oxygen Service, IEC Publications. International Electrical Commission, 3, rue de Varembé, P.O. Box 131, CH , Geneva 20, Switzerland. IEC 61508, Functional Safety of Electrical/Electronic/Programmable Electronic Safety-Related Systems, Other Publications. Merriam-Webster s Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, References for Extracts in Mandatory Sections. NFPA 54, National Fuel Gas Code, 2015 edition. NFPA 69, Standard on Explosion Prevention Systems, 2014 edition. NFPA 70, National Electrical Code, 2014 edition. NFPA 85, Boiler and Combustion Systems Hazards Code,2011 edition. NFPA 99, Health Care Facilities Code, 2015 edition. NFPA 211, Standard for Chimneys, Fireplaces, Vents, and Solid Fuel Burning Appliances, 2013 edition. NFPA 302, Fire Protection Standard for Pleasure and Commercial Motor Craft, 2015 edition. NFPA 820, Standard for Fire Protection in Wastewater Treatment and Collection Facilities, 2012 edition. NFPA 86 Public Inputs with Responses Report Page 5 of 230

6 of 222 1/26/2017 2:37 PM Referenced current SDO names, addresses, standard names, numbers, and editions. Related Public Inputs for This Document Related Input Public Input No. 9-NFPA [Chapter M] Relationship Submitter Full Name: Aaron Adamczyk Organization: [ Not Specified ] Submittal Date: Tue Jul 21 16:03:08 EDT 2015 Resolution: FR-3-NFPA Statement: Referenced current SDO names, addresses, standard names, numbers, and editions. Staff is instructed to verify updated references. NFPA 86 Public Inputs with Responses Report Page 6 of 230

7 of 222 1/26/2017 2:37 PM Public Input No. 71-NFPA [ New Section after 3.3 ] Definition of Chambers: (a) Heating Chamber, (b) Combustion Chamber, (c) Work Chamber A lot of the terms within the definitions refer to combustion chambers and work chambers without defining the terms. This gets more muddled in as well as (B) and (1) calls out 'heating chambers' without a full definition of the term. Definition of Chambers: (a) Heating Chamber, (b) Combustion Chamber, (c) Work Chamber A lot of the terms within the definitions refer to combustion chambers and work chambers without defining the terms. This gets more muddled in as well as (B) and (1) calls out 'heating chambers' without a full definition of the term. Submitter Full Name: Robert Davis Organization: Alcoa Submittal Date: Thu Jun 09 13:45:15 EDT 2016 Resolution: The submitter is invited to present definitions but this submittal does not include suggested language. A Committee Input(CI-1) has been created to consider creating definitions for these terms as the Committee would like to define these terms in the future. NFPA 86 Public Inputs with Responses Report Page 7 of 230

8 of 222 1/26/2017 2:37 PM Public Input No. 75-NFPA [ New Section after ] TITLE OF NEW CONTENT 3.3.x Cooling systems. 3.3.x.1 Closed cooling systems. A cooling system that does not utilize unrestricted sight drain(s) observable by the operator(s). 3.3.x.2 Open cooling systems. A cooling system that utilizes unrestricted sight drain(s) observable by the operator(s). Since closed loop and open loop are used in multiple places in the standard (i.e. Chapters 5, 13, and 14), closed loop and open loop should be defined. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Thu Jun 09 16:09:24 EDT 2016 Resolution: FR-30-NFPA Statement: Since closed loop and open loop are used in multiple places in the standard (i.e. Chapters 5, 13, and 14), closed loop and open loop should be defined. NFPA 86 Public Inputs with Responses Report Page 8 of 230

9 of 222 1/26/2017 2:37 PM Public Input No. 50-NFPA [ New Section after ] Design pressure: The maximum pressure of a gas piping system or gas train is that can be continuously sustained, contained or controlled. The proposal standardizes on pressure rating terms and uses the ASME B31.3 terms in the same way. Submitter Full Name: Kevin Carlisle Organization: Affilliation: Industrial Heating Equipment Association Industrial Heating Equipment Association Submittal Date: Fri Jun 03 14:50:18 EDT 2016 Resolution: CI-5-NFPA Statement: The proposal standardizes on pressure rating terms and uses the ASME B31.3 terms in the same way. This may include working pressure and rated pressure. The committee recognizes pressure definition confusion and a task group has been formed to address this topic. NFPA 86 Public Inputs with Responses Report Page 9 of 230

10 0 of 222 1/26/2017 2:37 PM Public Input No. 68-NFPA [ New Section after ] Equipment. Also known as an oven, furnace, or dryer. Associated equipment; Parts of an oven, furnace, or dryer specially designed for executing a task, such as a tool, blower, valve, switch, machine, device, component. Auxiliary equipment : looking to committee members to define this The term equipment, Associated equipment and Auxiliary Equipment are used. We suggest a review of the standard and define the terms. The term Equipment is used many places with different meanings The term means oven or dryer in these para (2) Safety Interlock Afterburner (Direct Thermal Oxidizer) Continuous Pilot Line Pressure Regulator * Safety Device Vacuum Pumping System Equipment Isolation Valve Water-Cooling System for Vacuum Furnaces Approvals, Plans, and Specifications Aprovals, Plans, and Specifications Safety Labeling Location in Regard to Stock, Processes, and Personnel The term means device or components in Operator *Location NFPA 86 Public Inputs with Responses Report Page 10 of 230

11 1 of 222 1/26/2017 2:37 PM The term means device or components in control equipment Meaning if the term is not known in these paragraphs * * 5.5 Mountings and Auxiliary Equipment Auxiliary equipment Term is used in Associated equipment Term is used in Submitter Full Name: Kevin Carlisle Organization: Industrial Heating Equipment Association Affilliation: Industrial Heating Equipment Association Submittal Date: Fri Jun 03 15:46:06 EDT 2016 Resolution: No language was proposed, submitter would like to resolve and come back with new language. NFPA 86 Public Inputs with Responses Report Page 11 of 230

12 2 of 222 1/26/2017 2:37 PM Public Input No. 169-NFPA [ Section No ] * Explosion-Resistant (Radiant Tube). A radiant tube or radiant tube heat recovery system that does not fail catastrophically when subjected to the maximum deflagration pressure caused by the ignition of an accumulation of a stoichiometric mixture of the selected fuel(s) and air. ELIMINATE THIS SECTION The current NFPA Standard for Ovens and Furnaces implies that metallic radiant tubes are safer than other high temperature materials of construction such as ceramics and composites. Alternative non-metallic materials currently in industrial radiant tube service include mullites, sialons, silicon nitrides, siliconized silicon carbides and silicon / silicon carbide composites. The standard excludes and/or favorably treats metallic radiant tubes in terms of relaxed requirements for: Pre-ignition Purging Sections , A , & Safety Shut-Off Valves Section Flame Supervision Section This special treatment for metallic radiant tubes ignores several decades of industry experience where deflagration / explosion has not proved to be a significant risk factor for non-metallic materials, or at minimum the incident losses are no different than metallic tubes used in equivalent service. In actual operation most metallic radiant tubes used in carburizing, carbonitriding and higher temperature processing periodically experience open-crack, thru-wall hole and/or perforation failures due to material creep distortion, carburization corrosion/embrittlement and/or weld stress fracture. Any risks posed by open metallic tube failures are no different than those of non-metallic tubes, regardless of whether combustible gases flow into the furnace chamber or, vice versa, into the radiant tube. For the processes cited above metallic failures generally occur every three to five years (sometimes sooner) mandating radiant tube replacement to maintain the integrity of the process atmosphere and quality of production. While ceramic and composite tubes available to the industrial furnace users do not experience the progressive failure modes of metallic tubes, they are more susceptible to mechanical impact and less tolerable of thermo-mechanical stress. Failure of non-metallic radiant tubes has the same effect on the furnace atmosphere and production quality, also mandating their replacement. When radiant metallic tube applications are optimally designed (so that the surface temperatures are uniform and not excessive for the specific alloy employed), they are just as likely, if not more likely, to fail catastrophically compared with ceramic and composite tubes under the same service conditions in carburizing, carbonitriding and higher temperature atmospheres. Furthermore, consideration of radiant tube durability should not be based on new material properties, but rather on radiant tubes that are at or near the end of their useful service lives. It is at this point that a tube failure-related incident is most likely to occur. To be logically consistent both metallic and non-metallic radiant tubes used at elevated temperatures NFPA 86 Public Inputs with Responses Report Page 12 of 230

13 3 of 222 1/26/2017 2:37 PM (e.g. above 1550 F) must be treated the same. For example, if flame supervision is required for non-metallic radiant tubes, then it should be required for metallic radiant tubes as well. An alternative approach might be to require that metallic tubes are removed from use before they are projected to fail (based on a documented analysis of service life in the specific application). In practice it is rare that adequate information is available to base such projections with certainty, therefore we do not envision that this risk avoidance tactic can be reliably adopted by industry. On the other hand, if metallic radiant tubes are proven to operate in service with little or no deterioration at lower temperatures (e.g. below 1550 F), a specific reliability analysis might support the conclusion that catastrophic failure is improbable in that application. The testing prescribed in Section A to validate the explosion-resistance of non-metallic materials ignores the failure modes of metallic tubes in carburizing, carbonitriding and higher temperature processing. Normative service failures (open-cracks, thru-wall holes and/or perforations) result in metallic radiant tubes incapable of supporting any pressurization whatsoever. Furthermore, the exclusion of metallic materials from these validity protocols per Section ignores the design pressure ratings of radiant tubes (as a function of wall thickness, alloy strength and weld integrity). Also longer-term metallic tube wall deterioration due to spalling and embrittlement (which inevitably occurs in high temperature service) is not considered. Related Public Inputs for This Document Related Input Public Input No. 170-NFPA [Sections , ] Public Input No. 172-NFPA [Section No ] Public Input No. 173-NFPA [Section No ] Public Input No. 174-NFPA [Section No. A ] Public Input No. 175-NFPA [Section No. A ] Public Input No. 176-NFPA [Section No. A ] Public Input No. 171-NFPA [Sections , ] Relationship Submitter Full Name: Curt Colopy Organization: INEX Incorporated Submittal Date: Wed Jun 29 15:47:11 EDT 2016 Resolution: The committee has addressed these issues throughout the text and it is unnecessary to delete the definition at this time. NFPA 86 Public Inputs with Responses Report Page 13 of 230

14 4 of 222 1/26/2017 2:37 PM Public Input No. 55-NFPA [ New Section after ] Inlet gas pressure : gas pressure measured at the equipment isolation valve. Term is used in proposal for overpressure protection and it is suggested that this term replace SUPPLY PRESSURE through the standard except in A , where this should supply pressure regulator should be gas appliance (equipment) regulator. Submitter Full Name: Kevin Carlisle Organization: Affilliation: Industrial Heating Equipment Association Industrial Heating Equipment Association Submittal Date: Fri Jun 03 15:07:36 EDT 2016 Resolution: It is unclear the specific application that this definition is required for, the CI-5 task group will address any updates for the second draft. NFPA 86 Public Inputs with Responses Report Page 14 of 230

15 15 of 222 1/26/2017 2:37 PM Public Input No. 142-NFPA [ New Section after ] Impulse Pipe A pipe or tube used to connect an instrument to a point in the system at which a process variable is to be measured. Adding definition to a term that is currently used in annex material and will be used in proposed mandatory language (new ). Related Public Inputs for This Document Related Input Public Input No. 140-NFPA [New Section after 7.4.4] Public Input No. 141-NFPA [New Section after A.7.3.8] Relationship Submitter Full Name: Geoffrey Raifsnider Organization: Global Finishing Solutions Submittal Date: Tue Jun 28 08:23:32 EDT 2016 Resolution: FR-31-NFPA Statement: Adding definition to a term that is currently used in annex material and will be used in proposed mandatory language (new ). NFPA 86 Public Inputs with Responses Report Page 15 of 230

16 16 of 222 1/26/2017 2:37 PM Public Input No. 165-NFPA [ New Section after ] TITLE OF NEW CONTENT 3.3.3x Impulse Pipe. A pipe or tube used to connect an instrument to a point in the system at which a process variable is to be measured. PI to propose requirements for impulse lines used for safety devices. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Tue Jun 28 15:04:49 EDT 2016 Resolution: FR-31-NFPA Statement: Adding definition to a term that is currently used in annex material and will be used in proposed mandatory language (new ). NFPA 86 Public Inputs with Responses Report Page 16 of 230

17 7 of 222 1/26/2017 2:37 PM Public Input No. 95-NFPA [ Section No ] Proved Low-Fire Start Ignition Interlock. A burner start interlock in which a control sequence ensures that a high low or modulated burner is at a reduced specified firing rate for reliable ignition before the burner can be ignited. The defined term Proved Low-Fire Start Interlock is not used in the Standard. This public input recommends that the term be changed and used in the mandatory text. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Fri Jun 10 13:19:42 EDT 2016 Resolution: FR-66-NFPA Statement: The definition has only been used once in the text, and will now be addressed where used. NFPA 86 Public Inputs with Responses Report Page 17 of 230

18 8 of 222 1/26/2017 2:37 PM Public Input No. 79-NFPA [ Section No ] Air Fuel Gas Mixer. A mixer that combines air and fuel gas in the proper specific proportions for use in combustion. Existing text implies a flammable mixture, but mixers could also make mixtures for fuel equivalency that are not in the flammable range. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Thu Jun 09 16:23:49 EDT 2016 Resolution: FR-32-NFPA Statement: Existing text implies a flammable mixture, but mixers could also make mixtures for fuel equivalency that are not in the flammable range. NFPA 86 Public Inputs with Responses Report Page 18 of 230

19 9 of 222 1/26/2017 2:37 PM Public Input No. 81-NFPA [ Section No ] Mixing Blower. A motor-driven blower to supply air fuel gas mixtures for combustion through one or more fuel burners or nozzles on a single-zone industrial heating appliance or on each control zone of a multizone installation. Mixing machines operated at 10 in. w.c. (2.49 kpa) or less static pressure are considered mixing blowers. This creates confusion in proposal for (B) and its annex. Deleting it here and adding it under requirements in provides clarity. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Thu Jun 09 16:28:00 EDT 2016 Resolution: FR-33-NFPA Statement: This creates confusion in proposal for (B) and its annex. Deleting it here and adding it under requirements in provides clarity. NFPA 86 Public Inputs with Responses Report Page 19 of 230

20 0 of 222 1/26/2017 2:37 PM Public Input No. 51-NFPA [ New Section after ] Rated pressure The maximum internal and external pressures that the materials, devices, or components are designed to contain or control. This term is part of a proposal to the overpressure protection requirements Submitter Full Name: Kevin Carlisle Organization: Affilliation: Industrial Heating Equipment Association Industrial Heating Equipment Association Submittal Date: Fri Jun 03 14:53:22 EDT 2016 Resolution: It is unclear the specific application that this definition is required for, the CI-5 task group will address any updates for the second draft. NFPA 86 Public Inputs with Responses Report Page 20 of 230

21 1 of 222 1/26/2017 2:37 PM Public Input No. 41-NFPA [ New Section after ] Safety service: a device used to perform a safety function and is either listed and labeled to the proper standard or has special performance features that give it significantly better reliability for the service intended compared to devices intended for general purpose service. The term safety service is used, but not defined. Since this is a critical feature about a device, I suggest we define it. Submitter Full Name: Kevin Carlisle Organization: Karl Dungs Inc Submittal Date: Fri Jun 03 13:12:28 EDT 2016 Resolution: Safety service is too general a term to be specifically defined as suggested. The committee will be reviewing the definitions for safety relay and safety device for possible revisions or explanatory material. NFPA 86 Public Inputs with Responses Report Page 21 of 230

22 2 of 222 1/26/2017 2:37 PM Public Input No. 45-NFPA [ New Section after ] Combustion Safety Service An application related to safety for an oven which uses combustion and requirements for hazards are addressed in a device standard. The term combustion safety service is used, but not defined. Since this is a critical feature about a device, I suggest we define it. Used in Submitter Full Name: Kevin Carlisle Organization: Industrial Heating Equipment Association Affilliation: Industrial Heating Equipment Association Submittal Date: Fri Jun 03 14:23:54 EDT 2016 Resolution: Combustion safety service is too general a term to be specifically defined as suggested. NFPA 86 Public Inputs with Responses Report Page 22 of 230

23 3 of 222 1/26/2017 2:37 PM Public Input No. 80-NFPA [ New Section after ] TITLE OF NEW CONTENT 3.x.x Safety Blowout. A device or combination of devices that quench a flame, relieve pressure and provide a means for automatic shut-off of the air-gas mixture flow in the event of a flashback in air-fuel gas mixture piping. New definition, used in (E). Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Thu Jun 09 16:25:51 EDT 2016 Resolution: FR-34-NFPA Statement: New definition, used in (E). NFPA 86 Public Inputs with Responses Report Page 23 of 230

24 4 of 222 1/26/2017 2:37 PM Public Input No. 42-NFPA [ New Section after ] Token (minimal) Relief valve: a reduced port, relief valve, intended to vent a small volume of gas pressure when the gas train is in a no-flow (shutdown) state. The excessive pressure condition is an increased pressure between the regulator and the downstream safety shutoff valve, usually caused by too high of lock-up pressure or due to an increase of temperature. These devices do not act as an OPD under a continuous demand condition and do not act as an OPD when an upstream regulator fails NPFA 86 uses the term, so it would be good to define it. Submitter Full Name: Kevin Carlisle Organization: Affilliation: Industrial Heating Equipment Association Industrial Heating Equipment Association Submittal Date: Fri Jun 03 14:13:32 EDT 2016 Resolution: A (previous A ) already addresses this issue. The annex material was previously misnumbered. NFPA 86 Public Inputs with Responses Report Page 24 of 230

25 5 of 222 1/26/2017 2:37 PM Public Input No. 49-NFPA [ New Section after ] Maximum Working Pressure. The maximum pressure of a pressure vessel that can be continuously sustained, contained or controlled The proposal standardizes on pressure rating terms and uses the ASME B31.3 terms in the same way. Submitter Full Name: Kevin Carlisle Organization: Affilliation: Industrial Heating Equipment Association Industrial Heating Equipment Association Submittal Date: Fri Jun 03 14:48:07 EDT 2016 Resolution: It is unclear the specific application that this definition is required for, the CI-5 task group will address any updates for the second draft. NFPA 86 Public Inputs with Responses Report Page 25 of 230

26 6 of 222 1/26/2017 2:37 PM Public Input No. 143-NFPA [ New Section after ] TITLE OF NEW CONTENT Flame Curtain is lacking a definition in NFPA 86. If a Flame Curtain is a burner, then it requires (2) SSOV s per Insert a definition as follows and renumber subsequent definitions: Flame Curtain. A Flame Curtain is a type of line burner mounted outside of a furnace door and used to provide an ignition source for flammable gasses exiting the furnace through the door when opened or to reduce the ingress of air into a furnace to minimize process upsets. Flame Curtain is lacking a definition in NFPA 86. If a Flame Curtain is a burner, then it requires (2) SSOV s per Related Public Inputs for This Document Related Input Public Input No. 144-NFPA [Section No ] Public Input No. 145-NFPA [Section No. A ] Public Input No. 146-NFPA [New Section after A ] Relationship Submitter Full Name: Joseph Kozma III Organization: AFC-Holcroft LLC Submittal Date: Tue Jun 28 12:00:22 EDT 2016 Resolution: FR-7-NFPA Statement: Flame Curtain is lacking a definition in NFPA 86. Chapter 13 eliminates at the double SSOV requirement for Flame Curtains. NFPA 86 Public Inputs with Responses Report Page 26 of 230

27 7 of 222 1/26/2017 2:37 PM Public Input No. 76-NFPA [ Section No ] * Each portion of a closed cooling system Closed cooling systems that can exceed the design pressure shall be equipped with the following: (1) Pressure relief (2) Flow switches equipped with An audible and visual alarms alarm upon loss of coolant flow The existing wording (i.e. Each portion and switches ) implies that multiple pressure reliefs and flow switches are a requirement of the standard. Common (i.e. non-isolated) piping portions of a cooling system only require a single point of pressure relief and a single flow switch for alarming. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Thu Jun 09 16:13:10 EDT 2016 Resolution: FR-36-NFPA Statement: The existing wording (i.e. Each portion and switches ) implies that multiple pressure reliefs and flow switches are a requirement of the standard. Common (i.e. non-isolated) piping portions of a cooling system only require a single point of pressure relief and a single flow switch for alarming. NFPA 86 Public Inputs with Responses Report Page 27 of 230

28 8 of 222 1/26/2017 2:37 PM Public Input No. 77-NFPA [ Section No ] Open cooling systems utilizing unrestricted sight drains observable by the operator shall not require pressure relief or loss of flow switches alarming. 1. Since open cooling systems has been defined, no further clarification is required (i.e. utilizing unrestricted. ). 2. The addition of pressure relief or in paragraph clarifies that for pressure relief is not required for open cooling systems. 3. Paragraph is more an exception to paragraph than an actual requirement. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Thu Jun 09 16:15:25 EDT 2016 Resolution: FR-37-NFPA Statement: 1. Since open cooling systems has been defined, no further clarification is required (i.e. utilizing unrestricted. ). 2. The addition of pressure relief or in paragraph clarifies that for pressure relief is not required for open cooling systems. 3. Paragraph is more an exception to paragraph than an actual requirement. NFPA 86 Public Inputs with Responses Report Page 28 of 230

29 29 of 222 1/26/2017 2:37 PM Public Input No. 78-NFPA [ Section No ] Where a cooling system is critical to continued safe operation of a furnace, the : (1) The cooling system shall continue to operate after a safety shutdown or power failure. (2) The furnace manufacturer s operating instructions shall state, in effect, that the cooling system is critical for safe operation. It is the responsibility of the furnace manufacturer to inform the end user that the cooling system (typically the water supply) is critical to the safe operation of the furnace. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Thu Jun 09 16:19:01 EDT 2016 Resolution: FR-38-NFPA Statement: It is the responsibility of the furnace manufacturer to inform the end user that the cooling system (typically the water supply) is critical to the safe operation of the furnace. NFPA 86 Public Inputs with Responses Report Page 29 of 230

30 0 of 222 1/26/2017 2:37 PM Public Input No. 115-NFPA [ Section No ] Furnace hydraulic systems shall utilize either fire-resistant fluids or flammable hydraulic fluids where approved and where failure of hydraulic system components cannot result in a fire hazard. Adding the word clarifies the provision and makes it easier to read. Submitter Full Name: Jim Muir Organization: Affilliation: Building Safety Division, Clark County, Washington NFPA's Building Code Development Committee (BCDC) Submittal Date: Thu Jun 16 17:52:46 EDT 2016 Resolution: FR-69-NFPA Statement: Clarification of verbiage on flammable hydraulic fluids and those that do not need to be approved. NFPA 86 Public Inputs with Responses Report Page 30 of 230

31 1 of 222 1/26/2017 2:37 PM Public Input No. 103-NFPA [ Section No ] 5.3.1* Fuel-fired furnaces and furnaces that contain flammable liquids, gases, or combustible dusts shall be equipped with unobstructed explosion relief for freely relieving internal explosion pressures except in the following cases: (1) Explosion relief shall not be required on furnaces with shell construction having 3 16 in. (4.8 mm) or heavier steel plate shells reinforced with structural steel beams and buckstays that support and retain refractory or insulating materials that are required for temperature endurance, which makes them unsuitable for the installation of explosion relief. (2) Explosion-relief panels shall not be required for low-oxygen atmosphere ovens designed and protected in accordance with (3) The requirements for explosion relief shall not apply to thermal oxidizers. (4) The requirements for explosion relief shall not apply to Class D furnaces. (5) Explosion-relief panels shall not be required in the work chamber of indirect fired ovens where it is demonstrated by calculation that the combustible concentration in the work chamber cannot exceed 25 percent of the lower flammable limit (LFL) under any conditions. (6) (7) * Explosion - relief panels shall not be required in the work chamber of direct fired ovens where all of the following are conditions are met: a) It is demonstrated by calculation that the combustible concentration in the work chamber cannot exceed 25 percent of the lower flammable limit (LFL) under any conditions. b) *LFL aspirating detection is provided to monitor flammable concentrations in each direct fired combustion chamber and interlocked to prevent start-up or initiate a safety shutdown upon detecting a concentration of no more than 10% LFL. c) Where recirculating direct fired systems are implemented, the LFL aspirating detection system shall be calibrated for all possible flammable gases that could be present as a result of the process, or incomplete combustion. d) Aspirating LFL detection sensing intake ports shall be located in the region of each combustion chamber that is most likely to accumulate flammable gases as a result of a gas leak or incomplete combustion. e) Documentation of LFL detection system calibration shall be maintained and posted at each system. f) LFL detection systems shall be calibrated at least annually or more often if recommended by the manufacturer for intended service. * Explosion relief shall not be required for the combustion chamber of an indirect-fired oven that incorporates a single combustion airflow path through the heat exchanger and does not recirculate the products of combustion. For Oven/Furnace "5.3 Explosion Relief", some automotive clients use aspirating LFL detection in the NFPA 86 Public Inputs with Responses Report Page 31 of 230

32 2 of 222 1/26/2017 2:37 PM combustion chamber of oven heater boxes. The main reason for excluding direct fired ovens from the "exception language" in 5.3.1(5) is that direct fired ovens can introduce an explosive atmosphere into the work chamber due to incomplete combustion and gas leaks. With LFL detection implemented to trip at a level well below 25% LFL and interlocked to interrupt start-up and running permissives, the new provision should be allowed. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Fri Jun 10 13:47:12 EDT 2016 Resolution: FR-8-NFPA Statement: For Item 1: Different construction shells are available for this application and should be allowed by the standard if determined to be equivalent. For Item 2: The wrong section is referenced. The correct section to reference is 11.7 "Low-Oxygen Atmosphere Class A Ovens with Solvent Recovery". For Oven/Furnace "5.3 Explosion Relief", some users use aspirating LFL detection in the combustion chamber of oven heater boxes. The main reason for excluding direct fired ovens from the "exception language" in 5.3.1(6) is that direct fired ovens can introduce an explosive atmosphere into the work chamber due to incomplete combustion and gas leaks. With LFL detection implemented to trip at a level well below 25% LFL and interlocked to interrupt start-up and running permissives. Annex materiel related to new (6) changes this item to 5.3.1(7). NFPA 86 Public Inputs with Responses Report Page 32 of 230

33 3 of 222 1/26/2017 2:37 PM Public Input No. 13-NFPA [ Section No ] 5.3.1* Fuel-fired furnaces and furnaces that contain flammable liquids, gases, or combustible dusts shall be equipped with unobstructed explosion relief for freely relieving internal explosion pressures except in the following cases: (1) Explosion relief shall not be required on furnaces with shell construction having 3 16 in. (4.8 mm) or heavier steel plate shells reinforced with structural steel beams and buckstays that support and retain refractory or insulating materials that are required for temperature endurance, which makes them unsuitable for the installation of explosion relief. (2) Explosion-relief panels shall not be required for low-oxygen atmosphere ovens designed and protected in accordance with (3) The requirements for explosion relief shall not apply to thermal oxidizers. (4) The requirements for explosion relief shall not apply to Class D furnaces. (5) Explosion-relief panels shall not be required in the work chamber of indirect fired ovens where it is demonstrated by calculation that the combustible concentration in the work chamber cannot exceed 25 percent of the lower flammable limit (LFL) under any conditions. (6) * Explosion relief shall not be required for the combustion chamber of an indirect-fired oven that incorporates a single combustion airflow path through the heat exchanger and does not recirculate the products of combustion. The wrong section is referenced. The correct section to reference is 11.7 "Low-Oxygen Atmosphere Class A Ovens with Solvent Recovery". Notes: 1. Section "Time Flow Purge Method..." applies to Class C furnaces and has nothing to do with explosion relief. 2. The 2011 Edition is in error also. 3. The 2007 Edition is correct. Submitter Full Name: Mark Stender Organization: Surface Combustion, Inc. Submittal Date: Wed Sep 09 15:31:45 EDT 2015 NFPA 86 Public Inputs with Responses Report Page 33 of 230

34 4 of 222 1/26/2017 2:37 PM Resolution: FR-8-NFPA Statement: For Item 1: Different construction shells are available for this application and should be allowed by the standard if determined to be equivalent. For Item 2: The wrong section is referenced. The correct section to reference is 11.7 "Low-Oxygen Atmosphere Class A Ovens with Solvent Recovery". For Oven/Furnace "5.3 Explosion Relief", some users use aspirating LFL detection in the combustion chamber of oven heater boxes. The main reason for excluding direct fired ovens from the "exception language" in 5.3.1(6) is that direct fired ovens can introduce an explosive atmosphere into the work chamber due to incomplete combustion and gas leaks. With LFL detection implemented to trip at a level well below 25% LFL and interlocked to interrupt start-up and running permissives. Annex materiel related to new (6) changes this item to 5.3.1(7). NFPA 86 Public Inputs with Responses Report Page 34 of 230

35 5 of 222 1/26/2017 2:37 PM Public Input No. 65-NFPA [ Section No ] 5.3.1* Fuel-fired furnaces and furnaces that contain flammable liquids, gases, or combustible dusts shall be equipped with unobstructed explosion relief for freely relieving internal explosion pressures except in the following cases: (1) Explosion relief shall not be required on furnaces with equivalent strength of steel plate or expanded metal shell construction having 3 16 in. (4.8 mm) or heavier steel plate shells reinforced with structural steel beams and buckstays that support and retain refractory or insulating materials that are required for temperature endurance, which makes them unsuitable for the installation of explosion relief. (2) Explosion-relief panels shall not be required for low-oxygen atmosphere ovens designed and protected in accordance with (3) The requirements for explosion relief shall not apply to thermal oxidizers. (4) The requirements for explosion relief shall not apply to Class D furnaces. (5) Explosion-relief panels shall not be required in the work chamber of indirect fired ovens where it is demonstrated by calculation that the combustible concentration in the work chamber cannot exceed 25 percent of the lower flammable limit (LFL) under any conditions. (6) * Explosion relief shall not be required for the combustion chamber of an indirect-fired oven that incorporates a single combustion airflow path through the heat exchanger and does not recirculate the products of combustion. The sentence is limiting the use of other techniques to do the steel structure, specially the expanded metal, which is worldwide used for ceramic fiber isolation with the same results. Substantiation: A finite element analysis demonstrate that the expanded metal can support a total load of 100 lb/ft2 without reaching its ultimate strength (100 lb/ft2 is calculated from the yield strength of ASTM A283 and very similar to A36 and others, which is PSI ) Submitter Full Name: Kevin Carlisle Organization: Industrial Heating Equipment Association Affilliation: Industrial Heating Equipment Association Submittal Date: Fri Jun 03 15:39:43 EDT 2016 NFPA 86 Public Inputs with Responses Report Page 35 of 230

36 6 of 222 1/26/2017 2:37 PM Resolution: FR-8-NFPA Statement: For Item 1: Different construction shells are available for this application and should be allowed by the standard if determined to be equivalent. For Item 2: The wrong section is referenced. The correct section to reference is 11.7 "Low-Oxygen Atmosphere Class A Ovens with Solvent Recovery". For Oven/Furnace "5.3 Explosion Relief", some users use aspirating LFL detection in the combustion chamber of oven heater boxes. The main reason for excluding direct fired ovens from the "exception language" in 5.3.1(6) is that direct fired ovens can introduce an explosive atmosphere into the work chamber due to incomplete combustion and gas leaks. With LFL detection implemented to trip at a level well below 25% LFL and interlocked to interrupt start-up and running permissives. Annex materiel related to new (6) changes this item to 5.3.1(7). NFPA 86 Public Inputs with Responses Report Page 36 of 230

37 7 of 222 1/26/2017 2:37 PM Public Input No. 152-NFPA [ Section No ] * Where primary or secondary combustion air is provided mechanically, combustion airflow or pressure shall be proven and interlocked with the safety shutoff valves so that fuel gas cannot be admitted prior to establishment of combustion air and so that the gas is shut off in the event of combustion air failure. (See and 8.7.4) Reference needed as part of related PI. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Tue Jun 28 14:26:25 EDT 2016 Resolution: FR-40-NFPA Statement: Reference needed as part of related FR's. NFPA 86 Public Inputs with Responses Report Page 37 of 230

38 8 of 222 1/26/2017 2:37 PM Public Input No. 112-NFPA [ Sections 6.2.3, ] Sections 6.2.3, New definitions Gas piping system ; All gas confining pipe, tubing, valves, and fittings from the point of delivery to the outlet of the equipment isolation valve (see NPFA 54). Fuel gas train ; All gas confining pipe, tubing, valves, devices, controls, and fittings from outlet of the equipment isolation valve up to the burner Fuel Gas Supply Piping System * An emergency shutoff valve shall be provided that meets the following requirements: (1) It shall be remotely located away from the furnace so that fire or explosion at a furnace does not prevent access to the valve. (2) It shall be readily accessible. (3) It shall have permanently affixed visual indication of the valve position. (4) A removable handle shall be permitted provided all the following requirements are satisfied: (5) The valve position shall be clearly indicated whether the handle is attached or detached. (6) The valve handle shall be tethered to the gas main no more than 3 ft (1 m) from the valve in a manner that does not cause personnel safety issues and that allows trouble-free reattachment of the handle and operation of the valve without untethering the handle. (7) It shall be able to be operated from full open to full close and return without the use of tools Installation of LP-Gas storage and handling systems shall comply with NFPA 58, Liquefied Petroleum Gas Code Piping from the point of delivery to the equipment isolation valve The gas piping system shall comply with NFPA 54, National Fuel Gas Code. (See ) An equipment isolation valve shall be provided Equipment Fuel Gas Piping. Fuel gas piping system shall be sized to provide flow rates and pressure to maintain a stable pressure to the fuel gas train NFPA 86 Public Inputs with Responses Report Page 38 of 230

39 9 of 222 1/26/2017 2:37 PM Equipment Isolation Valves Valve. Equipment An equipment isolation valves valve shall meet the following requirements: (1) They It shall be provided for each piece of equipment. (2) They shall Itshall have permanently affixed visual indication of the valve position. (3) They It shall be quarter-turn valves with stops. (4) Wrenches or handles shall remain affixed to valves the valve and shall be oriented with respect to the valve port to indicate the following: (5) An open valve when the handle is parallel to the pipe (6) A closed valve when the handle is perpendicular to the pipe (7) They It shall be readily accessible. (8) Valves A valve with removable wrenches shall not allow the wrench handle to be installed perpendicular to the fuel gas line when the valve is open. (9) They It shall be able to be operated from full open to full close and return without the use of tools Equipment Fuel Gas Train * Materials, Sizing, Piping and Fittings. (A) Fuel gas piping materials Gas confining pipe, tubing, and fittings on a fuel gas train shall be in accordance with NFPA 54, National Fuel Gas Code. (B) Fuel The fuel gas piping train shall be sized to provide flow rates and pressure to maintain a stable flame over the burner operating range. Add Annex A NPFA 54 contains specific requirements for the type of suitable materials for the fuel gas piping system, which are also desirable for NPFA 86 applications. However, there are some conflicts when referencing NFPA 54. (1) The term fuel gas piping system is all piping that is upstream of the equipment isolation valve. NPFA 54 defines piping system as All pipe, tubing, valves, and fittings from the point of delivery to the outlets of the appliance shutoff valve (aka equipment isolation valve). All piping that is downstream of the equipment isolation valve is part of the fuel gas train, which is part of the oven and is not considered fuel gas piping. (1) The NFPA 54 reference is circuitous; NPFA 86 references a standard, whose scope does not cover and should not be applied to a fuel gas train of the oven. Thus, unintentional conflicts can occur. For example, NPFA 54 (2015), 5.6 Acceptable Piping Materials and Joining Methods required that non-ferrous flanged (i.e. aluminum flanged connections) comply with ANSI/ASME B16.24, Cast Copper Alloy Pipe Flanges and Flanged Fittings: Classes 150, 300, , 1500, and 2500 (see NFPA 54, paragraph ). This standard only permits flat face flanges. The intent of referencing NPFA 54 in this paragraph is to have the material requirements and fittings for gas piping systems in NFPA 54 also apply to the fuel gas train piping materials and fittings. This paragraph does should not be applied to the joining methods of the gas train of the oven. For example, it should not be used to require that aluminum bodied valves have flange NFPA 86 Public Inputs with Responses Report Page 39 of 230

40 0 of 222 1/26/2017 2:37 PM connections to ANSI/ASME B Aluminum bodied valves are typically raise face in accordance with ASME B16.5 as permitted in ASME B31.3 Appendix L (see para. L304). Standard needs to better define where the gas piping system is and the gas train is. Sizing of the gas piping system is per NPFA 54. Sizing of the gas train covered by per NPFA 86. Also, A gas piping system is a part of NPFA 54. Fuel gas trains should use materials and fittings that are specified in NFPA 54, but a gas train is not a gas piping system, and there are certain engineering practices are required for a fuel gas train that are not permitted in NFPA 54. The proposal clearly separate when NPFA 54 is applied and where not. There is only a requirement for one equipment isolation valve. Submitter Full Name: Kevin Carlisle Organization: industrial Heating Equipment Association Affilliation: industrial Heating Equipment Association Submittal Date: Fri Jun 10 16:09:53 EDT 2016 Resolution: CI-10-NFPA Statement: The committee would like to resolve any potential conflicts between NFPA 86 and NFPA 54. NFPA 86 Public Inputs with Responses Report Page 40 of 230

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42 2 of 222 1/26/2017 2:37 PM Vents from systems operating at different pressure control levels shall not be manifolded together Vents from systems served from different pressure-reducing stations shall not be manifolded together Vents from systems using different fuel sources shall not be manifolded together Vent lines from multiple regulators and switches of a single furnace, where manifolded together, shall be piped in such a manner that any gas being vented from one ruptured diaphragm does not backload the other devices The cross-sectional area of the manifold line shall not be less than the greater of the following: (1) The cross-sectional area of the largest vent plus 50 percent of the sum of the crosssectional areas of the additional vent lines (2) The sum of the cross-sectional areas of the two largest vent lines * A vent between safety shutoff valves, where installed: (1) Shall not be combined with other vents (2) * Shall terminate to an approved location Suggest that 1) gas appliance (equipment) pressure regulator be standardized 2) it be clear that we are talking about manifold pressure of the burner 3) ratio regulator and zero governors be added to list in , 4) clarify that only those devices having a non-metallic, atmospheric diaphragm be vented (comes for UL 353) 5) expand limitations for backloading on other similar devices. Submitter Full Name: Kevin Carlisle Organization: Karl Dungs Inc Submittal Date: Fri Jun 03 12:04:14 EDT 2016 NFPA 86 Public Inputs with Responses Report Page 42 of 230

43 43 of 222 1/26/2017 2:37 PM Resolution: FR-11-NFPA Statement: Explanatory text is being added to provide examples of various regulators that would fall under the requirements of this section. Allowances for the installation of listed devices that do not require a vent were added. NFPA 86 Public Inputs with Responses Report Page 43 of 230

44 4 of 222 1/26/2017 2:37 PM Public Input No. 59-NFPA [ New Section after ] 6.2.x Safety Shutoff valves : Safety shutoff valves shall be in accordance with section 8. This part of larger proposal to separate the requirements of the gas piping system from the fuel gas train requirements. Submitter Full Name: Kevin Carlisle Organization: Industrial Heating Equipment Association Affilliation: Industrial Heating Equipment Association Submittal Date: Fri Jun 03 15:17:15 EDT 2016 Resolution: This issue is being addressed by the CI-10 Task Group for the Second Draft Meeting. NFPA 86 Public Inputs with Responses Report Page 44 of 230

45 5 of 222 1/26/2017 2:37 PM Public Input No. 64-NFPA [ Section No ] Add definition: Overpressure Protection Device: A pressure limiting or relieving device that prevents the downstream pressure from exceeding a setpoint due to a failure of an upstream pressure regulator(s) under a continuous demand/flow condition Overpressure Protection When Required, Location, OPD devices, and Detection of Activation Overpressure protection shall be provided in either of the following cases: (1) When the supply inlet gas pressure exceeds both 14 kpa (2 psi) and the rated pressure rating of any downstream component (2) When the failure of a single upstream line regulator or service pressure regulator results in a supply an inlet gas pressure exceeding the rated pressure rating of any downstream component, as applicable in Overpressure protection shall be provided by any one of the following: (1) A series regulator in combination with a line regulator or service pressure regulator (2) A monitoring regulator installed in combination with a line regulator or service pressure regulator (3) A full-capacity pressure relief valve and vent line installed according to (4) An overpressure cutoff device, such as a slam-shut valve or a high-pressure switch in combination with an adequately rated shutoff valve * When an overpressure protection device is installed on a fuel gas train, there shall be an active or passive means by which the activation of the overpressure protection device is detectable. A * Example of an active means is an alarm or light notification. Example of a passive device would be a manual reset. NFPA 86 Public Inputs with Responses Report Page 45 of 230

46 6 of 222 1/26/2017 2:37 PM R elief valves and lines * When a relief valve is used to comply with , the relief valve shall be a full-capacity relief type and have an atmospheric vent line sized to fully relieve the required volume of gas such that the pressure to the downstream components is maintained at or below the limits specified in The relieving flow rate of the relief valve and its atmospheric vent line shall be based on nominal inlet pressures to and the Cv factor of the nearest upstream line pressure regulator with an allowance for any pressure drop between the relief valve and the regulator. A Token relief valves and internal token relief valves shall not be permitted to be used as the only overpressure protection devices * Setpoint of the Overpressure Protection Device. The overpressure protection device shall set to provide a maximum downstream pressure as follows: (1) When the rated pressure of any component is less than 83 kpa (12 psi), the set point of the overpressure protection device shall not exceed 150 percent of the rated pressure of the lowest rated component. (2) When the rated pressure of any component is equal to or greater than 83 kpa (12 psi) but less than 414 kpa (60 psi), the set point of the overpressure protection device shall not exceed 41 kpa (6 psi) above the rated pressure of the lowest rated component. (3) When the rated pressure of any component is equal to or greater than 414 kpa (60 psi), the set point of the overpressure protection device shall not exceed 110 percent of the rated pressure of the lowest rated component. A The pressure limits in this section are consistent with 49 CFR Part , Required Capacity of Pressure Relieving and Limiting Stations Proposal attempt so simplify the requirements by using defined terms, limiting the failure of the line pressure regulator, which is in the gas piping system, and by providing relief valve and line requirements. Additional, the current language has not requirement for the max OPD Setpoint. Submitter Full Name: Kevin Carlisle Organization: Industrial Heating Equipment Association Affilliation: Industrial Heating Equipment Association NFPA 86 Public Inputs with Responses Report Page 46 of 230

47 7 of 222 1/26/2017 2:37 PM Submittal Date: Fri Jun 03 15:30:38 EDT 2016 Resolution: CI-12-NFPA Statement: The committee is considering language on the max OPD Setpoint. NFPA 86 Public Inputs with Responses Report Page 47 of 230

48 8 of 222 1/26/2017 2:37 PM Public Input No. 90-NFPA [ Section No ] Overpressure protection shall be provided by any one of the following: (1) A series regulator in combination with a line regulator or service pressure regulator (2) A monitoring regulator installed in combination with a line regulator or service pressure regulator (3) * A full-capacity pressure relief valve (4) An overpressure cutoff device, such as a slam-shut valve or a high-pressure switch in combination with an adequately rated shutoff valve* Add annex * to (3). Renumbered A (3) adds information explaining the differences between full-capacity relief valves and token relief valves. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Thu Jun 09 16:50:49 EDT 2016 Resolution: FR-6-NFPA Statement: This section was misnumbered in a previous edition. NFPA 86 Public Inputs with Responses Report Page 48 of 230

49 9 of 222 1/26/2017 2:37 PM Public Input No. 91-NFPA [ Section No ] * When a relief valve is used to comply with , the relief valve shall be a full-capacity relief type. Deleted paragraph is repeats the same information in paragraph (3). Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Thu Jun 09 16:53:47 EDT 2016 Resolution: FR-42-NFPA Statement: Deleted paragraph is repeats the same information in paragraph (3). NFPA 86 Public Inputs with Responses Report Page 49 of 230

50 0 of 222 1/26/2017 2:37 PM Public Input No. 92-NFPA [ Section No ] Token relief valves and internal token relief valves shall not be permitted to be used as the only overpressure protection devices. Deleted paragraph is not necessary, the requirement in paragraph (3) already prohibits the use of token pressure relief valves. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Thu Jun 09 16:55:18 EDT 2016 Resolution: FR-43-NFPA Statement: Deleted paragraph is not necessary, the requirement in paragraph (3) already prohibits the use of token pressure relief valves. NFPA 86 Public Inputs with Responses Report Page 50 of 230

51 1 of 222 1/26/2017 2:37 PM Public Input No. 54-NFPA [ Section No ] Proportional Mixing. (A) Piping shall be designed to provide a uniform mixture flow of pressure and velocity needed for stable burner operation. (B) Valves or other obstructions shall not be installed between a proportional mixer and burners, unless otherwise permitted by (C). (C) Fixed orifices shall be permitted for purposes of balancing. (D) Any field-adjustable device built into a proportional mixer (e.g., gas orifice, air orifice, ratio valve) shall incorporate a device to prevent unintentional changes in the setting. (E) Where a mixing blower is used, safety shutoff valves shall be installed in the fuel gas supply and shall interrupt the fuel gas supply automatically when the mixing blower is not in operation or in the event of a fuel gas supply failure. (F) Mixing blowers shall not be used with fuel gases containing more than 10 percent free hydrogen (H2). (G) Mixing blowers having a static delivery discharge pressure of more than 10 in. w.c. (2.49 kpa) shall be considered mixing machines. Discharge is better term to use in this case Submitter Full Name: Kevin Carlisle Organization: Karl Dungs Inc Submittal Date: Fri Jun 03 15:03:50 EDT 2016 NFPA 86 Public Inputs with Responses Report Page 51 of 230

52 2 of 222 1/26/2017 2:37 PM Resolution: FR-13-NFPA Statement: The term discharge is a more accurate term than delivery. NFPA 86 Public Inputs with Responses Report Page 52 of 230

53 3 of 222 1/26/2017 2:37 PM Public Input No. 82-NFPA [ Section No (B) ] (B) Valves or other obstructions shall not be installed between a an air jet mixer, gas jet mixer, proportional mixer or a mixing blower and burners, unless otherwise permitted by (C). Clarifies specific defined mixer types; these were not previously used except in Chap 3. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Thu Jun 09 16:30:13 EDT 2016 Resolution: FR-46-NFPA Statement: Clarifies specific defined mixer types; these were not previously used except in Chap 3. NFPA 86 Public Inputs with Responses Report Page 53 of 230

54 4 of 222 1/26/2017 2:37 PM Public Input No. 83-NFPA [ Section No (A) ] (A)* Automatic fire checks shall be provided in piping systems that distribute flammable air fuel gas mixtures from a mixing machine at a pressure greater than 10 in. w.c. (2.49 kpa). Adds back the requirement only for pressure >10"wc with proposal to remove it from the definition. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Thu Jun 09 16:32:38 EDT 2016 Resolution: FR-45-NFPA Statement: Adds back the requirement only for pressure >10"wc with proposal to remove it from the definition. NFPA 86 Public Inputs with Responses Report Page 54 of 230

55 5 of 222 1/26/2017 2:37 PM Public Input No. 84-NFPA [ Section No (E) ] (E)* A backfire arrester with a A safety blowout device shall be installed in accordance with the manufacturer's instructions near the outlet of each mixing machine that produces a flammable air fuel gas mixture at a pressure greater than 10 in. w.c. (2.49 kpa). Proposed safety blowout definition eliminates the need for the deleted text. Adds back the requirement only for pressure >10"wc with the proposal to remove it from definition. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Thu Jun 09 16:34:47 EDT 2016 Resolution: FR-70-NFPA Statement: Adds back the requirement only for pressure >10"wc in combination with the removal of it from definition. The safety blowout definition and annex eliminates the need for this annex. NFPA 86 Public Inputs with Responses Report Page 55 of 230

56 6 of 222 1/26/2017 2:37 PM Public Input No. 85-NFPA [ Section No (F) ] (F) Where a mixing machine is used, safety shutoff valves shall be installed in the fuel gas supply and shall interrupt the fuel gas supply automatically when the mixing machine is not in operation or in the event of an air or fuel gas supply failure. (F) is redundant to Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Thu Jun 09 16:37:35 EDT 2016 Resolution: FR-49-NFPA Statement: (F) is redundant to NFPA 86 Public Inputs with Responses Report Page 56 of 230

57 57 of 222 1/26/2017 2:37 PM Public Input No. 171-NFPA [ Sections , ] Sections , Radiant tube heating systems using metallic tubes open at one or both ends shall not require explosion resistance validation. ELIMINATE THIS SECTION * A manufacturer's claim of explosion-resistant radiant tube heating systems using nonmetallic tubes or metallic tubes sealed in at both ends shall be validated. ELIMINATE THIS SECTION The current NFPA Standard for Ovens and Furnaces implies that metallic radiant tubes are safer than other high temperature materials of construction such as ceramics and composites. Alternative non-metallic materials currently in industrial radiant tube service include mullites, sialons, silicon nitrides, siliconized silicon carbides and silicon / silicon carbide composites. The standard excludes and/or favorably treats metallic radiant tubes in terms of relaxed requirements for: Pre-ignition Purging Sections , A , & Safety Shut-Off Valves Section Flame Supervision Section This special treatment for metallic radiant tubes ignores several decades of industry experience where deflagration / explosion has not proved to be a significant risk factor for non-metallic materials, or at minimum the incident losses are no different than metallic tubes used in equivalent service. In actual operation most metallic radiant tubes used in carburizing, carbonitriding and higher temperature processing periodically experience open-crack, thru-wall hole and/or perforation failures due to material creep distortion, carburization corrosion/embrittlement and/or weld stress fracture. Any risks posed by open metallic tube failures are no different than those of non-metallic tubes, regardless of whether combustible gases flow into the furnace chamber or, vice versa, into the radiant tube. For the processes cited above metallic failures generally occur every three to five years (sometimes sooner) mandating radiant tube replacement to maintain the integrity of the process atmosphere and quality of production. While ceramic and composite tubes available to the industrial furnace users do not experience the progressive failure modes of metallic tubes, they are more susceptible to mechanical impact and less tolerable of thermo-mechanical stress. Failure of non-metallic radiant tubes has the same effect on the furnace atmosphere and production quality, also mandating their replacement. When radiant metallic tube applications are optimally designed (so that the surface temperatures are uniform and not excessive for the specific alloy employed), they are just as likely, if not more likely, to fail catastrophically compared with ceramic and composite tubes under the same service conditions in carburizing, carbonitriding and higher temperature atmospheres. NFPA 86 Public Inputs with Responses Report Page 57 of 230

58 8 of 222 1/26/2017 2:37 PM Furthermore, consideration of radiant tube durability should not be based on new material properties, but rather on radiant tubes that are at or near the end of their useful service lives. It is at this point that a tube failure-related incident is most likely to occur. To be logically consistent both metallic and non-metallic radiant tubes used at elevated temperatures (e.g. above 1550 F) must be treated the same. For example, if flame supervision is required for non-metallic radiant tubes, then it should be required for metallic radiant tubes as well. An alternative approach might be to require that metallic tubes are removed from use before they are projected to fail (based on a documented analysis of service life in the specific application). In practice it is rare that adequate information is available to base such projections with certainty, therefore we do not envision that this risk avoidance tactic can be reliably adopted by industry. On the other hand, if metallic radiant tubes are proven to operate in service with little or no deterioration at lower temperatures (e.g. below 1550 F), a specific reliability analysis might support the conclusion that catastrophic failure is improbable in that application. The testing prescribed in Section A to validate the explosion-resistance of non-metallic materials ignores the failure modes of metallic tubes in carburizing, carbonitriding and higher temperature processing. Normative service failures (open-cracks, thru-wall holes and/or perforations) result in metallic radiant tubes incapable of supporting any pressurization whatsoever. Furthermore, the exclusion of metallic materials from these validity protocols per Section ignores the design pressure ratings of radiant tubes (as a function of wall thickness, alloy strength and weld integrity). Also longer-term metallic tube wall deterioration due to spalling and embrittlement (which inevitably occurs in high temperature service) is not considered. Related Public Inputs for This Document Related Input Public Input No. 169-NFPA [Section No ] Public Input No. 170-NFPA [Sections , ] Public Input No. 172-NFPA [Section No ] Public Input No. 173-NFPA [Section No ] Public Input No. 174-NFPA [Section No. A ] Public Input No. 175-NFPA [Section No. A ] Public Input No. 176-NFPA [Section No. A ] Relationship Submitter Full Name: Curt Colopy Organization: INEX Incorporated Submittal Date: Wed Jun 29 16:06:39 EDT 2016 Resolution: FR-19-NFPA NFPA 86 Public Inputs with Responses Report Page 58 of 230

59 9 of 222 1/26/2017 2:37 PM Statement: These requirements should be based on performance and not specifically on the type of material utilized. NFPA 86 Public Inputs with Responses Report Page 59 of 230

60 0 of 222 1/26/2017 2:37 PM Public Input No. 30-NFPA [ New Section after ] (new) Handheld igniters shall not use high voltage to generate electric sparks. Accompanying Annex material: A Fixed igniters that utilize high voltage to generate electric sparks have been proven safe in vast numbers of systems. However, handheld sparking igniters utilizing high voltage transformers (especially homemade igniters not constructed with suitable electrical insulation and safety guards) pose a severe electrocution hazard and should not be used to light gas-fired burners in ovens or furnaces. Sparking igniters that rely on piezoelectric energy to generate a spark are not intended to be precluded by this prescriptive requirement. Fixed igniters that utilize high voltage to generate electric sparks have been proven safe in vast numbers of systems. However, handheld sparking igniters utilizing high voltage transformers (especially homemade igniters not constructed with suitable electrical insulation and safety guards) pose a severe electrocution hazard and should not be used to light gas-fired burners in ovens or furnaces. Sparking igniters that rely on piezoelectric energy to generate a spark are not intended to be precluded by this prescriptive requirement. Submitter Full Name: Richard Martin Organization: Martin Thermal Engineering Inc Submittal Date: Mon May 16 14:17:52 EDT 2016 Resolution: FR-9-NFPA Statement: Fixed igniters that utilize high voltage to generate electric sparks have been proven safe in vast numbers of systems. However, handheld sparking igniters utilizing high voltage transformers (especially homemade igniters not constructed with suitable electrical insulation and safety guards) pose a severe electrocution hazard and should not be used to light gas-fired burners in ovens or furnaces. Sparking igniters that rely on piezoelectric energy to generate a spark are not intended to be precluded by this prescriptive requirement. NFPA 86 Public Inputs with Responses Report Page 60 of 230

61 1 of 222 1/26/2017 2:37 PM Public Input No. 106-NFPA [ Section No ] Pilot burners shall be considered burners, and all provisions of Section 6.2 shall apply. Add Annex Nothing in this standard prohibits having the pilot and main burner use the same equipment regulator. Having one regulator control the pressure to the pilot fuel gas train and main burner fuel gas train is not a safety issue. having the annex clarify this would be helpful since the drawing shows the pilot take off upstream of the main gas pressure regulator. Submitter Full Name: Kevin Carlisle Organization: Karl Dungs Inc Submittal Date: Fri Jun 10 14:36:35 EDT 2016 Resolution: It is not within the scope of the standard to always define what is not prohibited by the standard. NFPA 86 Public Inputs with Responses Report Page 61 of 230

62 2 of 222 1/26/2017 2:37 PM Public Input No. 140-NFPA [ New Section after ] * Where an impulse pipe is used to connect a safety device the impulse pipe shall be inspected for leaks or blockages at least annually. Changes the suggestion to inspect the impulse line found in current annex material to a requirement to test the functionality of the impulse line. The proposed change also establishes a time frequency that is consistent with the current frequency required for the safety device it is connected to. Related Public Inputs for This Document Related Input Public Input No. 141-NFPA [New Section after A.7.3.8] Public Input No. 142-NFPA [New Section after ] Relationship Submitter Full Name: Geoffrey Raifsnider Organization: Global Finishing Solutions Submittal Date: Tue Jun 28 08:13:06 EDT 2016 Resolution: FR-47-NFPA Statement: Changes the suggestion to inspect the impulse line found in current annex material to a requirement to test the functionality of the impulse line. The change also establishes a time frequency that is consistent with the current frequency required for the safety device it is connected to. Annex material for new to list the inspections that should be performed. NFPA 86 Public Inputs with Responses Report Page 62 of 230

63 3 of 222 1/26/2017 2:37 PM Public Input No. 166-NFPA [ New Section after ] TITLE OF NEW CONTENT * Where an impulse pipe is used to connect a safety device the impulse pipe shall be inspected for leaks or blockages at least annually. Changes the suggestion to inspect the impulse line to a requirement to test the functionality of the impulse line and establishes a time frequency that is consistent with the current frequency required for the safety device it is connected to. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Tue Jun 28 15:07:57 EDT 2016 Resolution: FR-47-NFPA Statement: Changes the suggestion to inspect the impulse line found in current annex material to a requirement to test the functionality of the impulse line. The change also establishes a time frequency that is consistent with the current frequency required for the safety device it is connected to. Annex material for new to list the inspections that should be performed. NFPA 86 Public Inputs with Responses Report Page 63 of 230

64 4 of 222 1/26/2017 2:37 PM Public Input No. 36-NFPA [ New Section after ] * The setpoint of pressure relief valve, where installed, shall be verified at least annually. Add annex A It s not practical to test in the field the full relieving capacity of a relief valve in combination of its vent line. Recommended checks in the field could include (1) Verify it's in good mechanical condition; (2) Verify the sizing for the service in which it is employed; (3) Verify it has been p roperly installed and protected from dirt, liquids, or other conditions that might prevent proper operation; (4) That the point of termination of the vent line is goose-necked and is not clogged (check screen). Recommend NPFA 86 have some guidance on how relief valves can be inspected in the field since there provide a layer of safety to the gas train. Submitter Full Name: Kevin Carlisle Organization: Industrial Heating Equipment Association Affilliation: Industrial Heating Equipment Association Submittal Date: Fri Jun 03 11:39:07 EDT 2016 Resolution: FR-17-NFPA Statement: NFPA 86 needed guidance on how relief valves can be inspected in the field since they provide a layer of safety to the gas train. NFPA 86 Public Inputs with Responses Report Page 64 of 230

65 5 of 222 1/26/2017 2:37 PM Public Input No. 70-NFPA [ Section No ] 7.4.9* Valve seat leakage testing of safety shutoff valves, vent valves, and valve proving systems shall be performed in accordance with the manufacturer's instructions Testing frequency shall be at least annually The installation of a valve proving system or a valve with proof of closure shall not replace the requirement for seat leakage testing in vent valves need to be tested, too. Submitter Full Name: Kevin Carlisle Organization: Industrial Heating Equipment Association Affilliation: Industrial Heating Equipment Association Submittal Date: Thu Jun 09 09:42:56 EDT 2016 Resolution: Vent valves should not be addressed within the mandatory section of NFPA 86. NFPA 86 Public Inputs with Responses Report Page 65 of 230

66 6 of 222 1/26/2017 2:37 PM Public Input No. 22-NFPA [ Section No ] Replacement of Safety Shutoff Valve Replacement for open-close cycling applications Safety shutoff valves that are used to comply with (4) 6 and are not proved closed shall be replaced before they exceed their maximum allowable number of lifetime open closed cycles * The number of safety shutoff valve cycles shall be determined by one of the following ways: (1) Counting of actual safety shutoff valve open-closed close cycles (2) Estimated time to reach 90 percent of lifetime total cycles based on normal cycling rates The requirements in were not clear in terms of referring to (4). See related PI for Related Public Inputs for This Document Related Input Public Input No. 20-NFPA [Section No ] Relationship Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Sun May 01 18:38:23 EDT 2016 Resolution: FR-25-NFPA Statement: Title was changed to distinguish replacement of the safety shutoff valve applicability to only open-close cycling applications. The requirements in were not clear in terms of referring to (4). See related NFPA 86 Public Inputs with Responses Report Page 66 of 230

67 7 of 222 1/26/2017 2:37 PM Public Input No. 88-NFPA [ Section No ] Safety Shutoff Valve Replacement Safety shutoff valves that are used to comply with (4) and are not proved closed shall be replaced before they exceed their maximum allowable number of lifetime open closed cycles * The number of safety shutoff valve cycles shall be determined by one of the following ways: (1) Counting of actual safety shutoff valve open-closed cycles (2) Estimated time to reach 90 percent of lifetime total cycles based on normal cycling rates * When seat leakage of a safety shutoff valve or isolation is excessive, it shall be replaced. To provide guidance on what action needs to be done if the valve leaks too much Submitter Full Name: Kevin Carlisle Organization: Karl Dungs Inc Submittal Date: Thu Jun 09 16:46:51 EDT 2016 Resolution: The term "excessive" in the text is unenforceable. NFPA 86 Public Inputs with Responses Report Page 67 of 230

68 8 of 222 1/26/2017 2:37 PM Public Input No. 107-NFPA [ Section No ] Safety shutoff valves that are used to comply with (4) 6 and are not proved closed shall be replaced before they exceed their maximum allowable number of lifetime open closed cycles. This PI is related to that for Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Fri Jun 10 15:07:45 EDT 2016 Resolution: FR-25-NFPA Statement: Title was changed to distinguish replacement of the safety shutoff valve applicability to only open-close cycling applications. The requirements in were not clear in terms of referring to (4). See related NFPA 86 Public Inputs with Responses Report Page 68 of 230

69 9 of 222 1/26/2017 2:37 PM Public Input No. 164-NFPA [ Section No ] Safety shutoff valves that are used to comply with (4) and are not proved closed shall be replaced before they exceed their maximum allowable number of lifetime open closed cycles.when acceptable to the manufacturer, when a VPS completes a valve proving sequence on two SSOV s in series over a period of two burner on-off cycles, such safety shutoff valves shall be replaced when the VPS detects a valve fault. Due do the fast cycling demand on a high cycle application, the VPS sequence can be performed on one of the SSOV s before the next burner start. The burner is then permitted to cycle on, then off. And then thereafter the VPS performs a VPS sequence on the other SSOV. The level of functional testing due to the VPS in combination with 2 SSOV s in series provides enough safety to permit valves to remain in service until an actual fault is detected. Submitter Full Name: Kevin Carlisle Organization: Karl Dungs Inc Submittal Date: Tue Jun 28 15:02:50 EDT 2016 Resolution: FR-25-NFPA Statement: Title was changed to distinguish replacement of the safety shutoff valve applicability to only open-close cycling applications. The requirements in were not clear in terms of referring to (4). See related NFPA 86 Public Inputs with Responses Report Page 69 of 230

70 0 of 222 1/26/2017 2:37 PM Public Input No. 43-NFPA [ Section No ] Safety devices shall be installed, used, and maintained in accordance with the manufacturer's instructions is redundant as these requirements are already in and Submitter Full Name: Kevin Carlisle Organization: Karl Dungs Inc Submittal Date: Fri Jun 03 14:16:32 EDT 2016 Resolution: FR-73-NFPA Statement: is redundant as these requirements are already in and NFPA 86 Public Inputs with Responses Report Page 70 of 230

71 1 of 222 1/26/2017 2:37 PM Public Input No. 101-NFPA [ New Section after ] TITLE OF NEW CONTENT * If the mushroom-type emergency fuel stop is wired to the inputs of a safety PLC per 8.4 then the emergency fuel stop shall use redundant contacts to redundant safety inputs per the manufacturer s safety manual for implementing an emergency stop to SIL 3/PL e * Ancillary furnace functions not related to fuel e.g., pumps, blowers, atmospheric gas controller, hydraulics, motion, quench tank controls shall be evaluated using the appropriate standards for their inherent hazard and the appropriate action shall be taken to mitigate that hazard when the emergency fuel stop is activated. Complementary to PI for Some furnaces include complex control of motion, hydraulics, and special atmospheres that can t be immediately depowered without creating additional hazards when the fuel stop button is depressed. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Fri Jun 10 13:42:24 EDT 2016 Resolution: FR-52-NFPA Statement: Some furnaces include complex control of motion, hydraulics, and special atmospheres that can t be immediately depowered without creating additional hazards when the fuel stop button is depressed. NFPA 86 Public Inputs with Responses Report Page 71 of 230

72 72 of 222 1/26/2017 2:37 PM Public Input No. 100-NFPA [ Section No ] 8.2.9* At least one manual emergency switch shall be provided to initiate a safety shutdown fuel stop. Some furnaces include complex control of motion, hydraulics, and special atmospheres that can t be immediately depowered without creating additional hazards when the fuel stop button is depressed. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Fri Jun 10 13:40:22 EDT 2016 Resolution: The definition of Safety Shutdown already covers this action. NFPA 86 Public Inputs with Responses Report Page 72 of 230

73 3 of 222 1/26/2017 2:37 PM Public Input No. 99-NFPA [ New Section after ] TITLE OF NEW CONTENT 8.3.2* Each safety interlock shall be wired so that a single fault occurring outside of the control enclosure (short, open wire condition, etc.) cannot interfere with or disable more than one safety interlock. Safety circuit wiring should minimize the risk of fault accumulation or common mode failures. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Fri Jun 10 13:37:01 EDT 2016 Resolution: Proposal for current hardwired systems does not add to the safety of the system. NFPA 86 Public Inputs with Responses Report Page 73 of 230

74 4 of 222 1/26/2017 2:37 PM Public Input No. 61-NFPA [ Section No ] 8.4.2* Where PLCs are used for combustion safety service (e.g used as a combustion safeguard) and are not listed for combustion safety service or as combustion safeguard, the PLC and its associated input and output (I/O) used to perform safety functions shall be as follows: (1) Third-party certified to IEC 61508, Functional Safety of Electrical/Electronic /Programmable Electronic Safety-Related Systems, safety integrity level (SIL) 2 or greater (2) Applied to achieve at least an SIL 2 capability per the manufacturer's safety manual 8.4. x Where PLCs are used for safety functions to handle the atmosphere within the oven (e.g. safety ventilation, purge-in/purge-out, etc), the PLC and its associated input and output (I/O) used to perform safety functions shall be as follows: (1) Comply with IEC 61508, Functional Safety of Electrical/Electronic/Programmable Electronic Safety-Related Systems, safety integrity level (SIL) 1 or greater, and ( 2 ) Applied to achieve at least an SIL 1 capability per the manufacturer s safety manual (3) The configuration of the program logic uploaded by the designer is according to IEC for SIL 1 or greater Software. (A) Access to the PLC and its logic shall be restricted to authorized personnel. (B) Software shall be documented as follows: (1) Labeled to identify elements or a group of elements containing safety software (2) Labeled to describe the function of each element containing safety software (C) A listing of the program with documentation shall be available. It s not clear when applies to PLC s (e.g. see (3) ), which are used for safety functions that have nothing to do with the combustion process. E.g. purge in and purge out. The whole section of 8.4 speaks to the combustion process. Submitter Full Name: Kevin Carlisle Organization: Industrial Heating Equipment Association Affilliation: Industrial Heating Equipment Association NFPA 86 Public Inputs with Responses Report Page 74 of 230

75 5 of 222 1/26/2017 2:37 PM Submittal Date: Fri Jun 03 15:19:28 EDT 2016 Resolution: This is addressed in FR-76. NFPA 86 Public Inputs with Responses Report Page 75 of 230

76 6 of 222 1/26/2017 2:37 PM Public Input No. 168-NFPA [ Section No [Excluding any Sub-Sections] ] Where PLCs are not listed for combustion safety service or as combustion safeguard, the PLC and its associated input and output (I/O) used to perform safety functions shall be as follows: (1) Third-party certified to IEC 61508, Functional Safety of Electrical/Electronic/Programmable Electronic Safety-Related Systems, safety integrity level (SIL) 2 or greater (2) Applied to achieve at least an SIL 2 capability per the manufacturer's safety manual. (3) The program logic is third-party certified according to IEC and for SIL 2 or greater. A ny trip of an interlock (e.g. flame detector, air or gas switch, valve switch, e xcess temperature limit interlock, 1400 F (760 C) bypass interlock, etc) shall lead to safety shutdown of the burner. Add the following Annex The PLC should provide the following operations, in proper sequence, the start-up and shut-down of the burner using at least the following timings, responses, and features: a) Pilot or main burner flame establishing period or both. b) Safety shutdown within the flame-failure response time in the event of flame failure. c) Lockout feature such that a restart can be accomplished only by a manual reset at the control. Considerations in regards to the potential drift of safety related timings should be made when the PLC is subject to 85% of rated voltage for AC or 80% of rated voltage for DC voltage in combination with the lowest and highest rated ambient temperature. ANSI Z _CAN_CSA-C22.2 No , the standard to which flame safeguard are listed, has specific requirements for timings, sequencing, and actions upon first and second faults. There are details regarding required actions upon first and second faults for systems with and without self-checking feature. These actions are also defined in IEC See H for systems without self-checking and H for systems with self-checking feature. These actions upon first and second faults should be mimicked in the PLC. The level of safety of a PLC when used as an alternative to a listed and labeled flame safeguard should be equivalent, and this also includes the software. Submitter Full Name: Kevin Carlisle Organization: Karl Dungs Inc NFPA 86 Public Inputs with Responses Report Page 76 of 230

77 7 of 222 1/26/2017 2:37 PM Submittal Date: Tue Jun 28 15:34:56 EDT 2016 Resolution: Statement: The committee is looking at whether there is a gap between software and hardware requirements. NFPA 86 Public Inputs with Responses Report Page 77 of 230

78 8 of 222 1/26/2017 2:37 PM Public Input No. 38-NFPA [ Section No [Excluding any Sub-Sections] ] Where PLCs are not listed for combustion safety service or as combustion safeguard, the PLC and its associated input and output (I/O) used to perform safety functions shall be as follows: (1) Third-party certified to IEC 61508, Functional Safety of Electrical/Electronic/Programmable Electronic Safety-Related Systems, safety integrity level (SIL) 2 3 or greater (2) Applied to achieve at least an SIL 2 3 capability per the manufacturer's safety manual (3) The configuration of the program logic uploaded by the designer is according to IEC for SIL 3 or greater In the 2015 edition SIL 2 was selected as the minimum level because it was not know at that time what the SIL level was for existing flame safeguards. Since then, flame safeguard manufactures have determined that the level of safety in listed flame safeguards is SIL 3. Thus, the 2018 edition should bring the SIL level to the equivalent level that listed flame safeguards have. Here are some differences between SIL2 vs SIL 3 requirements. SIL 3 has two microprocessor. SIL 2 has 1 processor. SIL 3, developer needs continued education, SIL 2, only recommended. In SIL 3, every line of the software code needs some kind of review. E.g. 2 people, or 1 writing and other reviewing. Also, you can do branch checking, which is in SIL 2, too, but with SIL 3, all possible values need to be considered, not just a few random ones or some % of all possible numbers. If possible values are 1-100, SIL 3 has to check all values. SIL 2 needs only to check for example, 1, 5, 8, 99 and, 86. SIL 3 has 1oo2 and 2oo3. SIL 2 only has one processer, so there is no option for this. For SIL, the application matters. For example SIL 3 needed for a school to protect life, SIL 2 needed to protect the building, SIL 1 needed if explosion occurs, and relief door opens, and no one is ever by relief door. But NPFA 86 does not differentiate the application. Submitter Full Name: Kevin Carlisle Organization: Industrial Heating Equipment Association Affilliation: Industrial Heating Equipment Association Submittal Date: Fri Jun 03 12:18:39 EDT 2016 Resolution: This issue is addressed in FR-76. NFPA 86 Public Inputs with Responses Report Page 78 of 230

79 9 of 222 1/26/2017 2:37 PM Public Input No. 62-NFPA [ Section No (B) ] (B) Safety PLCs shall notimplement replace the function of the following devices : (1) Manual emergency switches (2) Continuous vapor concentration high-limit controllers What is meaning of implement? Does it mean that the PLC cannot implement the logic or cannot it not implement the switch. Can I integrate into the PLC the push button E-Stop. Can PLC do the logic? The 2010 edition said PLC cannot implement logic and devices. Proposal attempt to make this more clear Submitter Full Name: Kevin Carlisle Organization: Industrial Heating Equipment Association Affilliation: Industrial Heating Equipment Association Submittal Date: Fri Jun 03 15:21:26 EDT 2016 Resolution: FR-77-NFPA Statement: Clarifying the language that prohibits the use of a PLC to replace the manual emergency switch and Continuous vapor concentration high-limit controllers. NFPA 86 Public Inputs with Responses Report Page 79 of 230

80 0 of 222 1/26/2017 2:37 PM Public Input No. 138-NFPA [ Section No ] Pre-ignition (Prepurge, Purging Cycle) * Prior to each furnace heating system startup, provision shall be made for the removal of all flammable vapors and gases that have entered the heating chambers during the shutdown period * A timed pre-ignition purge shall be provided. (A) At least foursystem volumes of fresh air or inert gas shall be introduced during the purging cycle. (B) The system volume shall include the heating chambers and all other passages that handle the recirculation and exhaust of products of combustion. (C) To begin the timed pre-ignition purge interval, all of the following conditions shall be satisfied: (1) * The minimum required pre-ignition airflow is proved. (2) (3) At least one safety shutoff valve is proved closed between all main burners and the fuel supply for ovens with total capacity over 400,000 Btu/hr (D) * At least one safety shutoff valve is proved closed between all pilot burners and the fuel supply for ovens with total pilot capacity over 400,000 Btu/hr. The minimum required pre-ignition airflow shall be proved and maintained throughout the timed pre-ignition purge interval. NFPA 86 Public Inputs with Responses Report Page 80 of 230

81 1 of 222 1/26/2017 2:37 PM (E) Failure to maintain the minimum required pre-ignition purge airflow shall stop the pre-ignition purge and reset the purge timer Pre-ignition purge shall be completed in 60 minutes or less unless otherwise permitted in Pre-ignition purge shall be permitted to exceed 60 minutes where it is demonstrated flammable vapor and gas concentrations within the volume described in (B) will not exceed 25% of LFL Once pre-ignition purge is complete and the preignition airflow rate is no longer proven, burners shall be ignited and proven in 30 minutes or less unless otherwise permitted in Once pre-ignition purge is complete and the preignition airflow rate is no longer proven, it shall be permitted for burners to be ignited and proven in more than 30 minutes where it is demonstrated flammable vapor and gas concentrations within the volume described in (B) will not exceed 25% of LFL [renumber ] A furnace heating system, either alone or as part of multiple furnaces feeding into one fume incinerator, shall not be purged into an operating incinerator unless otherwise permitted by [renumber ] A furnace heating system shall be permitted to be purged into an operating incinerator if it can be demonstrated that the flammable vapor concentration entering the fume incinerator cannot exceed 50 percent of the LFL [renumber ] Pre-ignition purging of radiant tube type heating systems shall be provided, unless otherwise permitted by [renumber ] Pre-ignition purging of radiant tube type heating systems shall not be required where the systems are arranged and designed such that either of the following conditions is satisfied: (1) The tubes are of metal construction and open at one or both ends. If heat recovery systems are used, they shall be of explosion-resistant construction. (2) The entire radiant tube heating system, including any associated heat recovery system, is of explosion-resistant construction [renumber ] Prior to the re-ignition of a burner after a burner shutdown or flame failure, a pre-ignition purge shall be accomplished. CAUTION: Repeated ignition attempts can result in a combustible concentration greater than 25 percent of the LFL. Liquid fuels can accumulate, causing additional fire hazards. NFPA 86 Public Inputs with Responses Report Page 81 of 230

82 2 of 222 1/26/2017 2:37 PM * [renumber *] Repeating the pre-ignition purge shall not be required where any one of the following conditions is satisfied: (1) The heating chamber temperature is proved to be above 1400 F (760 C). (2) For a multiburner fuel-fired system not proved to be above 1400 F (760 C), all of the following conditions are satisfied: (3) * At least one burner remains operating in the common combustion chamber of the burner to be re-ignited. (4) The burner(s) remaining in operation shall provide ignition without explosion of any unintended release of fuel through other burners that are not in operation. (5) * For fuel gas fired burner systems and assuming that all safety shutoff valves fail in the full open position, it can be demonstrated that the combustible concentration in the heating chamber and all other passages that handle the recirculation and exhaust of products of combustion cannot exceed 25 percent of the LFL. (6) All of the following conditions are satisfied (does not apply to fuel oil systems): (7) The number of safety shutoff valves required to close in and will close between the burner system and the fuel gas supply when that burner system is off. (8) Safety shutoff valve seat leak testing is performed on at least a semiannual basis. (9) The burner system uses natural gas, butane, or propane fuel gas. (10) * It can be demonstrated based on the leakage rate, that the combustible concentration in the heating chamber and all other passages that handle the recirculation and exhaust of products of combustion cannot exceed 25 percent of the LFL. (11) The minimum airflow used in the LFL calculation in (4)(d) is proved and maintained during the period the burner(s) are off. To establish requirements for duration of the pre-ignition purge interval and requirements for the time between completion of the pre-ignition purge interval and the ignition of burners. Submitter Full Name: Richard Gallagher Organization: Zurich Services Corporation Submittal Date: Fri Jun 24 10:47:38 EDT 2016 NFPA 86 Public Inputs with Responses Report Page 82 of 230

83 3 of 222 1/26/2017 2:37 PM Resolution: FR-78-NFPA Statement: To introduce requirements to the standard that limits the time frame between completing purge and lighting burners. NFPA 86 Public Inputs with Responses Report Page 83 of 230

84 4 of 222 1/26/2017 2:37 PM Public Input No. 34-NFPA [ New Section after ] < no title required > Add New Paragraph after : * For gas-fired heating systems equipped with Flue Gas Recirculation (FGR) for pollution control, an analysis shall be performed to evaluate the necessity for additional purge duration (beyond that computed in A) to ensure that a fail-open condition of the FGR damper does not lead to an accumulation of fuel gas in the explosive range inside the combustion chamber Incorporation of Proof-of-Closure on the FGR damper and into the purge safety logic shall be permitted in lieu of the requirement in Add New Annex material for new : A When a burner is equipped with FGR, the safety control logic normally attempts to drive the FGR damper closed before initiation of the pre-purge timer. However, FGR dampers are rarely equipped with Proof-of-Closure switches, and the possibility exists that the FGR damper could fail to close when instructed to do so. Such a situation would allow the re-introduction of unburned fuel (left over from a prior ignition trial) back into the combustion chamber. This consequence of this situation is that the purge gas (which is nominally understood to be fresh air) that is introduced prior to a second or third igntion attempt, is in fact an indeterminate gas mixture that may be in the explosive range. The requirement at is intended to ensure that this hazard is addressed when the purge timing is established by the manufacturer, installer/commissioner, or user. The analysis may be conducted experimentally, with a tracer gas (preferably non-flammable) being introduced to simulate fuel gas and a gas analyzer to determine the purge duration that will effectively dilute the purge mixture to 25% of LFL or lower. The analysis may also be performed via a Computational Fluid Dynamics (CFD) model. If neither is possible, the analysis should be performed using a "Perfectly Stirred Reactor" conceptual model for the combustion chamber, which is more conservative than a "Plug Flow Model". Failure of an FGR damper to close prior to the commencement of the pre-ignition purge cycle could introduce an indeterminate gas (quite possibly a flammable mixture of fuel gas and air) into the combustion chamber instead of fresh air. Any system that is equipped with FGR for pollution control should be analyzed to account for the possibility of the FGR damper's failure to close and to account for that possibility through extending the purge time to ensure that the worst case scenario will not create an explosive mixture in the combustion chamber on a subject ignition trial. Extending the purge time should not be required if the FGR damper can be proved closed and interlocked with the commencement of the purge cycle. Submitter Full Name: Richard Martin Organization: Martin Thermal Engineering Inc NFPA 86 Public Inputs with Responses Report Page 84 of 230

85 5 of 222 1/26/2017 2:37 PM Submittal Date: Thu Jun 02 10:53:40 EDT 2016 Resolution: Statement: Failure of an FGR damper to close prior to the commencement of the pre-ignition purge cycle could introduce an indeterminate gas (quite possibly a flammable mixture of fuel gas and air) into the combustion chamber instead of fresh air. Any system that is equipped with FGR for pollution control should be analyzed to account for the possibility of the FGR damper's failure to close and to account for that possibility through extending the purge time to ensure that the worst case scenario will not create an explosive mixture in the combustion chamber on a subject ignition trial. NFPA 86 Public Inputs with Responses Report Page 85 of 230

86 6 of 222 1/26/2017 2:37 PM Public Input No. 153-NFPA [ New Section after (E) ] TITLE OF NEW CONTENT * (F) Air pressure switches shall not be used to prove airflow where valves downstream of the pressure switch can be closed to the point of reducing airflow below the minimum required. PI provides another method of implementing an air flow interlock which is based on the burner system's defined pressure drop versus air flow. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Tue Jun 28 14:28:34 EDT 2016 Resolution: FR-55-NFPA Statement: Provides another method of implementing an air flow interlock which is based on the burner system's defined pressure drop versus air flow. Annex Item: In some applications, the airflow is so low that it is impractical to prove at each individual burner. However, if the airflow is proven at the main header and then flows through a fixed orifice, this meets the intent of NFPA 86. NFPA 86 Public Inputs with Responses Report Page 86 of 230

87 7 of 222 1/26/2017 2:37 PM Public Input No. 170-NFPA [ Sections , ] Sections , Pre-ignition purging of radiant tube type heating systems shall be provided, unless otherwise permitted by ELIMINATE THIS SECTION Pre-ignition purging of radiant tube type heating systems shall not be required where the systems are arranged and designed such that either of the following conditions is satisfied: The tubes are of metal construction and open at one or both ends. If heat recovery systems are used, they shall be of explosion-resistant construction. The entire radiant tube heating system, including any associated heat recovery system, is of explosion-resistant construction. The current NFPA Standard for Ovens and Furnaces implies that metallic radiant tubes are safer than other high temperature materials of construction such as ceramics and composites. Alternative non-metallic materials currently in industrial radiant tube service include mullites, sialons, silicon nitrides, siliconized silicon carbides and silicon / silicon carbide composites. The standard excludes and/or favorably treats metallic radiant tubes in terms of relaxed requirements for: Pre-ignition Purging Sections , A , & Safety Shut-Off Valves Section Flame Supervision Section This special treatment for metallic radiant tubes ignores several decades of industry experience where deflagration / explosion has not proved to be a significant risk factor for non-metallic materials, or at minimum the incident losses are no different than metallic tubes used in equivalent service. In actual operation most metallic radiant tubes used in carburizing, carbonitriding and higher temperature processing periodically experience open-crack, thru-wall hole and/or perforation failures due to material creep distortion, carburization corrosion/embrittlement and/or weld stress fracture. Any risks posed by open metallic tube failures are no different than those of non-metallic tubes, regardless of whether combustible gases flow into the furnace chamber or, vice versa, into the radiant tube. For the processes cited above metallic failures generally occur every three to five years (sometimes sooner) mandating radiant tube replacement to maintain the integrity of the process atmosphere and quality of production. While ceramic and composite tubes available to the industrial furnace users do not experience the progressive failure modes of metallic tubes, they are more susceptible to mechanical impact and less tolerable of thermo-mechanical stress. Failure of non-metallic radiant tubes has the same effect on the furnace atmosphere and production quality, also mandating their replacement. When radiant metallic tube applications are optimally designed (so that the surface temperatures are NFPA 86 Public Inputs with Responses Report Page 87 of 230

88 8 of 222 1/26/2017 2:37 PM uniform and not excessive for the specific alloy employed), they are just as likely, if not more likely, to fail catastrophically compared with ceramic and composite tubes under the same service conditions in carburizing, carbonitriding and higher temperature atmospheres. Furthermore, consideration of radiant tube durability should not be based on new material properties, but rather on radiant tubes that are at or near the end of their useful service lives. It is at this point that a tube failure-related incident is most likely to occur. To be logically consistent both metallic and non-metallic radiant tubes used at elevated temperatures (e.g. above 1550 F) must be treated the same. For example, if flame supervision is required for non-metallic radiant tubes, then it should be required for metallic radiant tubes as well. An alternative approach might be to require that metallic tubes are removed from use before they are projected to fail (based on a documented analysis of service life in the specific application). In practice it is rare that adequate information is available to base such projections with certainty, therefore we do not envision that this risk avoidance tactic can be reliably adopted by industry. On the other hand, if metallic radiant tubes are proven to operate in service with little or no deterioration at lower temperatures (e.g. below 1550 F), a specific reliability analysis might support the conclusion that catastrophic failure is improbable in that application. The testing prescribed in Section A to validate the explosion-resistance of non-metallic materials ignores the failure modes of metallic tubes in carburizing, carbonitriding and higher temperature processing. Normative service failures (open-cracks, thru-wall holes and/or perforations) result in metallic radiant tubes incapable of supporting any pressurization whatsoever. Furthermore, the exclusion of metallic materials from these validity protocols per Section ignores the design pressure ratings of radiant tubes (as a function of wall thickness, alloy strength and weld integrity). Also longer-term metallic tube wall deterioration due to spalling and embrittlement (which inevitably occurs in high temperature service) is not considered. Related Public Inputs for This Document Related Input Public Input No. 172-NFPA [Section No ] Public Input No. 173-NFPA [Section No ] Public Input No. 174-NFPA [Section No. A ] Public Input No. 175-NFPA [Section No. A ] Public Input No. 176-NFPA [Section No. A ] Public Input No. 169-NFPA [Section No ] Public Input No. 171-NFPA [Sections , ] Relationship Submitter Full Name: Curt Colopy Organization: INEX Incorporated Submittal Date: Wed Jun 29 15:59:49 EDT 2016 NFPA 86 Public Inputs with Responses Report Page 88 of 230

89 9 of 222 1/26/2017 2:37 PM Resolution: FR-20-NFPA Statement: These requirements should be based on performance and not specifically on the type of material utilized. NFPA 86 Public Inputs with Responses Report Page 89 of 230

90 90 of 222 1/26/2017 2:37 PM Public Input No. 93-NFPA [ Section No ] * Repeating the pre-ignition purge shall not be required where any one of the following conditions is satisfied: (1) The heating chamber temperature is proved to be above 1400 F (760 C). (2) For a multiburner fuel-fired system not proved to be above 1400 F (760 C), all of the following conditions are satisfied: (3) * At least one burner remains operating in the common combustion chamber of the burner to be re-ignited. (4) The burner(s) remaining in operation shall provide ignition without explosion of any unintended release of fuel through other burners that are not in operation. (5) * For fuel gas fired burner systems and assuming that all safety shutoff valves fail in the full open position, it can be demonstrated that the combustible concentration in the heating chamber and all other passages that handle the recirculation and exhaust of products of combustion cannot exceed 25 percent of the LFL. (6) All of the following conditions are satisfied (does not apply to fuel oil systems): (7) The number of safety shutoff valves required to close in and will close between the burner system and the fuel gas supply when that burner system is off. (8) Safety shutoff valve seat leak testing is performed on at least a semiannual basis. (a) The burner system uses natural gas, butane, or propane fuel gas. (b) * It can be demonstrated based on the leakage rate, that the combustible concentration in the heating chamber and all other passages that handle the recirculation and exhaust of products of combustion cannot exceed 25 percent of the LFL. (c) The minimum airflow used in the LFL calculation in (4)(d) is proved and maintained during the period the burner(s) are off. (d) If no gas filter is installed on the individual burner, u pstream of the s afety shutoff valve(s), valve seat leak testing is performed on at least a semiannual basis. The need to perform semiannual leak testing was due to the concern of debris building up on the valve disc. However, this risk greatly reduced with a gas filter mounted upstream, and therefore, annual leak testing is sufficient. Submitter Full Name: Kevin Carlisle Organization: Karl Dungs Inc NFPA 86 Public Inputs with Responses Report Page 90 of 230

91 1 of 222 1/26/2017 2:37 PM Submittal Date: Fri Jun 10 09:43:41 EDT 2016 Resolution: FR-79-NFPA Statement: The change recognizes the integrity of using 2 safety shutoff valves in series for burners that are not operating in a multi-burner system to be an indication that the potential leakage through any safety shutoff valve is much less than the 1 SCFH recognized in the annex. The added requirement of 1 burner operating in the common combustion chamber with the burner(s) that are not operating proves that the overall burner management system is functional and the equipment is in a normal operating state. The requirement for semiannual testing of safety shutoff valves was deleted because of requirements elsewhere in the standard that specify the replacement of safety shutoff valves before they reach their allowable number of lifetime open-close cycles. NFPA 86 Public Inputs with Responses Report Page 91 of 230

92 2 of 222 1/26/2017 2:37 PM Public Input No. 96-NFPA [ Section No ] Ignition of Main Burners Fuel Gas or Oil. Where a reduced specified firing rate is required for ignition of the burner, an interlock or by the equipment, a Proved Ignition Interlock shall be provided to prove that the control valve has moved to the design Ignition position prior to each attempt at ignition. The defined term Proved Low-Fire Start Interlock is not used in the Standard. This input recommends that the term be changed and used in the mandatory text. Add Annex to identify various means to provide the interlock. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Fri Jun 10 13:23:30 EDT 2016 Resolution: FR-67-NFPA Statement: Revisions made in the mandatory text to eliminate the need for a definition. Explanatory material to identify various means to provide the proving for ignition was added. NFPA 86 Public Inputs with Responses Report Page 92 of 230

93 3 of 222 1/26/2017 2:37 PM Public Input No. 154-NFPA [ Section No ] 8.7.4* Combustion air minimum pressure or flow shall be interlocked into theburner the burner management system. by any of the following methods: (1) A low pressure switch that senses and monitors the combustion air source pressure (2) A differential pressure switch that senses the differential pressure across a fixed orifice in the combustion air system (3) An airflow switch fixed typos. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Tue Jun 28 14:31:03 EDT 2016 Resolution: FR-56-NFPA Statement: Fixed typos. Annex materials adds implementation examples. NFPA 86 Public Inputs with Responses Report Page 93 of 230

94 4 of 222 1/26/2017 2:37 PM Public Input No. 25-NFPA [ Section No ] In any combustion system where the combustion air supply can be diverted to an alternate flow path other than to a burner (e.g., to a regenerative burner system s exhaust path), that burner s associated combustion air flow path valve(s) shall be proved open, and its alternate air flow airflow path valve(s) shall be proved closed, before that burner s fuel safety shutoff valve(s) are energized. The use of term airflow and air flow should be used consistently throughout the Standard. Related Public Inputs for This Document Related Input Public Input No. 26-NFPA [Section No ] Relationship Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Sun May 01 18:53:33 EDT 2016 Resolution: FR-63-NFPA Statement: The use of term airflow and air flow should be used consistently throughout the Standard. NFPA 86 Public Inputs with Responses Report Page 94 of 230

95 5 of 222 1/26/2017 2:37 PM Public Input No. 20-NFPA [ Section No ] * Safety shutoff valves operated open-close more than 10 cycles per hour shall be permitted where all of following requirements are met: shall not be open-close cycled at a rate that exceeds exceed that specified by its manufacturer (1) The safety shutoff valves have a published designed open-close cycle rate. (2) The control logic does not result in exceeding the published open-close cycle rate of the safety shutoff valves. (3) The safety shutoff valves have a published designed lifetime number of cycles and/or time interval. (4) The safety shutoff valves are replaced prior to exceeding the lesser of the published designed lifetime number of cycles and/or time interval unless equipped with a proof of closure switch incorporating change of state logic in the burner management system. (5) The valves are tested in accordance with the manufacturer s requirements for high cycle rate valves. A The open-close safety shutoff valve cycle limit of 10 cycles per hour is intended to differentiate safety shutoff valve requirements for high cycling operation (e.g. pulse firing) from traditional operation, where safety shutoff valves cycle only a few times per day. Further, the 10 cycles per hour threshold is based on: The certification of safety shutoff valves to UL429 and/or ANSI Z21.21 / CSA 6.5 which requires demonstration that a safety shutoff valve is still fully functional and able to pass leak testing leak tight after a testing interval of 100,000 cycles and The minimum required safety shutoff valve leak tightness testing interval of at least once per year required by this Standard. Additionally, 100,000 cycles per year divided by 8,760 hours per year equals 11.4 cycles per hour which is greater than and the basis for the 10 cycles per hour threshold. The requirements of apply to all safety shutoff valve including three position safety shutoff valves and those rated for concurrent modulating service. The existing requirement in is not clear in terms of its reference to (4). A PI to revise will also be submitted. Annex material is added for additional information. Related Public Inputs for This Document Related Input Public Input No. 22-NFPA [Section No ] Relationship NFPA 86 Public Inputs with Responses Report Page 95 of 230

96 6 of 222 1/26/2017 2:37 PM Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Sun May 01 18:24:38 EDT 2016 Resolution: FR-81-NFPA Statement: The existing requirement in is not clear in terms of its reference to (4). Annex material is added for additional information. The requirements differentiate open-close cycle duty between pulse firing and non-pulse firing systems. The 10 cycles per hour were chosen as a distinct benchmark to differentiate these systems and is explained further in annex material. NFPA 86 Public Inputs with Responses Report Page 96 of 230

97 7 of 222 1/26/2017 2:37 PM Public Input No. 53-NFPA [ Section No ] Valves shall not be subjected to supply gas pressures in excess of the manufacturer's ratings rated pressure. rated pressure is now a defined term, and is the proper usage here. Also remove supply pressures and change to gas pressure. The pressure could come from the backside of the gas valve. Submitter Full Name: Kevin Carlisle Organization: Affilliation: Industrial Heating Equipment Association Industrial Heating Equipment Association Submittal Date: Fri Jun 03 14:59:14 EDT 2016 Resolution: CI-5-NFPA Statement: The proposal standardizes on pressure rating terms and uses the ASME B31.3 terms in the same way. This may include working pressure and rated pressure. The committee recognizes pressure definition confusion and a task group has been formed to address this topic. NFPA 86 Public Inputs with Responses Report Page 97 of 230

98 8 of 222 1/26/2017 2:37 PM Public Input No. 172-NFPA [ Section No ] Each main and pilot fuel gas burner system shall be separately equipped with either of the following: (1) Two safety shutoff valves piped in series (2) For radiant tube fired burner systems only, a single safety shutoff valve where either of the following conditions is satisfied: (3) The tubes are of metal construction and open at one or both ends. If heat recovery systems are used, they shall be of explosion-resistant construction. (4) The entire radiant tube heating system, including any associated heat recovery system, is of explosion-resistant construction. is required. The current NFPA Standard for Ovens and Furnaces implies that metallic radiant tubes are safer than other high temperature materials of construction such as ceramics and composites. Alternative non-metallic materials currently in industrial radiant tube service include mullites, sialons, silicon nitrides, siliconized silicon carbides and silicon / silicon carbide composites. The standard excludes and/or favorably treats metallic radiant tubes in terms of relaxed requirements for: Pre-ignition Purging Sections , A , & Safety Shut-Off Valves Section Flame Supervision Section This special treatment for metallic radiant tubes ignores several decades of industry experience where deflagration / explosion has not proved to be a significant risk factor for non-metallic materials, or at minimum the incident losses are no different than metallic tubes used in equivalent service. In actual operation most metallic radiant tubes used in carburizing, carbonitriding and higher temperature processing periodically experience open-crack, thru-wall hole and/or perforation failures due to material creep distortion, carburization corrosion/embrittlement and/or weld stress fracture. Any risks posed by open metallic tube failures are no different than those of non-metallic tubes, regardless of whether combustible gases flow into the furnace chamber or, vice versa, into the radiant tube. For the processes cited above metallic failures generally occur every three to five years (sometimes sooner) mandating radiant tube replacement to maintain the integrity of the process atmosphere and quality of production. While ceramic and composite tubes available to the industrial furnace users do not experience the progressive failure modes of metallic tubes, they are more susceptible to mechanical impact and less tolerable of thermo-mechanical stress. Failure of non-metallic radiant tubes has the same effect on the furnace atmosphere and production quality, also mandating their replacement. NFPA 86 Public Inputs with Responses Report Page 98 of 230

99 9 of 222 1/26/2017 2:37 PM When radiant metallic tube applications are optimally designed (so that the surface temperatures are uniform and not excessive for the specific alloy employed), they are just as likely, if not more likely, to fail catastrophically compared with ceramic and composite tubes under the same service conditions in carburizing, carbonitriding and higher temperature atmospheres. Furthermore, consideration of radiant tube durability should not be based on new material properties, but rather on radiant tubes that are at or near the end of their useful service lives. It is at this point that a tube failure-related incident is most likely to occur. To be logically consistent both metallic and non-metallic radiant tubes used at elevated temperatures (e.g. above 1550 F) must be treated the same. For example, if flame supervision is required for non-metallic radiant tubes, then it should be required for metallic radiant tubes as well. An alternative approach might be to require that metallic tubes are removed from use before they are projected to fail (based on a documented analysis of service life in the specific application). In practice it is rare that adequate information is available to base such projections with certainty, therefore we do not envision that this risk avoidance tactic can be reliably adopted by industry. On the other hand, if metallic radiant tubes are proven to operate in service with little or no deterioration at lower temperatures (e.g. below 1550 F), a specific reliability analysis might support the conclusion that catastrophic failure is improbable in that application. The testing prescribed in Section A to validate the explosion-resistance of non-metallic materials ignores the failure modes of metallic tubes in carburizing, carbonitriding and higher temperature processing. Normative service failures (open-cracks, thru-wall holes and/or perforations) result in metallic radiant tubes incapable of supporting any pressurization whatsoever. Furthermore, the exclusion of metallic materials from these validity protocols per Section ignores the design pressure ratings of radiant tubes (as a function of wall thickness, alloy strength and weld integrity). Also longer-term metallic tube wall deterioration due to spalling and embrittlement (which inevitably occurs in high temperature service) is not considered. Related Public Inputs for This Document Related Input Public Input No. 173-NFPA [Section No ] Public Input No. 174-NFPA [Section No. A ] Public Input No. 175-NFPA [Section No. A ] Public Input No. 176-NFPA [Section No. A ] Public Input No. 169-NFPA [Section No ] Public Input No. 170-NFPA [Sections , ] Public Input No. 171-NFPA [Sections , ] Relationship Submitter Full Name: Curt Colopy Organization: INEX Incorporated Submittal Date: Wed Jun 29 16:11:35 EDT 2016 NFPA 86 Public Inputs with Responses Report Page 99 of 230

100 00 of 222 1/26/2017 2:37 PM Resolution: FR-21-NFPA Statement: These requirements should be based on performance and not specifically on the type of material utilized. NFPA 86 Public Inputs with Responses Report Page 100 of 230

101 01 of 222 1/26/2017 2:37 PM Public Input No. 173-NFPA [ Section No ] The following shall not require a supervised flame: (1) Burner flames for radiant tube type heating systems where a means of ignition is provided and the systems are arranged and designed such that either of the following conditions is satisfied:the tubes are of metal high temperature construction and open at one or both ends. If heat recovery systems are used, they shall be of explosion-resistant high temperature construction. (2) The entire radiant tube heating system, including any associated heat recovery system, is of explosion-resistant construction. (3) Burner flames at burners interlocked with a 1400 F (760 C) bypass interlock that prevents burner operation when the temperature in the zone where the burner is located is less than 1400 F (760 C). The current NFPA Standard for Ovens and Furnaces implies that metallic radiant tubes are safer than other high temperature materials of construction such as ceramics and composites. Alternative non-metallic materials currently in industrial radiant tube service include mullites, sialons, silicon nitrides, siliconized silicon carbides and silicon / silicon carbide composites. The standard excludes and/or favorably treats metallic radiant tubes in terms of relaxed requirements for: Pre-ignition Purging Sections , A , & Safety Shut-Off Valves Section Flame Supervision Section This special treatment for metallic radiant tubes ignores several decades of industry experience where deflagration / explosion has not proved to be a significant risk factor for non-metallic materials, or at minimum the incident losses are no different than metallic tubes used in equivalent service. In actual operation most metallic radiant tubes used in carburizing, carbonitriding and higher temperature processing periodically experience open-crack, thru-wall hole and/or perforation failures due to material creep distortion, carburization corrosion/embrittlement and/or weld stress fracture. Any risks posed by open metallic tube failures are no different than those of non-metallic tubes, regardless of whether combustible gases flow into the furnace chamber or, vice versa, into the radiant tube. For the processes cited above metallic failures generally occur every three to five years (sometimes sooner) mandating radiant tube replacement to maintain the integrity of the process atmosphere and quality of production. While ceramic and composite tubes available to the industrial furnace users do not experience the progressive failure modes of metallic tubes, they are more susceptible to mechanical impact and less tolerable of thermo-mechanical stress. Failure of non-metallic radiant tubes has the same effect on the furnace atmosphere and production quality, also mandating their replacement. When radiant metallic tube applications are optimally designed (so that the surface temperatures are NFPA 86 Public Inputs with Responses Report Page 101 of 230

102 02 of 222 1/26/2017 2:37 PM uniform and not excessive for the specific alloy employed), they are just as likely, if not more likely, to fail catastrophically compared with ceramic and composite tubes under the same service conditions in carburizing, carbonitriding and higher temperature atmospheres. Furthermore, consideration of radiant tube durability should not be based on new material properties, but rather on radiant tubes that are at or near the end of their useful service lives. It is at this point that a tube failure-related incident is most likely to occur. To be logically consistent both metallic and non-metallic radiant tubes used at elevated temperatures (e.g. above 1550 F) must be treated the same. For example, if flame supervision is required for non-metallic radiant tubes, then it should be required for metallic radiant tubes as well. An alternative approach might be to require that metallic tubes are removed from use before they are projected to fail (based on a documented analysis of service life in the specific application). In practice it is rare that adequate information is available to base such projections with certainty, therefore we do not envision that this risk avoidance tactic can be reliably adopted by industry. On the other hand, if metallic radiant tubes are proven to operate in service with little or no deterioration at lower temperatures (e.g. below 1550 F), a specific reliability analysis might support the conclusion that catastrophic failure is improbable in that application. The testing prescribed in Section A to validate the explosion-resistance of non-metallic materials ignores the failure modes of metallic tubes in carburizing, carbonitriding and higher temperature processing. Normative service failures (open-cracks, thru-wall holes and/or perforations) result in metallic radiant tubes incapable of supporting any pressurization whatsoever. Furthermore, the exclusion of metallic materials from these validity protocols per Section ignores the design pressure ratings of radiant tubes (as a function of wall thickness, alloy strength and weld integrity). Also longer-term metallic tube wall deterioration due to spalling and embrittlement (which inevitably occurs in high temperature service) is not considered. Related Public Inputs for This Document Related Input Public Input No. 174-NFPA [Section No. A ] Public Input No. 175-NFPA [Section No. A ] Public Input No. 176-NFPA [Section No. A ] Public Input No. 169-NFPA [Section No ] Public Input No. 170-NFPA [Sections , ] Public Input No. 171-NFPA [Sections , ] Public Input No. 172-NFPA [Section No ] Relationship Submitter Full Name: Curt Colopy Organization: INEX Incorporated Submittal Date: Wed Jun 29 16:15:33 EDT 2016 NFPA 86 Public Inputs with Responses Report Page 102 of 230

103 03 of 222 1/26/2017 2:37 PM Resolution: FR-22-NFPA Statement: These requirements should be based on performance and not specifically on the type of material utilized. NFPA 86 Public Inputs with Responses Report Page 103 of 230

104 04 of 222 1/26/2017 2:37 PM Public Input No. 147-NFPA [ Section No ] * Line burners A line burner, pipe burners burner, and radiant burners, where installed adjacent to one another or connected with flame-propagating devices, shall be considered to be a single burner and shall or radiant burner with flames propagating 3 or longer shall have at least one flame detector installed to only sense the main burner flame at the end of the assembly farthest from the source of ignition A line burner, pipe burner, or radiant burner with a pilot shall have one flame detector installed to sense pilot burner flame at the source of ignition. Additional information is desired to define the circumstance when 2 flame detectors are required. The 3' length requirement referenced is from Canadian B149.3 clause Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: group Submittal Date: Tue Jun 28 14:06:00 EDT 2016 Resolution: FR-60-NFPA Statement: Adjacent is relative. Unburned fuel in the firing chamber or direct-fired heating duct is a primary combustion system hazard. Lineburners and such that operate without fully propagated flames can produce significant amounts of unburned fuel. Lack of flame development across the entire lineburner length may be caused by uneven process air flow distribution through the burner, burner damage, or debris accumulation. Previous wording is subject to interpretation and does not exclude very short line burner lengths that have low risk for flame propagation failure. Annex to help identify requirements when trying to independently monitor the pilot and main flame. NFPA 86 Public Inputs with Responses Report Page 104 of 230

105 05 of 222 1/26/2017 2:37 PM Public Input No. 63-NFPA [ Section No ] * Line burners A line burner, pipe burners burner, and radiant burners, where installed adjacent to one another or connected with flame-propagating devices, shall be considered to be a single burner and shall or radiant burner with flames propagating 3 or longer shall have at least one flame detector installed to sense main burner flame at the end of the assembly farthest from the source of ignition. Adjacent is relative. Unburned fuel in the firing chamber or direct-fired heating duct is a primary combustion system hazard. Lineburners and such that operate without fully propagated flames can produce significant amounts of unburned fuel. Lack of flame development across the entire lineburner length may be caused by uneven process air flow distribution through the burner, burner damage, or debris accumulation. Previous wording is subject to interpretation and does not exclude very short line burner lengths that have low risk for flame propagation failure. Submitter Full Name: Kevin Carlisle Organization: Industrial Heating Equipment Association Affilliation: Industrial Heating Equipment Association Submittal Date: Fri Jun 03 15:23:12 EDT 2016 Resolution: FR-60-NFPA Statement: Adjacent is relative. Unburned fuel in the firing chamber or direct-fired heating duct is a primary combustion system hazard. Lineburners and such that operate without fully propagated flames can produce significant amounts of unburned fuel. Lack of flame development across the entire lineburner length may be caused by uneven process air flow distribution through the burner, burner damage, or debris accumulation. Previous wording is subject to interpretation and does not exclude very short line burner lengths that have low risk for flame propagation failure. Annex to help identify requirements when trying to independently monitor the pilot and main flame. NFPA 86 Public Inputs with Responses Report Page 105 of 230

106 06 of 222 1/26/2017 2:37 PM Public Input No. 14-NFPA [ Section No ] Where sprinklers are selected for the protection of ovens, furnaces, or related equipment, the use of closed-head sprinkler sprinkler systems shall be prohibited, and only deluge sprinkler systems shall be used where the following conditions exist: (1) In equipment where temperatures can exceed 625 F (329 C) (2) Where flash fire conditions can occur The word sprinkler should be used verses head. NFPA 13 does not define what a head is. Submitter Full Name: PETER SCHWAB Organization: WAYNE AUTOMATIC FIRE SPRINKLER Submittal Date: Tue Oct 20 09:45:31 EDT 2015 Resolution: FR-84-NFPA Statement: Open sprinkler is defined so that term was used in the above revision. The submitter pointed out that the term closed head is not used in NFPA 13. NFPA 86 Public Inputs with Responses Report Page 106 of 230

107 07 of 222 1/26/2017 2:37 PM Public Input No. 149-NFPA [ New Section after ] * Purging Equipment shall not be purged into a running thermal oxidizer unless one of the following condi ons is met: (1) It shall be demonstrated that the flammable vapor concentra on entering the fume incinerator cannot exceed 50 percent of the LFL under all an cipated normal and abnormal opera ng condi ons. (2) Where it is not permi ed to discharge the air mixture being purged directly to atmosphere, the source equipment, connec ng ductwork and thermal oxidizers used to oxidize the purge discharge shall have be have explosion preven on and protec on systems designed and installed in accordance with the requirements of NFPA 69. Currently the introductory chapters only preclude purging ovens and furnaces into running incinerators (as referenced in and ). However, Thermal oxidizers may process fumes that are sourced from equipment other than ovens and furnaces. Restricting concentrations to a maximum of 50% LFL, regardless of flammable gas/vapor source, the likelihood of the mixture being ignited and flashing back into the source equipment is reduced. Alternatively NFPA 69, which requires redundant methods of explosion prevention and protection, may provide an effective approach for processes where the equipment exhaust is toxic and must be oxidized at all times (discharge to atmosphere is not acceptable). Related Public Inputs for This Document Related Input Public Input No. 155-NFPA [New Section after A ] Relationship Submitter Full Name: Thomas George Organization: Tokio Marine Management, Inc. Submittal Date: Tue Jun 28 14:15:43 EDT 2016 Resolution: FR-85-NFPA Statement: Currently the introductory chapters only preclude purging ovens and furnaces into running incinerators (as referenced in and ). However, thermal oxidizers NFPA 86 Public Inputs with Responses Report Page 107 of 230

108 08 of 222 1/26/2017 2:37 PM may process fumes that are sourced from equipment other than ovens and furnaces. Restricting concentrations to a maximum of 50% LFL, regardless of flammable gas/vapor source, the likelihood of the mixture being ignited and flashing back into the source equipment is reduced. Alternatively NFPA 69, which requires redundant methods of explosion prevention and protection, may provide an effective approach for processes where the equipment exhaust is toxic and must be oxidized at all times (discharge to atmosphere is not acceptable). NFPA 86 Public Inputs with Responses Report Page 108 of 230

109 09 of 222 1/26/2017 2:37 PM Public Input No. 26-NFPA [ Section No ] * Safety ventilation shall be proved by one of the following: (1) A dedicated exhaust fan proved in accordance with Section 8.6 (2) The presence of at least the required fresh air flow airflow into the system proven in accordance with (3) The presence of at least the required exhaust flow out of the system proven in accordance with (4) A continuous vapor concentration high- limit controller in accordance with The use of term airflow and air flow should be used consistently throughout the Standard. Related Public Inputs for This Document Related Input Public Input No. 25-NFPA [Section No ] Public Input No. 27-NFPA [Section No ] Public Input No. 29-NFPA [Section No. A ] Relationship Same comment. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Sun May 01 18:55:17 EDT 2016 Resolution: FR-58-NFPA Statement: The use of term airflow and air flow should be used consistently throughout the Standard. NFPA 86 Public Inputs with Responses Report Page 109 of 230

110 10 of 222 1/26/2017 2:37 PM Public Input No. 27-NFPA [ Section No ] Safety ventilation shall be arranged to meet the following design characteristics: (1) The reduction of air flow airflow below the minimum required by shall activate the ventilation safety devices provided in accordance with Section 8.6. (2) The physical arrangement of dampers, fans, ducts, chambers, and passages shall ensure that a short-circuited airflow cannot occur without activating the ventilation safety devices provided in accordance with Section 8.6. The use of term airflow and air flow should be used consistently throughout the Standard. Related Public Inputs for This Document Related Input Public Input No. 26-NFPA [Section No ] Public Input No. 28-NFPA [Section No ] Relationship same comment. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Sun May 01 18:56:52 EDT 2016 Resolution: FR-26-NFPA Statement: The use of term airflow and air flow should be used consistently throughout the Standard. NFPA 86 Public Inputs with Responses Report Page 110 of 230

111 11 of 222 1/26/2017 2:37 PM Public Input No. 28-NFPA [ Section No ] * The required minimum rate of exhaust air flow airflow, at standard atmosphere and temperature, shall be determined by multiplying the cubic feet of diluted mixture at 25 percent LFL per gallon of solvent evaporated in the process by the maximum allowable gallons per minute of solvent entering the process oven, as follows: [ ] The use of term airflow and air flow should be used consistently throughout the Standard. Related Public Inputs for This Document Related Input Public Input No. 27-NFPA [Section No ] Relationship Same comment. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Sun May 01 18:58:34 EDT 2016 Resolution: FR-27-NFPA Statement: The use of term airflow and air flow should be used consistently throughout the Standard. NFPA 86 Public Inputs with Responses Report Page 111 of 230

112 12 of 222 1/26/2017 2:37 PM Public Input No. 162-NFPA [ Section No ] * Methods for Determining Solvent Safety Ventilation Rate. In batch process ovens, the rate of safety ventilation air shall be either calculated proven using (A) or estimated using (B). (A) Method for Calculating Proving Ventilation Rate. The minimum safety ventilation rate shall be one of the following: 440 scfm of air per gal (3.29 standard m 3 /min of air per L) of solvent Other Where o ther than 440 scfm (3.29 standard m 3 /min) where ventilation is provided, with exhaust the following safety ventilation equipment and controls shall be provided: (1) Exhaust fans and other devices designed to prevent average concentration in the oven from exceeding 25 percent of the LFL (2) A continuous vapor concentration high limit controller meeting one both of the following criteria: (3) The controller is arranged to alarm and shut down the oven heating system if the vapor concentration exceeds 50 percent of the LFL. (4) The controller is arranged to operate additional exhaust fans at a predetermined vapor concentration not exceeding 50 percent of the LFL. The amount of ventilation air in standard cubic feet (standard cubic meters) that is rendered barely flammable by the vapor generated in gallons per hour (liters per hour) of solvent in use is determined, and the determined value then is multiplied by an empirical factor of 10 and divided by 60 minutes/hour to obtain the safety ventilation in standard cubic feet per minute (standard cubic meters per minute). (a) NFPA 86 Public Inputs with Responses Report Page 112 of 230

113 13 of 222 1/26/2017 2:37 PM (B) Method for Estimating Rate of Ventilation. Batch ovens shall have a minimum safety ventilation rate either of that given in (A) or as follows: (1) The safety ventilation rate of batch ovens shall be designed and maintained to provide 440 scfm of air per gal (3.29 standard m 3 /min of air per L) of flammable volatiles in each batch. (2) * Where the solvent used requires a volume of air greater than 2640 standard ft 3 to dilute vapor from 1 gal of solvent to the LFL (19.75 standard m 3 /L), safety ventilation shall be adjusted in proportion to the ratio of the actual volume of air necessary to render 2640 ft 3 /gal (19.75 m 3 /L) barely explosive. CAUTION: Caution shall be used where applying this method to products of low mass that can heat up quickly (such as paper or textiles) or materials coated with very highly volatile solvents. Either condition can produce too high a peak evaporation rate for this method to be used. Method A as currently written is not a calculation method and is written in a confusing manner. (A)(1) is a duplication of the estimation method B. (A)(2) is meaningless as a standalone requirement. It references the 25% LFL limit requirement but provides no direction as to whether that is achieved through empirical testing, LFL monitoring, or other controls. If empirical testing, additional language is needed to explain the evaporation concentration curve from flash off to finish during the heating cycle and how to conservatively determine the required airflow on this basis. However, that is beyond the scope and intent of the current edition of NFPA 86. (A)(2) and (A)(3) make sense when tied together, as one requires ventilation and control devices and the other specifies what actions must take place when LFL concentrations exceed design limits or 50% LFL. Submitter Full Name: Thomas George Organization: Tokio Marine Management, Inc. Submittal Date: Tue Jun 28 14:57:58 EDT 2016 Resolution: FR-86-NFPA Statement: Method A was revised to clarify that it is not a calculation but a method for controlling vapor concentration. NFPA 86 Public Inputs with Responses Report Page 113 of 230

114 14 of 222 1/26/2017 2:37 PM Public Input No. 72-NFPA [ Section No ] Inert Gas Introduction and Starting the Production Line. The following procedures shall be accomplished for inert gas introduction and starting the production line: (1) Verifying that all personnel are out of the oven enclosure, all guards are in place, and all doors are closed (2) Verifying that the volume of inert gas is in storage and that the inert gas supply and solvent recovery systems are operational and ready to start production (3) Verifying that the solvent recovery system interfaced with the oven is operational and prepared to receive solvent-laden gas prior to starting production (4) Starting the recirculation fans in the oven enclosure prior to introduction of inert gas to ensure that effective oxygen purging occurs once inert gas enters the enclosure (5) * Purging the oven enclosure with inert gas until the gas until the requirements of are satisfied as well as the enclosure oxygen concentration is three percentage points below the limiting oxidant concentration (LOC) that is able to support combustion of the solvents used (6) Heating the recirculating oven gas to the required operating temperature The introduction of inert gas outline did not specify if the pre-ignition purge cycle was required along with attaining the design LOC minus three percent. Submitter Full Name: Robert Davis Organization: Alcoa Submittal Date: Thu Jun 09 14:12:37 EDT 2016 Resolution: Current language is sufficient to address this issue. An inert oven is not similar to a conventional oven in its requirements for purge. NFPA 86 Public Inputs with Responses Report Page 114 of 230

115 15 of 222 1/26/2017 2:37 PM Public Input No. 117-NFPA [ Section No (F) ] (F) Where inert gases are used as safety purge media, the minimum volume stored shall be the amount required to purge all connected special atmosphere furnaces with at least five furnace volume changes wherever the flammable atmospheres are being used. This is redundant material, this requirement already covered in paragraph (D)(1). Submitter Full Name: Mark Stender Organization: Surface Combustion, Inc. Submittal Date: Tue Jun 21 13:46:56 EDT 2016 Resolution: FR-88-NFPA Statement: (F) is already covered in paragraph (D)(1). NFPA 86 Public Inputs with Responses Report Page 115 of 230

116 16 of 222 1/26/2017 2:37 PM Public Input No. 118-NFPA [ Section No ] The When furnace chamber door operation or workload quenching causes atmosphere contractions, the flow rates used shall restore positive internal pressure without infiltration of air during atmosphere contractions when furnace chamber doors close or workloads are quenched before any air infiltration can reach an hazardous explosive level. During workload cycling (e.g. movement into and out of the furnace and quenching) air infiltration occurs. Flow rates should safely limit this air infiltration until positive pressure is restored. Submitter Full Name: Mark Stender Organization: Surface Combustion, Inc. Submittal Date: Tue Jun 21 13:51:49 EDT 2016 Resolution: FR-89-NFPA Statement: During workload cycling (e.g. movement into and out of the furnace and quenching) air infiltration occurs. Flow rates should safely limit this air infiltration until positive pressure is restored. NFPA 86 Public Inputs with Responses Report Page 116 of 230

117 17 of 222 1/26/2017 2:37 PM Public Input No. 119-NFPA [ Section No [Excluding any Sub-Sections] ] Synthetic atmosphere flow control units shall have the additional capabilities specified in through Corrects editorial error (i.e. all of the following sections/paragraphs apply). Submitter Full Name: Mark Stender Organization: Surface Combustion, Inc. Submittal Date: Tue Jun 21 13:56:09 EDT 2016 Resolution: FR-90-NFPA Statement: Corrects editorial error (i.e. all of the following sections/paragraphs apply). NFPA 86 Public Inputs with Responses Report Page 117 of 230

118 18 of 222 1/26/2017 2:37 PM Public Input No. 120-NFPA [ New Section after (F) ] (G)* Where a furnace uses an atmosphere oil seal, means shall be provided so that furnace pressure is maintained below the static head pressure of the seal oil. 1. In the 2015 edition paragraph (C) is the only place that lists requirements for oil seals. This paragraph is specific to burn-in requirements for Type VIII and IX furnaces only. 2. The above public comment moves the requirement to the general where it would apply to any atmosphere oil seal that is used by a Class C furnace and for any type of introduction of atmosphere (i.e. burn-in or purge-in). Submitter Full Name: Mark Stender Organization: Surface Combustion, Inc. Submittal Date: Tue Jun 21 14:00:19 EDT 2016 Resolution: FR-91-NFPA Statement: 1. In the 2015 edition paragraph (C) is the only place that lists requirements for oil seals. This paragraph is specific to burn-in requirements for Type VIII and IX furnaces only. 2. The above public comment moves the requirement to the general where it would apply to any atmosphere oil seal that is used by a Class C furnace and for any type of introduction of atmosphere (i.e. burn-in or purge-in). NFPA 86 Public Inputs with Responses Report Page 118 of 230

119 19 of 222 1/26/2017 2:37 PM Public Input No. 122-NFPA [ Section No (B) ] (B)* Burn-off pilots that are exposed to inert purge gas or special atmosphere gas under either normal or emergency conditions shall be of a type that will remain in service to ignite flammable effluent gases. This requirement should apply to door and open end burn-off pilots as well as effluent burn-off pilots. Submitter Full Name: Mark Stender Organization: Surface Combustion, Inc. Submittal Date: Tue Jun 21 14:14:00 EDT 2016 Resolution: The meaning of effluent in Merriam Websters is appropriate. NFPA 86 Public Inputs with Responses Report Page 119 of 230

120 20 of 222 1/26/2017 2:37 PM Public Input No. 144-NFPA [ Section No ] * Flame Curtains. Where a flame curtain is used, the following features shall be provided and in service: (1) One or more flame curtain pilots shall be positioned to reliably ignite the flame curtain. (2) * At least one flame curtain pilot at a flame curtain shall have flame supervision interlocked to prevent the opening of a closed door served and interlocked to prevent operation of the flame curtain at the door served. (3) At least one safety shutoff valve upstream of all flame curtains on a furnace shall be interlocked to close upon the following conditions: (4) Low fuel gas pressure on the flame curtain fuel gas supply (5) High fuel gas pressure on the flame curtain fuel gas supply where a high gas pressure issue would create a safety concern (6) For flame curtains equipped with flame supervision independent of the flame curtain pilot flame supervision, it is permissible to bypass the SSOV interlocks in (3)(a) and (3)(b) once the door served is open provided that flame curtain flame is sensed by the flame curtain flame supervision system. (7) An automatic control valve shall be provided ahead of each flame curtain arranged to open when the door served is not closed. (8) When the safety shutoff valve in item (3) is closed, any doors served by that safety shutoff valve shall be interlocked so they cannot open. (9) * A manual means of overriding the door interlock in (5) shall be provided. AFC-Holcroft has encountered instances wherein a flame curtain pilot flame is unexpectedly extinguished (due to air drafts, poor adjustment, etc.) when the furnace door is open with flammable atmosphere gas present. The loss of pilot flame has resulted in the flame curtain gas SSOV closing via the interlock prescribed in NFPA (2), thereby extinguishing the flame curtain flame. In some of these instances involving batch integral quench furnaces, an explosion has occurred due to the build-up of an explosive atmosphere in the vestibule. AFC-Holcroft believes it is of utmost importance to maintain a reliable ignition source to combust the flammable atmosphere gasses. Therefore AFC-Holcroft proposes to allow the interlocks in and to be bypassed if the flame curtain is equipped with a flame supervision system independent of the flame screen pilot flame supervision system and provided that the flame curtain flame is sensed by its independent flame supervision system. With the changes promulgated by AFC-Holcroft, the flame curtain SSOV will remain open after initiating the door open sequence regardless of the status of low and high gas pressure interlocks or loss of flame curtain pilot flame provided that the flame curtain flame supervision detects flame present. Should an abnormal flame curtain gas pressure condition occur, the flame curtain flame supervision will be active to shut off the flame curtain SSOV should the flame curtain flame be extinguished. NFPA 86 Public Inputs with Responses Report Page 120 of 230

121 21 of 222 1/26/2017 2:37 PM Related Public Inputs for This Document Related Input Public Input No. 143-NFPA [New Section after ] Public Input No. 145-NFPA [Section No. A ] Public Input No. 146-NFPA [New Section after A ] Relationship Submitter Full Name: Joseph Kozma III Organization: AFC-Holcroft LLC Submittal Date: Tue Jun 28 12:58:06 EDT 2016 Resolution: FR-100-NFPA Statement: Improves on the overall safety of the flame curtain operation. The statement added to the A Annex provides additional guidance on the use of flame curtains. NFPA 86 Public Inputs with Responses Report Page 121 of 230

122 22 of 222 1/26/2017 2:37 PM Public Input No. 123-NFPA [ Section No ] Flammable Special Atmosphere Introduction. Flammable special atmospheres shall be introduced into a furnace using one of the following methods: (1) Purge-in (2) Burn With the exception of Type VIII furnaces, burn -in The exception of burn-in should listed here, the reader of the standard should not have to read to paragraph to find the exception. Submitter Full Name: Mark Stender Organization: Surface Combustion, Inc. Submittal Date: Tue Jun 21 14:17:02 EDT 2016 Resolution: FR-93-NFPA Statement: Type VIII purge-in and purge-out only requirements should not be buried in the text. Oil seal design requirements should be located to General not Burn-in Requirements. Burn-off pilots lit and correct oil levels requirements should be included for burn-in the same as they are required for purge-in. Annex: 1. Existing paragraph prohibits using burn-in for Type VIII furnaces, so any special requirements of Type VIII is a moot point. 2. As for Type IX furnaces, the Table states that the furnace may or may not have a cover therefore references to covers is inappropriate. NFPA 86 Public Inputs with Responses Report Page 122 of 230

123 23 of 222 1/26/2017 2:37 PM Public Input No. 124-NFPA [ Section No ] Flammable Special Atmosphere Removal. Flammable special atmospheres shall be removed from a furnace using one of the following methods: (1) Purge-out Burn-out (2) With the exception of Type VIII furnaces, burn-out The exception of burn-out should listed here, the reader of the standard should not have to read to paragraph to find the exception. Submitter Full Name: Mark Stender Organization: Surface Combustion, Inc. Submittal Date: Tue Jun 21 14:19:41 EDT 2016 Resolution: FR-93-NFPA Statement: Type VIII purge-in and purge-out only requirements should not be buried in the text. Oil seal design requirements should be located to General not Burn-in Requirements. Burn-off pilots lit and correct oil levels requirements should be included for burn-in the same as they are required for purge-in. Annex: 1. Existing paragraph prohibits using burn-in for Type VIII furnaces, so any special requirements of Type VIII is a moot point. 2. As for Type IX furnaces, the Table states that the furnace may or may not have a cover therefore references to covers is inappropriate. NFPA 86 Public Inputs with Responses Report Page 123 of 230

124 24 of 222 1/26/2017 2:37 PM Public Input No. 125-NFPA [ Section No ] Special Requirements for Type VIII and IX Furnaces. (A) Circulating base fans, where provided, shall be turned on. (B) * The cover shall be sealed to the furnace base before flammable or indeterminate special atmospheres are introduced. (C) * Where a furnace uses an oil seal between a cover and a base, means shall be provided so that furnace pressure is maintained below the static head pressure of the seal oil. 1. Existing paragraph prohibits using burn-in for Type VIII furnaces, so any special requirements of Type VIII is a moot point. 2. As for Type IX furnaces, the Table states that the furnace may or may not have a cover therefore references to covers is inappropriate. Submitter Full Name: Mark Stender Organization: Surface Combustion, Inc. Submittal Date: Tue Jun 21 14:40:32 EDT 2016 Resolution: FR-93-NFPA Statement: Type VIII purge-in and purge-out only requirements should not be buried in the text. Oil seal design requirements should be located to General not Burn-in Requirements. Burn-off pilots lit and correct oil levels requirements should be included for burn-in the same as they are required for purge-in. Annex: 1. Existing paragraph prohibits using burn-in for Type VIII furnaces, so any special requirements of Type VIII is a moot point. NFPA 86 Public Inputs with Responses Report Page 124 of 230

125 25 of 222 1/26/2017 2:37 PM 2. As for Type IX furnaces, the Table states that the furnace may or may not have a cover therefore references to covers is inappropriate. NFPA 86 Public Inputs with Responses Report Page 125 of 230

126 26 of 222 1/26/2017 2:37 PM Public Input No. 127-NFPA [ Section No ] For Type VIII furnaces, atmosphere introduction shall be by purge-in, and atmosphere removal shall be by purge-out; burn-in and burn-out procedures shall not be used. 1. Paragraph only pertains to Burn-in Requirements, therefore any requirements for atmosphere removal is misplaced. 2. Locating to the beginning of the paragraph makes for a more natural flow of text for the reader of the standard. 3. Subsequent paragraphs need to be renumbered. Submitter Full Name: Mark Stender Organization: Surface Combustion, Inc. Submittal Date: Tue Jun 21 15:05:41 EDT 2016 Resolution: FR-93-NFPA Statement: Type VIII purge-in and purge-out only requirements should not be buried in the text. Oil seal design requirements should be located to General not Burn-in Requirements. Burn-off pilots lit and correct oil levels requirements should be included for burn-in the same as they are required for purge-in. Annex: 1. Existing paragraph prohibits using burn-in for Type VIII furnaces, so any special requirements of Type VIII is a moot point. 2. As for Type IX furnaces, the Table states that the furnace may or may not have a cover therefore references to covers is inappropriate. NFPA 86 Public Inputs with Responses Report Page 126 of 230

127 27 of 222 1/26/2017 2:37 PM Public Input No. 128-NFPA [ New Section after ] Flammable special atmosphere gases shall not be introduced unless the following conditions exist: (1) Burn-off pilots at open ends, doors, and effluent lines are ignited. (2)* All required quench fluid levels are at the correct level. (3) Operation of flame curtains (where provided) is verified. 1. Adds introduction of atmosphere requirements for burn-in, similar to those required for purge-in (paragraph ). 2. Annex material will have to be re-referenced. Submitter Full Name: Mark Stender Organization: Surface Combustion, Inc. Submittal Date: Tue Jun 21 15:17:06 EDT 2016 Resolution: FR-93-NFPA Statement: Type VIII purge-in and purge-out only requirements should not be buried in the text. Oil seal design requirements should be located to General not Burn-in Requirements. Burn-off pilots lit and correct oil levels requirements should be included for burn-in the same as they are required for purge-in. Annex: 1. Existing paragraph prohibits using burn-in for Type VIII furnaces, so any special requirements of Type VIII is a moot point. 2. As for Type IX furnaces, the Table states that the furnace may or may not have a cover therefore references to covers is inappropriate. NFPA 86 Public Inputs with Responses Report Page 127 of 230

128 28 of 222 1/26/2017 2:37 PM Public Input No. 129-NFPA [ Section No ] For Type VIII furnaces, burn-out procedures shall not be used Written burn-out instructions shall be provided for each furnace. (A)* Burn-out effectiveness shall not be compromised by taking any action that deviates from the written operating instructions for burn-out. (B)* Inner and outer furnace doors, where provided, shall be placed in the appropriate position as directed in the operating instructions during each stage of the burn-out procedure. 1. Locates existing paragraph requirement of purge-out only for Type VIII furnaces to correct paragraph (i.e ). 2. Locating at the beginning of the paragraph is a natural flow of text for the reader of the standard. 3. Subsequent paragraphs need to be renumbered. Submitter Full Name: Mark Stender Organization: Surface Combustion, Inc. Submittal Date: Tue Jun 21 15:54:32 EDT 2016 Resolution: FR-93-NFPA Statement: Type VIII purge-in and purge-out only requirements should not be buried in the text. Oil seal design requirements should be located to General not Burn-in Requirements. Burn-off pilots lit and correct oil levels requirements should be included for burn-in the same as they are required for purge-in. Annex: 1. Existing paragraph prohibits using burn-in for Type VIII furnaces, so any special requirements of Type VIII is a moot point. NFPA 86 Public Inputs with Responses Report Page 128 of 230

129 29 of 222 1/26/2017 2:37 PM 2. As for Type IX furnaces, the Table states that the furnace may or may not have a cover therefore references to covers is inappropriate. NFPA 86 Public Inputs with Responses Report Page 129 of 230

130 30 of 222 1/26/2017 2:37 PM Public Input No. 130-NFPA [ Section No ] External Air-Cooled Heat Heat Exchanger. If the air-cooled heat exchanger is installed in a rooftop location, it shall be installed in a curbed or diked area and drained to an approved location outside the building. Any oil heat exchanger installed on rooftops should be curbed or diked. Submitter Full Name: Mark Stender Organization: Surface Combustion, Inc. Submittal Date: Tue Jun 21 16:01:52 EDT 2016 Resolution: FR-94-NFPA Statement: This requirement is not limited to air cooled heat exchangers. NFPA 86 Public Inputs with Responses Report Page 130 of 230

131 31 of 222 1/26/2017 2:37 PM Public Input No. 131-NFPA [ Section No ] The quench tank shall be equipped with a low-level device that is arranged to sound an alarm to shall actuate a visual and audible alarm, prevent the start of quenching and that shuts off the heating medium in case of a low-level condition. Requires both visual and audible indication of the alarm (was just audible). Submitter Full Name: Mark Stender Organization: Surface Combustion, Inc. Submittal Date: Tue Jun 21 16:29:39 EDT 2016 Resolution: FR-95-NFPA Statement: The revision requires both visual and audible indication of the alarms. The revision places excess temperature limit interlock into protective paragraph where it belongs (versus "design"). The revision requires same temperature setting of the excess temperature limit interlock that is required for open quench tanks (i.e (E)). The revision states that quenching should be prohibited if a workload to be quenched will raise the temperature of the quench oil to an "unsafe" temperature. This also minimizes repetitious text: Temperature controller requirement and recirculating system interlock for any heating system (i.e. fuel-fired heaters or electrical heaters). NFPA 86 Public Inputs with Responses Report Page 131 of 230

132 32 of 222 1/26/2017 2:37 PM Public Input No. 132-NFPA [ New Section after ] An excess temperature limit interlock shall be provided on heated quench tanks. (A) It shall be independent of the quench tank s temperature controller. (B) It s setting shall be not less than 50F (28C ) below the flash point of the oil and a quench oil temperature greater than this setting shall: (1) Actuate a visual and audible alarm. (2) Shut down heating of the quench oil. 1. Places excess temperature limit interlock into protective paragraph where it belongs (versus "design"). 2. Requires same temperature setting of the excess temperature limit interlock that is required for open quench tanks (i.e (E)). Submitter Full Name: Mark Stender Organization: Surface Combustion, Inc. Submittal Date: Wed Jun 22 08:08:19 EDT 2016 Resolution: FR-95-NFPA Statement: The revision requires both visual and audible indication of the alarms. The revision places excess temperature limit interlock into protective paragraph where it belongs (versus "design"). The revision requires same temperature setting of the excess temperature limit interlock that is required for open quench tanks (i.e (E)). The revision states that quenching should be prohibited if a workload to be quenched will raise the temperature of the quench oil to an "unsafe" temperature. This also minimizes repetitious text: Temperature controller requirement and recirculating system interlock for any heating system (i.e. fuel-fired heaters or electrical heaters). NFPA 86 Public Inputs with Responses Report Page 132 of 230

133 33 of 222 1/26/2017 2:37 PM Public Input No. 133-NFPA [ New Section after ] Quenching shall not start if the work to be quenched will raise the quenchant temperature greater than 50F (28C ) below the flash point of the oil. Requires a safe starting temperature for quench oil. Quenching should be prohibited iff a workload to be quenched will raise the temperature of the quench oil to an "unsafe" temperature. Submitter Full Name: Mark Stender Organization: Surface Combustion, Inc. Submittal Date: Wed Jun 22 08:14:32 EDT 2016 Resolution: FR-95-NFPA Statement: The revision requires both visual and audible indication of the alarms. The revision places excess temperature limit interlock into protective paragraph where it belongs (versus "design"). The revision requires same temperature setting of the excess temperature limit interlock that is required for open quench tanks (i.e (E)). The revision states that quenching should be prohibited if a workload to be quenched will raise the temperature of the quench oil to an "unsafe" temperature. This also minimizes repetitious text: Temperature controller requirement and recirculating system interlock for any heating system (i.e. fuel-fired heaters or electrical heaters). NFPA 86 Public Inputs with Responses Report Page 133 of 230

134 34 of 222 1/26/2017 2:37 PM Public Input No. 134-NFPA [ Section No ] Quench Tank Heating Controls and Design Fuel-Fired Immersion Heaters. (A) Burner control Shall be equipped with a temperature controller that maintains the quench medium at the intended temperature Heating control systems shall be interlocked with the quench medium agitation system, the recirculating system, or both to prevent localized overheating of the quench medium. (B) The immersion Fuel-fired immersion tubes shall be installed so that the entire tube within the quench tank is covered with quench medium at all times. (C) A quench medium level control and excess temperature supervision shall be interlocked to shut off fuel-fired immersion heating when low quench level or overtemperature is detected. Electric Electric Immersion Heaters. (A) 4 Electric immersion heaters shall be of sheath-type construction (B) Heaters and shall be installed so that the hot sheath is fully submerged in the quench medium at all times. (C) The quench medium shall be supervised by both of the following: (1) Temperature controller that maintains the quench medium at the intended temperature (2) Quench medium level control and excess temperature supervision that are interlocked to shut off the electric immersion heating when low quench level or overtemperature is detected (D) The electrical heating system shall be interlocked with the quench medium agitation system to prevent localized overheating of the quench medium. NFPA 86 Public Inputs with Responses Report Page 134 of 230

135 35 of 222 1/26/2017 2:37 PM 1. Adds temperature controller requirement for fuel-fired heaters (same as electrical heater requirement). 2. Adds recirculating system language for electrically heated systems (same as fuel-fired heater requirement). 3. Minimizes repetitious text (e.g. The temperature controller for heating system requirement should be located in a single place). 4. Separate "public input" will propose moving protective feature requirements to the paragraph above ( ), this section deals with control and design requirements only. Submitter Full Name: Mark Stender Organization: Surface Combustion, Inc. Submittal Date: Wed Jun 22 08:29:41 EDT 2016 Resolution: FR-95-NFPA Statement: The revision requires both visual and audible indication of the alarms. The revision places excess temperature limit interlock into protective paragraph where it belongs (versus "design"). The revision requires same temperature setting of the excess temperature limit interlock that is required for open quench tanks (i.e (E)). The revision states that quenching should be prohibited if a workload to be quenched will raise the temperature of the quench oil to an "unsafe" temperature. This also minimizes repetitious text: Temperature controller requirement and recirculating system interlock for any heating system (i.e. fuel-fired heaters or electrical heaters). NFPA 86 Public Inputs with Responses Report Page 135 of 230

136 136 of 222 1/26/2017 2:37 PM Public Input No. 135-NFPA [ Section No ] Low Oil Level Sensor. A low oil level sensor shall be provided to sound an actuate a visual and audible alarm in the event that the oil level is below the prescribed limits where any of the following conditions exist: (1) The liquid surface area exceeds 10 ft 2 (1 m 2 ). (2) Incoming or outgoing work is handled by a conveyor. (3) The tank is equipped with a heating system. Requires both visual and audible indication of the alarm (was just audible). Submitter Full Name: Mark Stender Organization: Surface Combustion, Inc. Submittal Date: Wed Jun 22 08:52:18 EDT 2016 Resolution: FR-98-NFPA Statement: Without a visual alarm it may be difficult to ascertain which alarm is sounding at any time. NFPA 86 Public Inputs with Responses Report Page 136 of 230

137 37 of 222 1/26/2017 2:37 PM Public Input No. 24-NFPA [ Section No. A.1.1 ] A.1.1 The use of the term heated systems is intended to apply all guidance contained within this standard to the extent that it is applicable to the safe design, opera on, and maintenance of heat u liza on equipment as addressed within the provisions of the standard. Explosions and fires in fuel-fired and electric heat utilization equipment constitute a loss potential in life, property, and production. This standard is a compilation of guidelines, rules, and methods applicable to the safe operation of this type of equipment. Conditions and regulations that are not covered in this standard such as toxic vapors, hazardous materials, noise levels, heat stress, and local, state, and federal regulations (EPA and OSHA) should be considered in the design and operation of furnaces. Most failures can be traced to human error. The most significant failures include inadequate training of operators, lack of proper maintenance, and improper application of equipment. Users and designers must utilize engineering skill to bring together that proper combination of controls and training necessary for the safe operation of equipment. This standard classifies furnaces as follows: (1) Class A ovens and furnaces are heat utilization equipment operating at approximately atmospheric pressure wherein there is a potential explosion or fire hazard that could be occasioned by the presence of flammable volatiles or combustible materials processed or heated in the furnace. Such flammable volatiles or combustible materials can originate from any of the following: (2) Paints, powders, inks, and adhesives from finishing processes, such as dipped, coated, sprayed, and impregnated materials (3) Substrate material (4) Wood, paper, and plastic pallets, spacers, or packaging materials (5) Polymerization or other molecular rearrangements Potentially flammable materials, such as quench oil, water-borne finishes, cooling oil, and cooking oils, that present a hazard are ventilated according to Class A standards. (6) Class B ovens and furnaces are heat utilization equipment operating at approximately atmospheric pressure wherein no flammable volatiles or combustible materials are being heated. (7) Class C ovens and furnaces are those in which there is a potential hazard due to a flammable or other special atmosphere being used for treatment of material in process. This type of furnace can use any type of heating system and includes a special atmosphere supply system(s). Also included in the Class C classification are integral quench furnaces and molten salt bath furnaces. (8) Class D furnaces are vacuum furnaces that operate at temperatures that exceed ambient to over 5000 F (2760 C) and at pressures from vacuum to several atmospheres during heating using any type of heating system. These furnaces can include the use of special processing atmospheres. During gas quenching, these furnaces can operate at pressures from below atmospheric to over a gauge pressure of 100 psi (690 kpa). NFPA 86 Public Inputs with Responses Report Page 137 of 230

138 38 of 222 1/26/2017 2:37 PM Supporting revision for PI for clause 1.1 Related Public Inputs for This Document Related Input Public Input No. 23-NFPA [Section No. 1.1 [Excluding any Sub-Sections]] Relationship Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Sun May 01 18:49:45 EDT 2016 Resolution: FR-28-NFPA Statement: The term heated enclosures was too broad and could be interpreted to mean the building that the process equipment is located in. NFPA 86 Public Inputs with Responses Report Page 138 of 230

139 39 of 222 1/26/2017 2:37 PM Public Input No. 174-NFPA [ Section No. A ] A Explosion-Resistant (Radiant Tube). The radiant tube or the radiant tube heat recovery system can experience bulging and distortion but should not fail catastrophically. ELIMINATE THIS SECTION The current NFPA Standard for Ovens and Furnaces implies that metallic radiant tubes are safer than other high temperature materials of construction such as ceramics and composites. Alternative non-metallic materials currently in industrial radiant tube service include mullites, sialons, silicon nitrides, siliconized silicon carbides and silicon / silicon carbide composites. The standard excludes and/or favorably treats metallic radiant tubes in terms of relaxed requirements for: Pre-ignition Purging Sections , A , & Safety Shut-Off Valves Section Flame Supervision Section This special treatment for metallic radiant tubes ignores several decades of industry experience where deflagration / explosion has not proved to be a significant risk factor for non-metallic materials, or at minimum the incident losses are no different than metallic tubes used in equivalent service. In actual operation most metallic radiant tubes used in carburizing, carbonitriding and higher temperature processing periodically experience open-crack, thru-wall hole and/or perforation failures due to material creep distortion, carburization corrosion/embrittlement and/or weld stress fracture. Any risks posed by open metallic tube failures are no different than those of non-metallic tubes, regardless of whether combustible gases flow into the furnace chamber or, vice versa, into the radiant tube. For the processes cited above metallic failures generally occur every three to five years (sometimes sooner) mandating radiant tube replacement to maintain the integrity of the process atmosphere and quality of production. While ceramic and composite tubes available to the industrial furnace users do not experience the progressive failure modes of metallic tubes, they are more susceptible to mechanical impact and less tolerable of thermo-mechanical stress. Failure of non-metallic radiant tubes has the same effect on the furnace atmosphere and production quality, also mandating their replacement. \When radiant metallic tube applications are optimally designed (so that the surface temperatures are uniform and not excessive for the specific alloy employed), they are just as likely, if not more likely, to fail catastrophically compared with ceramic and composite tubes under the same service conditions in carburizing, carbonitriding and higher temperature atmospheres. Furthermore, consideration of radiant tube durability should not be based on new material properties, but rather on radiant tubes that are at or near the end of their useful service lives. It is at this point that a tube failure-related incident is most likely to occur. To be logically consistent both metallic and non-metallic radiant tubes used at elevated temperatures (e.g. above 1550 F) must be treated the same. For example, if flame supervision is required for non-metallic radiant tubes, then it should be required for metallic radiant tubes as well. An alternative NFPA 86 Public Inputs with Responses Report Page 139 of 230

140 40 of 222 1/26/2017 2:37 PM approach might be to require that metallic tubes are removed from use before they are projected to fail (based on a documented analysis of service life in the specific application). In practice it is rare that adequate information is available to base such projections with certainty, therefore we do not envision that this risk avoidance tactic can be reliably adopted by industry. On the other hand, if metallic radiant tubes are proven to operate in service with little or no deterioration at lower temperatures (e.g. below 1550 F), a specific reliability analysis might support the conclusion that catastrophic failure is improbable in that application. The testing prescribed in Section A to validate the explosion-resistance of non-metallic materials ignores the failure modes of metallic tubes in carburizing, carbonitriding and higher temperature processing. Normative service failures (open-cracks, thru-wall holes and/or perforations) result in metallic radiant tubes incapable of supporting any pressurization whatsoever. Furthermore, the exclusion of metallic materials from these validity protocols per Section ignores the design pressure ratings of radiant tubes (as a function of wall thickness, alloy strength and weld integrity). Also longer-term metallic tube wall deterioration due to spalling and embrittlement (which inevitably occurs in high temperature service) is not considered. Related Public Inputs for This Document Related Input Public Input No. 169-NFPA [Section No ] Public Input No. 170-NFPA [Sections , ] Public Input No. 171-NFPA [Sections , ] Public Input No. 172-NFPA [Section No ] Public Input No. 173-NFPA [Section No ] Public Input No. 175-NFPA [Section No. A ] Public Input No. 176-NFPA [Section No. A ] Relationship Submitter Full Name: Curt Colopy Organization: INEX Incorporated Submittal Date: Wed Jun 29 16:22:32 EDT 2016 Resolution: The committee has addressed these issues throughout the text and it is unnecessary to delete the definition at this time. NFPA 86 Public Inputs with Responses Report Page 140 of 230

141 41 of 222 1/26/2017 2:37 PM Public Input No. 163-NFPA [ New Section after A ] TITLE OF NEW CONTENT A Reference NFPA 5000 Building Construction & safety Code and NFPA 101 Life safety Code for information on clearance to combustibles Annex directs the reader to relevant NFPA documents regarding clearance to combustibles. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Tue Jun 28 15:00:03 EDT 2016 Resolution: FR-111-NFPA Statement: Annex directs the reader to relevant NFPA documents regarding clearance to combustibles. NFPA 86 Public Inputs with Responses Report Page 141 of 230

142 42 of 222 1/26/2017 2:37 PM Public Input No. 104-NFPA [ Section No. A.5.3.1(6) ] A.5.3.1(6) For reliable operation, the LFL detection sensing location(s) should be located in the region of the combustion chamber most likely to accumulate flammable gases as a result of a gas leak or incomplete combustion. This should be determined by a qualified engineer as numerous factors need to be taken into account (properties of gases, source, expected airflows, etc.). In some cases, it may be necessary to provide multiple ports in a single combustion chamber to reliably monitor potential flammable gas accumulations. In addition, the detection sensing system should be selected to detect all potential explosive gases that could be developed as a result of the process and burner systems. This may require multiple sensing systems as LFL calibration for different gases may not be the same. Alternatively, the calibration should be such that no potential flammable gaas could exceed a concentration of 10% LFL without tripping the sensor (with the side effect that some gases may trip the sensor at much lower LFL percentage concentrations). A.5.3.1(7) Because the combustion air has only one path from the combustion blower through the supervised powered exhaust, there is no buildup of products of combustion in the heat exchanger. The minimum exhaust rate for the heat exchanger should be determined using , which states 183 scfm (5.18 standard m 3 /min) per 1,000,000 Btu/hr (293.1 kw) burner rating. Refer to Figure A.5.3.1(6 7). Figure A.5.3.1(6 7 ) Example of a Non-Recirculating, Indirect-Fired Oven. Annex materail related to public input for new (6). Submitter Full Name: Organization: Affilliation: Ted Jablkowski Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Group NFPA 86 Public Inputs with Responses Report Page 142 of 230

143 43 of 222 1/26/2017 2:37 PM Submittal Date: Fri Jun 10 13:51:01 EDT 2016 Resolution: FR-8-NFPA Statement: For Item 1: Different construction shells are available for this application and should be allowed by the standard if determined to be equivalent. For Item 2: The wrong section is referenced. The correct section to reference is 11.7 "Low-Oxygen Atmosphere Class A Ovens with Solvent Recovery". For Oven/Furnace "5.3 Explosion Relief", some users use aspirating LFL detection in the combustion chamber of oven heater boxes. The main reason for excluding direct fired ovens from the "exception language" in 5.3.1(6) is that direct fired ovens can introduce an explosive atmosphere into the work chamber due to incomplete combustion and gas leaks. With LFL detection implemented to trip at a level well below 25% LFL and interlocked to interrupt start-up and running permissives. Annex materiel related to new (6) changes this item to 5.3.1(7). NFPA 86 Public Inputs with Responses Report Page 143 of 230

144 44 of 222 1/26/2017 2:37 PM Public Input No. 52-NFPA [ Section No. A ] A See NFPA 54, National Fuel Gas Code, for exception to vent requirements. Vent limiters are used to limit the escape of gas into the ambient atmosphere if a vented device (e.g., regulator, zero governor, pressure switch) requiring access to the atmosphere for operation has an internal component failure. When a vent limiter is used, there might not be a need to vent the device to an approved location. Following are some general guidelines and principles on the use of vented devices incorporating vent limiters: (1) The listing requirements for vent limiters are covered in ANSI Z21.18/CSA 6.3, Standard for Gas Appliance Pressure Regulators, for regulators and in ANSI/UL 353, Standard for Limit Controls, for pressure switches and limit controls. ANSI Z21.18/CSA 6.3 requires a maximum allowable leakage rate of 2.5 ft 3 /hr (0.071 m 3 /hr) for natural gas and 1.0 ft 3 /hr (0.028 m 3 /hr) for LP-Gas at the device's maximum rated pressure. ANSI/UL 353 allows 1.0 ft 3 /hr (0.028 m 3 /hr) for natural gas and 1.53 ft 3 /hr (0.043 m 3 /hr) for LP-Gas at the device's maximum rated pressure. Since a vent limiter may be rated less than the device.itself. or it may de-rate the device to a lower pressure rating, a combination listed device vent limiter should be used. (2) Where a vent limiter is used, there should be adequate airflow through the room or enclosure in which the equipment is installed. In reality, conditions can be less ideal, and care should be exercised for the following reasons: (3) The relative density of the gas influences its ability to disperse in air. The higher the relative density, the more difficult it is for the gas to disperse (e.g., propane disperses more slowly than natural gas). (4) Airflow patterns through a room or enclosure, especially in the vicinity of the gas leak, affect the ability of the air to dilute that gas. The greater the local air movement, the greater the ease with which the gas is able to disperse. (5) The vent limiter may not prevent the formation of a localized flammable air gas concentration for the preceding reasons. (6) Table A shows various gases and their equivalent allowable leakage rates through a vent limiting device as per ANSI Z21.18/CSA 6.3, Standard for Gas Appliance Pressure Regulator. The leakage rates are based on the maximum rated pressure rating for the device. Table A Allowable Leakage Rates of Various Gases Gas Type s.g. (based on air = 1.0) Leakage Rate (ft 3 /hr) Natural gas Propane Butane NFPA 86 Public Inputs with Responses Report Page 144 of 230

145 45 of 222 1/26/2017 2:37 PM rated pressure is now defined and is the proper usage here. Submitter Full Name: Kevin Carlisle Organization: Industrial Heating Equipment Association Affilliation: Industrial Heating Equipment Association Submittal Date: Fri Jun 03 14:58:05 EDT 2016 Resolution: The CI-5 task group will address this issue for the Second Draft Meeting. NFPA 86 Public Inputs with Responses Report Page 145 of 230

146 46 of 222 1/26/2017 2:37 PM Public Input No. 89-NFPA [ Section No. A ] A ( 3 ) Upon upstream pressure regulation failure, a full-capacity pressure relief valve (versus token relief valves) will limit the downstream pressure. Token relief valves only provide minimum pressure relief in cases where ambient temperatures increase the pressure inside the gas piping, which can occur during shutdown periods, or relieves small increases of pressure due to high lockup pressures that occur during a shutdown. Renumbered A (3) adds information explaining the differences between full-capacity relief valves and token relief valves. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Thu Jun 09 16:47:34 EDT 2016 Resolution: FR-6-NFPA Statement: This section was misnumbered in a previous edition. NFPA 86 Public Inputs with Responses Report Page 146 of 230

147 47 of 222 1/26/2017 2:37 PM Public Input No. 86-NFPA [ Section No. A ] A In the design, fabrication, and utilization of mixture piping, it should be recognized that the air fuel gas mixture might be in the flammable range. Even with mixers that operate at or below 10"wc (2.49 kpa), there may be certain site conditions where it is advisable to install firechecks and safety blowouts. Consideration should be given to the volume, length, and location of the premix pipe. The user should consider the possibility of a backfire and subsequent rise in pressure and temperature in the mixture piping and connected systems. Some guidance for pressure calculations may be obtained from NFPA 68 Standard on Explosion Protection by Deflagration Venting. Revised annex adds additional information for the user on the use of firechecks and safety blowouts. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Thu Jun 09 16:39:51 EDT 2016 Resolution: FR-44-NFPA Statement: Revised annex adds additional information for the user on the use of firechecks and safety blowouts. NFPA 86 Public Inputs with Responses Report Page 147 of 230

148 48 of 222 1/26/2017 2:37 PM Public Input No. 87-NFPA [ Section No. A (E) ] A (E) Acceptable safety blowouts are available from some manufacturers of air fuel mixing machines. They incorporate all the following components and design features: (1) Flame arrester (2) Blowout disk (3) Provision for automatically shutting off the supply of air gas mixture to the burners in the event of a flashback passing through an automatic fire check Proposed safety blowout definition and annex eliminates the need for this annex. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Thu Jun 09 16:43:49 EDT 2016 Resolution: FR-70-NFPA Statement: Adds back the requirement only for pressure >10"wc in combination with the removal of it from definition. The safety blowout definition and annex eliminates the need for this annex. NFPA 86 Public Inputs with Responses Report Page 148 of 230

149 49 of 222 1/26/2017 2:37 PM Public Input No. 175-NFPA [ Section No. A ] A Testing of radiant tubes should include subjecting them to thermal cycling typical for the furnace application and then verifying their ability to withstand overpressure developed by a fuel air explosion. Overpressure testing can be done in one of two ways: (1) Statically pressurizing the tube until it fails, then comparing this pressure to the maximum pressure (from literature) that can be developed in a contained deflagration of an optimum fuel air mixture. (2) Partially blocking the open end of the tube to simulate a heat exchanger, then filling the tube with a well-mixed stoichiometric fuel air mixture (10 volumes of air to 1 volume of fuel for natural gas). The mixture is ignited at the closed end of the tube, and the pressure that develops is measured and compared to the maximum pressure (from literature) that can be developed in a contained deflagration of an optimum fuel air mixture. ELIMINATE THIS SECTION The current NFPA Standard for Ovens and Furnaces implies that metallic radiant tubes are safer than other high temperature materials of construction such as ceramics and composites. Alternative non-metallic materials currently in industrial radiant tube service include mullites, sialons, silicon nitrides, siliconized silicon carbides and silicon / silicon carbide composites. The standard excludes and/or favorably treats metallic radiant tubes in terms of relaxed requirements for: Pre-ignition Purging Sections , A , & Safety Shut-Off Valves Section Flame Supervision Section This special treatment for metallic radiant tubes ignores several decades of industry experience where deflagration / explosion has not proved to be a significant risk factor for non-metallic materials, or at minimum the incident losses are no different than metallic tubes used in equivalent service. In actual operation most metallic radiant tubes used in carburizing, carbonitriding and higher temperature processing periodically experience open-crack, thru-wall hole and/or perforation failures due to material creep distortion, carburization corrosion/embrittlement and/or weld stress fracture. Any risks posed by open metallic tube failures are no different than those of non-metallic tubes, regardless of whether combustible gases flow into the furnace chamber or, vice versa, into the radiant tube. For the processes cited above metallic failures generally occur every three to five years (sometimes sooner) mandating radiant tube replacement to maintain the integrity of the process atmosphere and quality of production. While ceramic and composite tubes available to the industrial furnace users do not experience the progressive failure modes of metallic tubes, they are more susceptible to mechanical impact and less tolerable of thermo-mechanical stress. Failure of non-metallic radiant tubes has the same effect on the furnace atmosphere and production quality, also mandating their NFPA 86 Public Inputs with Responses Report Page 149 of 230

150 50 of 222 1/26/2017 2:37 PM replacement. When radiant metallic tube applications are optimally designed (so that the surface temperatures are uniform and not excessive for the specific alloy employed), they are just as likely, if not more likely, to fail catastrophically compared with ceramic and composite tubes under the same service conditions in carburizing, carbonitriding and higher temperature atmospheres. Furthermore, consideration of radiant tube durability should not be based on new material properties, but rather on radiant tubes that are at or near the end of their useful service lives. It is at this point that a tube failure-related incident is most likely to occur. To be logically consistent both metallic and non-metallic radiant tubes used at elevated temperatures (e.g. above 1550 F) must be treated the same. For example, if flame supervision is required for non-metallic radiant tubes, then it should be required for metallic radiant tubes as well. An alternative approach might be to require that metallic tubes are removed from use before they are projected to fail (based on a documented analysis of service life in the specific application). In practice it is rare that adequate information is available to base such projections with certainty, therefore we do not envision that this risk avoidance tactic can be reliably adopted by industry. On the other hand, if metallic radiant tubes are proven to operate in service with little or no deterioration at lower temperatures (e.g. below 1550 F), a specific reliability analysis might support the conclusion that catastrophic failure is improbable in that application. The testing prescribed in Section A to validate the explosion-resistance of non-metallic materials ignores the failure modes of metallic tubes in carburizing, carbonitriding and higher temperature processing. Normative service failures (open-cracks, thru-wall holes and/or perforations) result in metallic radiant tubes incapable of supporting any pressurization whatsoever. Furthermore, the exclusion of metallic materials from these validity protocols per Section ignores the design pressure ratings of radiant tubes (as a function of wall thickness, alloy strength and weld integrity). Also longer-term metallic tube wall deterioration due to spalling and embrittlement (which inevitably occurs in high temperature service) is not considered. Related Public Inputs for This Document Related Input Public Input No. 174-NFPA [Section No. A ] Public Input No. 176-NFPA [Section No. A ] Public Input No. 169-NFPA [Section No ] Public Input No. 170-NFPA [Sections , ] Public Input No. 171-NFPA [Sections , ] Public Input No. 172-NFPA [Section No ] Public Input No. 173-NFPA [Section No ] Relationship Submitter Full Name: Curt Colopy Organization: INEX Incorporated NFPA 86 Public Inputs with Responses Report Page 150 of 230

151 51 of 222 1/26/2017 2:37 PM Submittal Date: Wed Jun 29 16:25:59 EDT 2016 Resolution: Since the original material was not deleted, as requested by submitter, the explanatory material should remain. NFPA 86 Public Inputs with Responses Report Page 151 of 230

152 52 of 222 1/26/2017 2:37 PM Public Input No. 40-NFPA [ Section No. A ] A Typically, inspection and leak tests of furnace piping that conveys flammable liquids or flammable gases are performed at a pressure not less than their normal operating pressure using the test method detailed in NFPA 54. What means inspected and how much leakage is allowed. NPFA 54 has a method to leak test gas piping. I suggest that this method be referenced. Submitter Full Name: Kevin Carlisle Organization: Karl Dungs Inc Submittal Date: Fri Jun 03 12:56:33 EDT 2016 Resolution: FR-14-NFPA Statement: NPFA 54 has a method for leak tightness testing that is suitable for leak testing a gas train. NFPA 86 Public Inputs with Responses Report Page 152 of 230

153 53 of 222 1/26/2017 2:37 PM Public Input No. 141-NFPA [ New Section after A ] A The following inspections should be performed: (1) Ensure that the pressure connection is correct. (2) Check for entrapped gas in liquid lines, or entrapped liquid in gas lines. (3) Check for sediment, or other blockage, in the impulse pipe to the transmitter. (4) Check for leaks. Annex material for new to list the inspections that should be performed. Related Public Inputs for This Document Related Input Public Input No. 140-NFPA [New Section after 7.4.4] Public Input No. 142-NFPA [New Section after ] Relationship Supporting annex material Submitter Full Name: Geoffrey Raifsnider Organization: Global Finishing Solutions Submittal Date: Tue Jun 28 08:17:51 EDT 2016 Resolution: FR-47-NFPA Statement: Changes the suggestion to inspect the impulse line found in current annex material to a requirement to test the functionality of the impulse line. The change also establishes a time frequency that is consistent with the current frequency required for the safety device it is connected to. Annex material for new to list the inspections that should be performed. NFPA 86 Public Inputs with Responses Report Page 153 of 230

154 54 of 222 1/26/2017 2:37 PM Public Input No. 167-NFPA [ New Section after A ] TITLE OF NEW CONTENT A The following inspections should be performed: (1) Ensure that the pressure connection is correct. (2) Check for entrapped gas in liquid lines, and entrapped liquid in gas lines. (3) Check for sediment, or other blockage, in the impulse pipe to the transmitter. (4) Check for leaks. Changes the suggestion to inspect the impulse line to a requirement to test the functionality of the impulse line and establishes a time frequency that is consistent with the current frequency required for the safety device it is connected to. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Tue Jun 28 15:10:04 EDT 2016 Resolution: FR-47-NFPA Statement: Changes the suggestion to inspect the impulse line found in current annex material to a requirement to test the functionality of the impulse line. The change also establishes a time frequency that is consistent with the current frequency required for the safety device it is connected to. Annex material for new to list the inspections that should be performed. NFPA 86 Public Inputs with Responses Report Page 154 of 230

155 55 of 222 1/26/2017 2:37 PM Public Input No. 10-NFPA [ Section No. A ] NFPA 86 Public Inputs with Responses Report Page 155 of 230

156 56 of 222 1/26/2017 2:37 PM A NFPA 86 Public Inputs with Responses Report Page 156 of 230

157 157 of 222 1/26/2017 2:37 PM The following is an example of a leak test procedure for safety shutoff valves on direct gas-fired ovens with a self-piloted burner and intermittent pilot. With the oven burner(s) shut off, the main shutoff valve open, and the manual shutoff valve closed, the procedures are as follows: (1) Place the tube in test connection 1, immersed just below the surface of a container of water. (2) Open the test connection valve. If bubbles appear, the valve is leaking, and the manufacturer's instructions should be referenced for corrective action. Energize the auxiliary power supply to safety shutoff valve No. 1 and open that valve. (3) Place the tube in test connection 2, immersed just below the surface of a container of water. (4) Open the test connection valve. If bubbles appear, the valve is leaking. Reference the manufacturer's instructions for corrective action. This procedure is predicated on the piping diagram shown in Figure A.7.4.9(a) and the wiring diagram shown in Figure A.7.4.9(b). Figure A.7.4.9(a) Example of a Gas Piping Diagram for Leak Test. Figure A.7.4.9(b) Example of a Wiring Diagram for Leak Test. It is recognized that safety shutoff valves are not entirely leak free. Because valve seats can deteriorate over time, they require periodic leak testing. Many variables are associated with the valve seat leak testing process, including gas piping and valve size, gas pressure and specific gravity, size of the burner chamber, length of downtime, and the many leakage rates published by recognized laboratories and other organizations. Leakage rates are published for new valves and vary by manufacturer and the individual listings to which the manufacturer subscribes. It is not expected that valves in service can be held to these published leakage rates, but rather that the leakage rates are comparable over a series of tests over time. Any significant deviation from the comparable leakage rates over time will indicate to the user that successive leakage tests can indicate unsafe conditions. These conditions should then be addressed by the user in a timely manner. The location of the manual shutoff valve downstream of the safety shutoff valve affects the volume downstream of the safety shutoff valve and is an important factor in determining when to start counting bubbles during a safety shutoff valve seat leakage test. The greater the volume downstream of the safety shutoff valve, the longer it will take to fully charge the trapped volume in the pipe between the safety shutoff valve and the manual shutoff valve. This trapped volume needs to be fully charged before starting the leak test. NFPA 86 Public Inputs with Responses Report Page 157 of 230

158 58 of 222 1/26/2017 2:37 PM Care should be exercised when performing the safety shutoff valve seat leakage test, because flammable gases will be released into the local environment at some indeterminate pressure. Particular attention should be paid to lubricated plug valves used as manual shutoff valves to ensure that they have been properly serviced prior to the valve seat leakage test. The publications listed in Annex M include examples, although not all inclusive, of acceptable leakage rate methodologies that the user can employ. Figure A.7.4.9(a) through Figure A.7.4.9(c) show examples of gas piping and wiring diagrams for leak testing. Example. The following example is predicated on the piping diagram shown in Figure A.7.4.9(a) and the wiring diagram shown in Figure A.7.4.9(b). With the oven burner(s) shut off, the equipment isolation valve open, and the manual shutoff valve located downstream of the second safety shutoff valve closed, the procedures are as follows: (1) Connect the tube to leak test valve No. 1. (2) Bleed trapped gas by opening leak test valve No. 1. (3) Immerse the tube in water as shown in Figure A.7.4.9(c). If bubbles appear, the valve is leaking. Reference the manufacturer's instructions for corrective action. Examples of acceptable leakage rates are given in Table A.7.4.9(a). (4) Apply auxiliary power to safety shutoff valve No. 1. Close leak test valve No. 1. Connect the tube to leak test valve No. 2 and immerse it in water as shown in Figure A.7.4.9(c). (5) Open leak test valve No. 2. If bubbles appear, the valve is leaking. Reference the manufacturer's instructions for corrective action. Examples of acceptable leakage rates are given in Table A.7.4.9(a). Figure A.7.4.9(c) Leak Test for a Safety Shutoff Valve. Table A.7.4.9(a) Acceptable Maximum Acceptable Leakage Rates for New Production Valves NPT DN UL 429, ANSI Z21.21/CSA 6.5 FM 7400 Nominal Nominal Size Size ft 3 ml/hr ml/min Bubbles/ /hr (in.) (mm) cc/hr cc/min ft min ml/hr ml/min Bubbles/ /hr cc/hr cc/min min ft NFPA 86 Public Inputs with Responses Report Page 158 of 230

159 59 of 222 1/26/2017 2:37 PM NPT Nominal Size (in.) DN Nominal Size (mm) UL 429, ANSI Z21.21/CSA 6.5 FM 7400 ft 3 /hr ml/hr cc/hr ml/min cc/min Bubbles/ min ft 3 /hr ml/hr cc/hr ml/min cc/min Bubbles/ , , min ft 3 [A.7.4.9] where: L = leakage rate (cm 3 /hr) p = absolute value of initial test pressure (mbar) final test pressure (mbar) Vtest = total volume of the test (cm 3 ) Patm = atmospheric pressure (atmospheres) Ttest = test time (seconds) Conversion factors 1 in. water col. = 2.44 mbar 1 psi = 27.7 in. water col. 1 atmosphere = 14.7 psi This test method can be done by tapping into the following ports and performing the test method in Table A.7.4.9(b). Table A.7.4.9(b) Test Methods. Test Port Location A test port between both safety shutoff valves A test port downstream of both safety shutoff valves A test port upstream of both valves Test Method Pressure decay on V 2 Pressure rise on V 1 Pressure rise on V 1 and V 2 (requires manual shutoff valve downstream both safety shutoff valves and that it be leak tightness tested). Pressure decay on V 1 and V 2 (requires a leak tightness test on the upstream, manual isolation valve) Current title does not clarify the proper usage of the data within the table. Submitter Full Name: FRANKLIN SWITZER NFPA 86 Public Inputs with Responses Report Page 159 of 230

160 60 of 222 1/26/2017 2:37 PM Organization: S AFE INC Submittal Date: Sun Aug 23 20:58:06 EDT 2015 Resolution: FR-16-NFPA Statement: Title of table was changed to reflect original material. NFPA 86 Public Inputs with Responses Report Page 160 of 230

161 61 of 222 1/26/2017 2:37 PM Public Input No. 66-NFPA [ Section No. A ] NFPA 86 Public Inputs with Responses Report Page 161 of 230

162 62 of 222 1/26/2017 2:37 PM A NFPA 86 Public Inputs with Responses Report Page 162 of 230

163 163 of 222 1/26/2017 2:37 PM The following is an example of a leak test procedure for safety shutoff valves on direct gas-fired ovens with a self-piloted burner and intermittent pilot. With the oven burner(s) shut off, the main shutoff valve open, and the manual shutoff valve closed, the procedures are as follows: (1) Place the tube in test connection 1, immersed just below the surface of a container of water. (2) Open the test connection valve. If bubbles appear, the valve is leaking, and the manufacturer's instructions should be referenced for corrective action. Energize the auxiliary power supply to safety shutoff valve No. 1 and open that valve. (3) Place the tube in test connection 2, immersed just below the surface of a container of water. (4) Open the test connection valve. If bubbles appear, the valve is leaking. Reference the manufacturer's instructions for corrective action. This procedure is predicated on the piping diagram shown in Figure A.7.4.9(a) and the wiring diagram shown in Figure A.7.4.9(b). Figure A.7.4.9(a) Example of a Gas Piping Diagram for Leak Test. Figure A.7.4.9(b) Example of a Wiring Diagram for Leak Test. It is recognized that safety shutoff valves are not entirely leak free. Because valve seats can deteriorate over time, they require periodic leak testing. Many variables are associated with the valve seat leak testing process, including gas piping and valve size, gas pressure and specific gravity, size of the burner chamber, length of downtime, and the many leakage rates published by recognized laboratories and other organizations. Leakage rates are published for new valves and vary by manufacturer and the individual listings to which the manufacturer subscribes. It is not expected that valves in service can be held to these published leakage rates, but rather that the leakage rates are comparable over a series of tests over time. Any significant deviation from the comparable leakage rates over time will indicate to the user that successive leakage tests can indicate unsafe conditions. These conditions should then be addressed by the user in a timely manner. The location of the manual shutoff valve downstream of the safety shutoff valve affects the volume downstream of the safety shutoff valve and is an important factor in determining when to start counting bubbles during a safety shutoff valve seat leakage test. The greater the volume downstream of the safety shutoff valve, the longer it will take to fully charge the trapped volume in the pipe between the safety shutoff valve and the manual shutoff valve. This trapped volume needs to be fully charged before starting the leak test. NFPA 86 Public Inputs with Responses Report Page 163 of 230

164 64 of 222 1/26/2017 2:37 PM Care should be exercised when performing the safety shutoff valve seat leakage test, because flammable gases will be released into the local environment at some indeterminate pressure. Particular attention should be paid to lubricated plug valves used as manual shutoff valves to ensure that they have been properly serviced prior to the valve seat leakage test. The publications listed in Annex M include examples, although not all inclusive, of acceptable leakage rate methodologies that the user can employ. Figure A.7.4.9(a) through Figure A.7.4.9(c) show examples of gas piping and wiring diagrams for leak testing. Example. The following example is predicated on the piping diagram shown in Figure A.7.4.9(a) and the wiring diagram shown in Figure A.7.4.9(b). With the oven burner(s) shut off, the equipment isolation valve open, and the manual shutoff valve located downstream of the second safety shutoff valve closed, the procedures are as follows: (1) Connect the tube to leak test valve No. 1. (2) Bleed trapped gas by opening leak test valve No. 1. (3) Immerse the tube in water as shown in Figure A.7.4.9(c). If bubbles appear, the valve is leaking. Reference the manufacturer's instructions for corrective action. Examples of acceptable leakage rates are given in Table A.7.4.9(a). (4) Apply auxiliary power to safety shutoff valve No. 1. Close leak test valve No. 1. Connect the tube to leak test valve No. 2 and immerse it in water as shown in Figure A.7.4.9(c). (5) Open leak test valve No. 2. If bubbles appear, the valve is leaking. Reference the manufacturer's instructions for corrective action. Examples of acceptable leakage rates are given in Table A.7.4.9(a). Figure A.7.4.9(c) Leak Test for a Safety Shutoff Valve. Table A.7.4.9(a) Acceptable Leakage Rates NPT Nominal Size (in.) DN Nominal Size (mm) UL 429, ANSI Z21.21/CSA 6.5 FM 7400 ft 3 /hr ml/hr cc/hr ml/min cc/min Bubbles/ min ft 3 /hr ml/hr cc/hr ml/min cc/min Bubbles/ min ft 3 /hr NFPA 86 Public Inputs with Responses Report Page 164 of 230

165 65 of 222 1/26/2017 2:37 PM NPT Nominal Size (in.) DN Nominal Size (mm) UL 429, ANSI Z21.21/CSA 6.5 FM 7400 ft 3 /hr ml/hr cc/hr ml/min cc/min Bubbles/ min ft 3 /hr ml/hr cc/hr ml/min cc/min Bubbles/ min ft 3 /hr , , [A.7.4.9] where: L = leakage rate (cm 3 /hr) p = absolute value of initial test pressure (mbar) final test pressure (mbar) Vtest = total volume of the test (cm 3 ) Patm = atmospheric pressure (atmospheres) Ttest = test time (seconds) Conversion factors 1 in. water col. = 2.44 mbar 1 psi = 27.7 in. water col. 1 atmosphere = 14.7 psi This test method can be done by tapping into the following ports and performing the test method in Table A.7.4.9(b). Table A.7.4.9(b) Test Methods. Test Port Location A test port between both safety shutoff valves A test port downstream of both safety shutoff valves A test port upstream of both valves Pressure decay on V2 Test Method Pressure rise on V1 Pressure rise on V1 and V2 (requires manual shutoff valve downstream both safety shutoff valves and that it be leak tightness tested). Pressure decay on V1 and V2 (requires a leak tightness test on the upstream, manual isolation valve) Other methods for leak testing Safety Shutoff Valves (1) Another means to leak test Safety Shutoff Valves using bubble tightness testing without energizing any of the safety shutoff valves is to have a leak test valve #1 upstream of V1, a leak test valve #2 between V1 and V2, and leak test valve #3 downstream V2. Then proceed as follows: Leak Testing of V1 Prep NFPA 86 Public Inputs with Responses Report Page 165 of 230

166 66 of 222 1/26/2017 2:37 PM Ready a tube that connects to leak test valve No. 2 (see figure FIGURE A.7.4.9(c). for tube dimensions) Ready a glass of water as shown in Figure A.7.4.9(c). Test method O pen leak test valve No 2, and bleed any trapped gas. Immerse the tube on leak test valve No. 2 into water as shown in Figure A.7.4.9(c). If bubbles appear, the valve is leaking. Reference the manufacturer s instructions for corrective action. Examples of acceptable leakage rates are given in Table A.7.4.9(a). Leak Testing of V2 Prep Ready a tube of sufficient length that will connect leak test valve #1 to leak test valve #2 without crimping. Ready another tube that connects to leak test valve No. 3 (see figure FIGURE A.7.4.9(c) for tube dimensions) Ready a glass of water as shown in Figure A.7.4.9(c). Test method Ready a tube of sufficient length that will connect leak test valve #1 to leak test valve #2 without crimping. Ready another tube that connects to leak test valve No. 3 (see figure FIGURE A.7.4.9(c) for tube dimensions) O pen leak test valve No 2, and bleed any trapped gas. Close manual shutoff valve downstream V2. Connect tube to leak test valve No. 2. Open leak test valve No. 1, and immediately connect the tube on leak test valve No. 2 to leak test valve No. 1. This will change the volume between V1 and V2 with gas pressure. Immerse the tube on leak test valve No. 3 into water as shown in Figure A.7.4.9(c). If bubbles appear, the valve is leaking. Reference the manufacturer s instructions for corrective action. Examples of acceptable leakage rates are given in Table A.7.4.9(a). (1) A combination of pressure decay and bubble tightness testing described above can be done to leak test safety shutoff valves. Depending on the fuel gas train arraignment, leak test valves and pressure port available, and availability of manual valves on the fuel gas train, a pressure decay test on valve #2 followed by a bubble tightness testing on valve #1 might be desirable. Proposal is to add another means to leak test valves in the field Submitter Full Name: Kevin Carlisle Organization: Industrial Heating Equipment Association NFPA 86 Public Inputs with Responses Report Page 166 of 230

167 67 of 222 1/26/2017 2:37 PM Affilliation: Industrial Heating Equipment Association Submittal Date: Fri Jun 03 15:41:14 EDT 2016 Resolution: FR-16-NFPA Statement: Title of table was changed to reflect original material. NFPA 86 Public Inputs with Responses Report Page 167 of 230

168 68 of 222 1/26/2017 2:37 PM Public Input No. 67-NFPA [ Section No. A ] A Consideration should be given to the effects of radiant heat on the safety devices. Radiant heat can cause safety devices to be exposed to temperatures greater than their ratings. Adequate insulation, heat shields, ventilation, or other measures should be used in cases where radiant heat causes safety devices to reach temperatures above their ratings. A safety device should be replaced if exposed to a conditions (e.g. pressure, temp, corrosive gases, etc) outside of manufacturer s specifications. This annex draws attention to protecting the safety devices from conditions outside their ratings. However, we should also recommend that actions to be taken if by change devices are exposed to conditions outside their ratings. E.g. too high of pressure cannot also permanently damage safety devices, and if this occurs, the devices might not properly operate. Submitter Full Name: Kevin Carlisle Organization: Industrial Heating Equipment Association Affilliation: Industrial Heating Equipment Association Submittal Date: Fri Jun 03 15:44:04 EDT 2016 Resolution: FR-72-NFPA Statement: The committee recommend that actions to be taken if devices are exposed to conditions outside their ratings. E.g. too high of pressure can also permanently damage safety devices, and if this occurs, the devices may not properly operate. NFPA 86 Public Inputs with Responses Report Page 168 of 230

169 69 of 222 1/26/2017 2:37 PM Public Input No. 102-NFPA [ New Section after A ] TITLE OF NEW CONTENT A This clause permits the mushroom-style switch to act as a hard-wired fuel stop by directly de-energizing the safety shut-off valves or it can be used as in input to a safety PLC when more complicated stop sequences are required. If the safety PLC is used to sequence the stop then dual contacts are required to dual safety inputs per the manufacturer s safety manual to ensure control reliability. If the single mushroom-style fuel stop eliminates all hazards associated with the furnace/machine then the mushroom style button can display the yellow ring at its base and it can be labeled an Emergency Stop per NFPA 79. A Some furnaces include complex control of motion, hydraulics, and special atmospheres that can t be immediately depowered without creating additional hazards when the fuel stop button is depressed. For that reason, the fuel stop button can be wired to a safety PLC so that a shutdown sequence is initiated to bring the furnace and ancillary equipment to a safe state. This controlled stop is consistent with a Category 1 or 2 stop function defined in NFPA 79. It is the designer s responsibility to analyze each of the ancillary function s hazards against the appropriate standards to ensure the entire furnace/machine is brought to a safe state when commanded to do so. Some furnaces include complex control of motion, hydraulics, and special atmospheres that can t be immediately depowered without creating additional hazards when the fuel stop button is depressed. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Fri Jun 10 13:45:12 EDT 2016 Resolution: FR-52-NFPA Statement: Some furnaces include complex control of motion, hydraulics, and special atmospheres that can t be immediately depowered without creating additional hazards when the fuel stop button is depressed. NFPA 86 Public Inputs with Responses Report Page 169 of 230

170 70 of 222 1/26/2017 2:37 PM Public Input No. 98-NFPA [ New Section after A.8.3 ] TITLE OF NEW CONTENT A Safety circuit wiring should minimize the risk of fault accumulation or common mode failures.in the simple example below, if each device s wires run back to the control enclosure as pairs, triples, quads, etc., then a shorting fault on that circuit only eliminates that device from the safety circuit.should any number of those devices be daisy chained and returned to the enclosure as a single pair and a shorting fault occurs all of the devices are removed from service. In more advanced systems using sophisticated safety devices, the fault shown in the example may be detectable and in that case as long as the system returns to a safe state when the fault is detected, this wiring method may be acceptable. Figure Examples of wiring methods Additional Proposed Changes File Name Description Approved NFPA_86_-_Wiring_method_PI_- _rev3_tj docx Please extract the Figure from the document attached for this PI. Safety circuit wiring should minimize the risk of fault accumulation or common mode failures. NFPA 86 Public Inputs with Responses Report Page 170 of 230

171 8.3.2* Each safety interlock shall be wired so that a single fault occurring outside of the control enclosure (short, open wire condition, etc.) cannot interfere with or disable more than one safety interlock. A Safety circuit wiring should minimize the risk of fault accumulation or common mode failures. In the simple example below, if each device s wires run back to the control enclosure as pairs, triples, quads, etc., then a shorting fault on that circuit only eliminates that device from the safety circuit. Should any number of those devices be daisy chained and returned to the enclosure as a single pair and a shorting fault occurs all of the devices are removed from service. In more advanced systems using sophisticated safety devices, the fault shown in the example may be detectable and in that case as long as the system returns to a safe state when the fault is detected, this wiring method may be acceptable. Preferred wiring of Safety interlocks Unacceptable wiring of Safety interlocks Safety Switch Safety Switch Safety Switch Control Enclosure Safety Switch Control Enclosure Fault Fault 1 fault 1 interlock 1 fault 2 interlocks Figure Examples of wiring methods Note: Change devices to interlocks NFPA 86 Public Inputs with Responses Report Page 171 of 230

172 71 of 222 1/26/2017 2:37 PM Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Fri Jun 10 13:33:20 EDT 2016 Resolution: New material was not added to the body of the standard for explanatory material, see action on PI-99. NFPA 86 Public Inputs with Responses Report Page 172 of 230

173 72 of 222 1/26/2017 2:37 PM Public Input No. 73-NFPA [ Section No. A.8.4 ] A.8.4 The Programmable Logic Controller ( PLC) approach to combustion interlocks multiburner a Burner Management System (BMS) is as follows: (1) Interlocks relating to purge are done via PLC. (2) The purge timer is implemented in the PLC. (3) Interlocks relating to combustion air and gas pressure are done via PLC. (4) Gas valves for pilots and burners directly connected to flame safeguards the PLC must conform to the requirements of (5) Operation of pilot and burner gas valves must be confirmed by the PLC. (6) A PLC can be set up as intermittent, interrupted, or constant pilot operation. With an appropriate flame safeguard, it would be possible to provide an interrupted pilot with one flame sensor and one flame safeguard The PLC must perform the safe start check. (7) The PLC performs the trial of ignition per (8) The PLC must minitor all limits and all permissives and close the safety shutoff valves when appropriate. Section 8.4 of the standard deals with using a PLC as the BMS logic solver yet A.8.4 (4) referenced a combustion safeguard which didn t belong in the reference. Additional PLC requirements were added to A.8.4 for completeness. Item (6) was reworded for clarity. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion PI submitted on behalf of the NFPA 86 Intro Chapter Task Affilliation: Group. Submittal Date: Thu Jun 09 15:50:24 EDT 2016 Resolution: FR-74-NFPA NFPA 86 Public Inputs with Responses Report Page 173 of 230

174 73 of 222 1/26/2017 2:37 PM Statement: Section 8.4 of the standard deals with using a PLC as the BMS logic solver yet A.8.4 (4) referenced a combustion safeguard which didn t belong in the reference. Additional PLC recommendations were added to A.8.4 for completeness. Item (6) was reworded for clarity. NFPA 86 Public Inputs with Responses Report Page 174 of 230

175 74 of 222 1/26/2017 2:37 PM Public Input No. 74-NFPA [ Section No. A ] NFPA 86 Public Inputs with Responses Report Page 175 of 230

176 75 of 222 1/26/2017 2:37 PM A NFPA 86 Public Inputs with Responses Report Page 176 of 230

177 76 of 222 1/26/2017 2:37 PM Compliance with the manufacturer s safety manual would achieve actions such as, but not limited to, the Programmable Logic Controller ( PLC) detecting the following: (1) Failure to execute any program or task containing safety logic (2) Failure to communicate with any safety I/O (3) Changes in software set points of safety functions (4) Failure of outputs related to safety functions (5) Failure of timing related to safety functions An SIL The requirements for Safety Integrity Level (SIL) capability in pertain only to the PLC and its Input / Output (I/O) and not to the implementation of the burner management system. The purpose of the SIL capability requirement is to provide control reliability. A SIL 3 capable PLC includes third-party certification, the actions above, and partitioning to separate safety logic from process logic. The requirements for SIL capability in pertain only to the PLC and its I/O and not to the implementation of the burner management system. The purpose of the SIL capability requirement is to provide control reliability. SIL 3 capable PLCs automate many of the complexities of designing a safety system, namely; The PLCs have separate safe and non-safe program and memory areas and the safe areas can be locked with a signature. The inputs and outputs are monitored for stuck bits and loss of control. The firmware, application code, and timing is continually checked for faults. The outputs are internally redundant to ensure they will open even with a hardware failure. By contrast, SIL 2 capable PLCs require that many of these functions be implemented by the application code developer. Codes have traditionally relied on independent third party companies to test and approve safety devices suitable for use in the specific application. In the USA, there are companies like FM and UL that develop design standards and test safety equipment to those standards to ensure the device will operate properly when properly applied. Safety shutoff valves, scanners, combustion safeguards and pressure switches are some of the items that need to be approved for their intended service. Combustion systems have become far more complex requiring greater computing power and greater flexibility so the industry has turned to programmable logic controllers (PLCs) to address the increased complexity. Using a PLC as the burner management system (BMS) makes the PLC a safety device. Just like every other safety component, the PLC must be held to a minimum standard to ensure that it performs predictably and reliably and that its failure modes are well understood. When assessing a PLC s ability to perform safety functions, the internationally recognized standard is IEC (Functional Safety of Electrical/Electronic Programmable Electronic Safety-Related Systems.) is a detailed quantitative guideline for designing and testing electronic safety systems. By following the directives in this standard, a piece of equipment can be certified by an independent body as capable of meeting a safety integrity level (SIL). The goal of IEC is to quantify the probability that the safety device will fail in an unsafe fashion when commanded to act. The term used is Probability of Failure on Demand (PFD). The data required and the circuit and software expertise to get to the PFD can be quite overwhelming but once calculated they are categorized as follows. Safety Integrity Level (SIL) Probability of Failure on Demand (PFD) Risk Reduction Factor (1/PFD) Safety Availability (1 PFD) 4 > to < > 10,000 to < 100,000 > to < NFPA 86 Public Inputs with Responses Report Page 177 of 230

178 77 of 222 1/26/2017 2:37 PM 3 > to < > 1,000 to < 10,000 > 99.9 to < > to < 0.01 > 100 to <1,000 > 99 to < > 0.01 to < 0.1 < 10 to < 100 > 90 to < 99 One can quickly see that the SIL number is a power of 10 change in PFD. The PFD for SIL 1 states that the probability of an unsafe failure in any year is 1% to 10% and SIL 3 has the probability of an unsafe failure in a given year of 0.1% to 0.01%. Stated otherwise, SIL 1 indicates there is the probability of an unsafe failure every 10 to 100 years and a SIL 3 system will have a probability of an unsafe failure, when demanded, once every 1,000 years to 10,000 years. When the PLC, sensor, or final element is certified to SIL 2 it carries the language, SIL 2 capable. This is done because the device in question is capable of performing at that level only when the manufacturer s safety manual has been followed and the installation is correct per the manufacturer s safety manual. Stipulating that the PLC and its associated I/O shall be SIL 2 capable is only setting the floor for performance and helping to ensure that the hardware selected is suitable for use as a safety device nothing else is implied. Confusion may occur when individuals assume that since the hardware has been certified to IEC and it is SIL capable, that this infers that the system must now be designed according to IEC or ANSI/ISA (Functional Safety: Safety Instrumented Systems for the Process Industry Sector) and that is not the intent. IEC is a performance-based standard that offers advice and guidance to quantify, analyze, and subsequently mitigate risks associated with hazards in Safety Instrumented Systems (SIS). When following IEC 61511, each safety function like flame failure, emergency stop, high gas pressure etc., is analyzed. A systematic approach is taken to determine the severity of the failure of that safety function and then the appropriate SIL is assigned to that safety function. Once assigned, the appropriate sensors, logic solvers and final elements are chosen so that three or more of them working together can achieve the required SIL. Placing a sensor in series with a logic solver in series with a final element lowers the SIL and increases the PFD because their individual unsafe failures are cumulative, so it is possible to start with all SIL 2 capable components and end up with a SIL 1 safety function due to the cumulative failures of the individual devices. Offered here is an extremely brief and simple overview of an SIS, however, its proper application is extremely complicated requiring expertise to do correctly. The NFPA 87 requirements do not specify or imply that a Safety Instrumented System must be implemented, nor that a safety function meet a specified SIL target. An extremely effective risk-reducing technique is the use of layers of protection. Analyzing the layers is called layer-of-protection-analysis (LOPA). This technique applies safeties that are independent of other safeties and therefore can t fall victim to common mode errors or failures. As an example, picture a storage tank being filled by a pump that is controlled by a level sensor. It is important to contain the liquid but also not over-pressurize the tank. A layer of protection could be a pressure relief valve because that is independent of the pump control and the level sensor. Another layer could be a dike around the tank in case the pressure relief valve relieves or the tank fails. Again, the dike is completely independent of the other safeties and shouldn t suffer failures that may attack the other safeties. Common mode failures can be insidious. Think about this example of independent safeties and then think about a massive earth quake and tsunami hitting the dike, tanks, and controls all destroyed by a common mode disturbance (e.g. Fukushima). This technique can be effective in providing independent layers of protection that can reduce the risk by a factor of 10 - or an entire SIL. Modern combustion systems take advantage of layers of protection, thus reducing the SIL of each individual safety function. Examples are; Burner flows are set-up with mechanical locking devices to stay within the burner s stable operating range, gas pressures are monitored for variances, combustion air pressure is monitored, and the NFPA 86 Public Inputs with Responses Report Page 178 of 230

179 178 of 222 1/26/2017 2:37 PM flame is scanned. ISA prepared IEC calculations and scenarios on boiler systems and didn t identify any functions above SIL 2, with the majority being SIL 1 or less. The proposed revision to A adds expanded information on the related subject matter so as to help the user understand more about the intent of the safety PLC requirements in the mandatory text. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Thu Jun 09 15:57:18 EDT 2016 Resolution: FR-75-NFPA Statement: The proposed revision to A adds expanded information on the related subject matter so as to help the user understand more about the intent of the safety PLC requirements in the mandatory text. NFPA 86 Public Inputs with Responses Report Page 179 of 230

180 79 of 222 1/26/2017 2:37 PM Public Input No. 176-NFPA [ Section No. A ] A Equipment that is not explosion resistant, has no combustion air blower or exhaust blower, and relies on a natural draft to meet the purge requirements of this , should address the following conditions to ensure conformance: (1) The natural draft flow rate can be affected by furnace doors, covers, and dampers. If the purge rate and timing depend on the setting of these devices, they should be interlocked to meet the requirements in (C) (1), (D), and (E). (2) The proof of minimum required purge flow should handle cases in which the natural draft flow rate can be affected by differences in pressure between the heating chamber and the inside or outside of the building. (3) The specific gravity of the fuel must be considered in the design of the furnace purge path. For example, there should be no collection areas at the bottom of the heating chamber with a heavier-than-air fuel gas. (4) If the purge flow rate is not known or is not directly proved, then the purge time to be set in the timer should be determined by measurement. The party commissioning the burner system is responsible for this measurement and the documentation. The measurement should be conducted at the time when the furnace is at normal ambient temperature and is at its lowest purge flow rate. Confirming calculations and measurement data should be available for review in accordance with Chapter 7. Combustible gas analyzers and oxygen analyzers should be used to measure the time from the end of unburned gas release for the trial-for-ignition period until the combustible concentration of the system volume is below 25 percent LFL. The test should be repeated immediately for a second release of gas and time delay to ensure that the measurement is still below 25 percent LFL. If it is not, then the purge time must be increased, with repeated purge and trial-for-ignition sequences, until there is no successive buildup of the combustible concentration. The current NFPA Standard for Ovens and Furnaces implies that metallic radiant tubes are safer than other high temperature materials of construction such as ceramics and composites. Alternative non-metallic materials currently in industrial radiant tube service include mullites, sialons, silicon nitrides, siliconized silicon carbides and silicon / silicon carbide composites. The standard excludes and/or favorably treats metallic radiant tubes in terms of relaxed requirements for: Pre-ignition Purging Sections , A , & Safety Shut-Off Valves Section Flame Supervision Section This special treatment for metallic radiant tubes ignores several decades of industry experience where deflagration / explosion has not proved to be a significant risk factor for non-metallic materials, or at minimum the incident losses are no different than metallic tubes used in equivalent service. In actual operation most metallic radiant tubes used in carburizing, carbonitriding and higher temperature processing periodically experience open-crack, thru-wall hole and/or perforation failures due to material creep distortion, carburization corrosion/embrittlement and/or weld stress fracture. Any NFPA 86 Public Inputs with Responses Report Page 180 of 230

181 80 of 222 1/26/2017 2:37 PM risks posed by open metallic tube failures are no different than those of non-metallic tubes, regardless of whether combustible gases flow into the furnace chamber or, vice versa, into the radiant tube. For the processes cited above metallic failures generally occur every three to five years (sometimes sooner) mandating radiant tube replacement to maintain the integrity of the process atmosphere and quality of production. While ceramic and composite tubes available to the industrial furnace users do not experience the progressive failure modes of metallic tubes, they are more susceptible to mechanical impact and less tolerable of thermo-mechanical stress. Failure of non-metallic radiant tubes has the same effect on the furnace atmosphere and production quality, also mandating their replacement. When radiant metallic tube applications are optimally designed (so that the surface temperatures are uniform and not excessive for the specific alloy employed), they are just as likely, if not more likely, to fail catastrophically compared with ceramic and composite tubes under the same service conditions in carburizing, carbonitriding and higher temperature atmospheres. Furthermore, consideration of radiant tube durability should not be based on new material properties, but rather on radiant tubes that are at or near the end of their useful service lives. It is at this point that a tube failure-related incident is most likely to occur. To be logically consistent both metallic and non-metallic radiant tubes used at elevated temperatures (e.g. above 1550 F) must be treated the same. For example, if flame supervision is required for non-metallic radiant tubes, then it should be required for metallic radiant tubes as well. An alternative approach might be to require that metallic tubes are removed from use before they are projected to fail (based on a documented analysis of service life in the specific application). In practice it is rare that adequate information is available to base such projections with certainty, therefore we do not envision that this risk avoidance tactic can be reliably adopted by industry. On the other hand, if metallic radiant tubes are proven to operate in service with little or no deterioration at lower temperatures (e.g. below 1550 F), a specific reliability analysis might support the conclusion that catastrophic failure is improbable in that application. The testing prescribed in Section A to validate the explosion-resistance of non-metallic materials ignores the failure modes of metallic tubes in carburizing, carbonitriding and higher temperature processing. Normative service failures (open-cracks, thru-wall holes and/or perforations) result in metallic radiant tubes incapable of supporting any pressurization whatsoever. Furthermore, the exclusion of metallic materials from these validity protocols per Section ignores the design pressure ratings of radiant tubes (as a function of wall thickness, alloy strength and weld integrity). Also longer-term metallic tube wall deterioration due to spalling and embrittlement (which inevitably occurs in high temperature service) is not considered. Related Public Inputs for This Document Related Input Public Input No. 174-NFPA [Section No. A ] Public Input No. 169-NFPA [Section No ] Public Input No. 170-NFPA [Sections , ] Public Input No. 171-NFPA [Sections , ] Public Input No. 172-NFPA [Section No ] Public Input No. 173-NFPA [Section No ] Public Input No. 175-NFPA [Section No. A ] Relationship NFPA 86 Public Inputs with Responses Report Page 181 of 230

182 81 of 222 1/26/2017 2:37 PM Submitter Full Name: Curt Colopy Organization: INEX Incorporated Submittal Date: Wed Jun 29 16:30:39 EDT 2016 Resolution: The submitter would like the committee to review requirements pertaining to the differences between metal and ceramic tubes. This change would not resolve this issue. NFPA 86 Public Inputs with Responses Report Page 182 of 230

183 82 of 222 1/26/2017 2:37 PM Public Input No. 156-NFPA [ New Section after A (C)(2) ] TITLE OF NEW CONTENT A (D) A pre-ignition airflow interlock can be provided by a variety of devices. Most commonly, a fixed orifice plate is used to generate a differential pressure at the desired (calculated) pre-ignition airflow rate. A differential pressure switch, used in conjunction with the fixed orifice, provides the electrical permissive to verify the presence of air movement at the required flow rate. Similarly, a differential pressure switch can be used as an airflow interlock by monitoring the differential pressure across a burner, either in single or multi-burner systems. Single burner applications would include package burner assemblies. Burners provide a fixed airflow rate at a known pressure, therefore, a burner can be utilized as the flow element. Burner manufacturer s literature will typically provide the pressure-flow data for each specific burner size available. Valves which can restrict airflow below the minimum required pre-ignition airflow rate shall not be installed downstream of the pressure switch location. Refer to Figure A If the furnace internal pressure is operated above atmospheric pressure, the reference connection on the pressure switch should be connected to the furnace heating chamber in lieu of an atmospheric pressure reference. A vane or paddle type flow switch is another example of a device that can be used to provide the required pre-ignition airflow interlock. When utilizing a vane flow switch, the purge time should be calculated based on the minimum airflow for the particular vane size being used. Manufacturer s literature will typically specify the airflow range for each size vane available. Annex material adds guidance for various methods to implement an air flow interlock. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Tue Jun 28 14:33:31 EDT 2016 Resolution: FR-112-NFPA Statement: Annex material adds guidance for various methods to implement an air flow interlock. NFPA 86 Public Inputs with Responses Report Page 183 of 230

184 83 of 222 1/26/2017 2:37 PM Public Input No. 159-NFPA [ Section No. A (C)(2) ] A (C)(2) See Figure A (C)(2) Figure A (C)(2) Example for Multiple Burner System with Independently Operated Burners Using a Common SSOV with Single Proved Closed Interlock for Pre-purge. Additional Proposed Changes File Name Description Approved A _C_Diagram_to_add_tj docx Adds legend for symbols used in current Annex. Was in the 2011 edition but removed as PI may have changed the reference. NFPA 86 Public Inputs with Responses Report Page 184 of 230

185 Fig. A (C) NFPA 86 Public Inputs with Responses Report Page 185 of 230

186 84 of 222 1/26/2017 2:37 PM add legend for symbols used in current Annex Figure. Submitter Full Ted Jablkowski Name: Organization: Fives North American Combustion Submitted on behalf of the NFPA 86 Intro Chapters Task Affilliation: Group Submittal Date: Tue Jun 28 14:50:40 EDT 2016 Resolution: FR-54-NFPA Statement: Add legend for symbols used in current Annex Figure. NFPA 86 Public Inputs with Responses Report Page 186 of 230

187 85 of 222 1/26/2017 2:37 PM Public Input No. 136-NFPA [ New Section after A (4)(d) ] A (4)(e) A (4)(e) A system which has a constant airflow through a fixed orifice with no valve downstream of it is considered to have proven airflow as long as the source of air is proven on the main header. Additional Proposed Changes File Name NFPA_proposal_for_section_A _4_e_.PDF Description Approved In some applications, the airflow is so low that it is impractical to prove at each individual burner. However, if the airflow is proven at the main header and then flows through a fixed orifice, this meets the intent of NFPA 86. Submitter Full Name: Steven Mickey Organization: WS Thermal Process Technology Inc. Submittal Date: Thu Jun 23 10:33:08 EDT 2016 Resolution: FR-55-NFPA Statement: Provides another method of implementing an air flow interlock which is based on the burner system's defined pressure drop versus air flow. Annex Item: In some applications, the airflow is so low that it is impractical to prove at each individual burner. However, if the airflow is proven at the main header and then flows through a fixed orifice, this meets the intent of NFPA 86. NFPA 86 Public Inputs with Responses Report Page 187 of 230

188 NFPA 86 Public Inputs with Responses Report Page 188 of 230