Technical Committee on Electric Generating Plants (ECG-AAA)

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1 Technical Committee on Electric Generating Plants () DATE: May 2, 2013 TO: FROM: M E M O R A N D U M Principal and Alternate Members of the Technical Committee on Electric Generating Plants () Chad Duffy, NFPA Staff Liaison Office: (617) cduffy@nfpa.org SUBJECT: AGENDA NFPA 850/851/853 First Draft Meeting (Fall 2014) May 21-23, 2013, at the NFPA Quincy, MA Please submit requests for additional agenda items to the chair at least seven days prior to the meeting, and notify the chair and staff liaison as soon as possible if you plan to introduce any first revisions at the meeting. All NFPA Technical Committee meetings are open to the public. Please contact me for information on attending a meeting as a guest. Read NFPA's Regulations Governing the Development of NFPA Standards (Section ) for further information. Additional Meeting Information: See the Meeting Notice on the Document Information Page ( or for meeting location details. If you have any questions, please feel free to contact Elena Carroll, Project Administrator at or by ecarroll@nfpa.org. C. Standards Administration

2

3 Attachment #1: Previous Meeting Minutes

4 Technical Committee on Electric Generating Plants MINUTES OF ROC MEETING April 28-29, 2009 Attendance: Principal Members/Staff: Dave Snell, Chair - Luminant, TX Don Drewry, Secretary HSB Professional Loss.Control, NJ Steven Behrens XL Global Asset Protection Services, CT Daryl Bessa F.E. Moran, Inc., IL Donald Birchler FP&C Consultants Inc, MO Bernard Bischoff Fire Systems Marketing and Technical Services, IL Harold Brandes Harold Brandes, NC Stanley Chingo NISYS Corporation, GA William Collins UTC Power/Fuel Cells Ismail Gosla Fluor, Inc., CA Rickey Johnson One Beacon Insurance, NY John Koester Marsh USA, MD Amjad Mian Manitoba Hydro, MB Thomas O Connor Edison Electric Institute, OH Scott Pruett Black & Veatch Corporation, KS Clifford Roberts Global Marine and Energy Norman Rockwell TVA, TN Todd Stinchfield FM Global, RI Robert Wichert US Fuel Cell Council, CA William Wood Starr Technical Risks Agency, Inc, GA Jason Gamache - NFPA Staff Liaison, MA ALTERNATES GUESTS Hugh Castles Entergy Services, Inc., LA Gary heller Edison Electric Institute, AZ Lawrence Danner - GE Energy, SC Mark Boone Dominion Paul Rivers 3M Company Angela Krcmar Firetrace Bob Gibbs - Firetrace

5 1. Opening of Meeting The meeting was called to order by Dave Snell, Chairmen at approximately 8:30 AM on April 28, Self-introductions 3. Chair s Report: Dave Snell thanked those that came to the meeting. One Item before getting started: This was one of our first NFPA sponsored meetings that there were less than the minimum number of rooms (committee member staying at the hotel) booked to obtain a meeting room discount. So that we do not have to start charging a meeting fee, we are asking that attending members stay, if possible, at the same hotel the meeting is being held. Dave Snell outlined the objective of the meeting. Since the agenda was changed about a week before the meeting, Dave reviewed the complete agenda. Dave explained that we would work though subcommittees (task groups) to cover the comments. Each chair will present their recommendations to the main committee for review and discussion. We will follow standard NFPA committee procedures in addressing each comment as Jason has outlined. During new business, we will be discussing the possibility of forming correlating committees for each document. We have had many new items added to NFPA 850. We want to make sure that we have also addressed the same items in NFPA 851 and NFPA 853. We need to reduce the likelihood of the gaps between all the documents. One way of doing this is to have correlating committees for each document. After we have completed public comments, we will open the floor to address committee comments and new business. There is a need to clarify the definition of conveyors in Chapter 7 (not new material). There was one item for NFPA 853 that was submitted late, but is not new material. It is considered additional information to help clarify the comment. One item of interest, there are still issues being discussed related to dust in plants, including what OSHA is doing. NFPA 654 has visited one of Tom O Connor s plants. The PRB group will be meeting in Chicago to discuss Best Practices. NFPA is having a presentation in Baltimore for Dust Suppression. Dave thanked everyone for continuing to work on the three documents and coming to the meeting. These documents have had and will continue to have an impact on the industry.

6 4. Minutes of last Meeting: Hugh Castles had several minor editor changes for the Minutes of the ROP Meeting from August The changes were noted and a revision will be sent to Jason. The minutes were then approved as noted. The committed voted to accept last meeting s minutes (Don Birchler voted to accepted, Scott Pruett seconded the motion.) The minutes and any comments will be posted on the NFPA s committee website. 5. Staff Liaison s Report - Jason Gamache Jason reviewed the committee procedures for handling comments. The committee may submit their comments during the meeting. However, no new material may be added. Participation is granted by chair Voting 2/3 majority, letter ballot is official Reviewed the various ways the committee can accept or reject a proposal No new material can be added to the document during the meeting. If committee has new material, it must submit a proposal for the next cycle. Ballots will be sent out in a few weeks and must be return by mail or fax. Note: all members both principal and their alternate need to respond. 6. Presentations 3 M Company Paul Rivers A presentation was made by the Paul Rivers of the 3M Company regarding NOVEC 1230 fluid as a clean extinishing agent. Mr. Rivers s presentation covered the various full-scale tests that were conducted in Spain using NOVEC 1230 for protection in a transform vaults. There were a series of three different test scenarios, a totally enclosed room, a partial vented room (20% open) and a full open (roof removed) room. Fire Trace Automatic Fire Suppression Systems (wind turbine applications) A presentation of the Fire Trace Fire Suppression System for wind turbine enclosures and associated electrical cabinets was presented to the committee. The system uses a local flooding application of NOVEC 1230 over the area being protected. They have also used FM200 in some installations. The system can be design for both direct and an indirect application. 7. ECG Meeting - ROC Discussion NFPA Review of public comments Following proper procedures, each committee chair made a proposal to the main committee as to how to handle the comment being discussed. Each comment was reviewed and issues were discussed by the full committee. A vote was made by the committee to as to the action recommended by the chair.

7 There were 15 public comments related to NFPA 850 Chapter 2 Steve Behrens, Chair one comment - Chapter 4 ( new chapter 16) - Hugh Castles, Chair one comment Chapter 7 - Scott Pruett, Chair - four comments Chapter 10 Ricky Johnson, Chair eight comments Annex D John Koester, Chair one Comment (this was a committee comment submitted as a public comment so that the information was presented a head of time. The comment consisted of updated loss information) NFPA Review of public comments Chapter 7 Amjad Mian, Chair One comment NFPA Subcommittee comments There was one committee comment that was submitted regarding thermoset insulation and the need for protection of the hydro-generator windings. The committee had a long discussion as to the information being presented and the loss history that was referenced in the comment. Clarification of the committee s intent regarding proposal (A.7.3.1) was made. Annex D - John Koester one Comment. (This was a committee comment submitted as a public comment so that the information was presented a head of time. Updated loss information was added to NFPA 851). NFPA Subcommittee comment Robert Wiechert presented editorial information to the committee that helps clarify several NFPA 853 proposals. ( No new Material) NFPA Subcommittee comment 1. It was expressed by Todd Stinchfield FM Global, that the reference the committee used to evaluate the use of Compressed Air Foam systems for the protection of transformers was incorrect. FM did not provide an approval for the use of the product to protect transformers. After further research, the sub-committee found that two different documents were attached together, one the FM approval, the other an independent Canadian test lab results. The Canadian tests were related to using the product for transformer protection, but not part of FM s approval. The committee felt it was best to remove the comment about using Compressed Air Foam for the protection of transformers at this time.

8 2. The second comment was related the committee specifying the same design density for all applications of Compress Air Foam. Currently, NFPA 11 committee has issued a TI Amendment that addresses the installation of Compressed Air Foam systems. After much discussion on the subject, the NFPA 850 committee concluded it would be best to reference the use and installation of Compressed Air Foam systems back to NFPA Doug Brandes presented a committee comment regarding the protection of critical Conveyors in the plant. After much discussion regarding how we would define a critical conveyor and the issue that the section in question is primarily for coal conveyor, Doug withdrew his proposed comment. Because the discussion was going into areas of new material, it was stated that the sub committee for chapter 7 would need to look at how we may need to define critical conveyors and if a change is needed, they will need to be made a proposal to be submitted for next cycle. 4. There was an editorial comment for proposal section that changed generators to generator/torque convector for clarification. 8. New Business Committee Structure After Dave discussed the concept of creating correlating committees for the various documents with Jason, it was expressed the process would not be easy. The Standards Council is not necessarily in favor of forming correlating committees. That said, we would continue our present structure. The assigned task groups will continue to handle the various chapters. Dave asked Rick Johnson to continue to oversee the new technology task group. As always, we will continue to bring in expertise as need into each task group. During the next cycle, we will need to look at bringing NFPA 851 into NFPA 850 to eliminate the duplication of information and to assure that the technical information is consistent. Dave will need to write a memo to the Standards Council that specifies our reasoning and justification for combining the two documents. Bernard Bischoff express the concern while the NFPA 850/851documents has been around however, once you get away from the Power Generation Industry most individual are not aware our documents exist or the importance of them. Perhaps a task group can be create that would better market the documents. Jason indicated that the NFPA puts more marketing efforts into their top selling documents. It was expressed that the committee needs to look at other means to promote our documents. It was agreed for the next meeting, a task group would work on how we will address this issue. Assigned to the task group were Robert Wiechert, Bernard Bischoff, Daryl Bessa, Don Birchler, Don Drewry, and Dave Snell. Jason reviewed the set-up of NFPA s E-committee Web page. Any task group or committee can use the web site to post information. 9. Future Meetings

9 We are finishing the Fall 2009 cycle with the issuing of the new documents. This means we would be entering a Fall 2014 cycle for the next release of the documents. NFPA only supports the ROP and the ROC meetings at this time. Any pre-rop meeting would be up to the committee to coordinate. Dave expressed that we would likely try to coordinate our meeting after one of the EEI meetings. This way most of the individuals that attend the EEI meeting can also attend our committee meeting. We will look at the possibility of following the Fall 2010 EEI meeting with a 1 ½-day NFPA 850 meeting. We would also want to make sure we stay at the same hotel as the EEI group does. 10. Losses Dave To complete 11. ROC Ballot The committee was reminded that we still would need to vote on the ballots. Our committee actions are not formal votes. To be accepted, we will need 2/3 majority. Meeting Adjournment. Respectfully Submitted, Don Drewry

10 Attachment #2: Public Input/850

11 Page 1 of 23 Public Input No. 4-NFPA [ Global Input ] Withdraw entire document TEST Submitter Full Name: Marisol Ballester Organization: NFPA Submittal Date: Thu May 10 12:08:24 EDT 2012 I, Marisol Ballester, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of By checking this box I affirm that I am Marisol Ballester, and I agree to be legally bound by the above and the terms and conditions contained therein. I understand and intend that, by

12 Page 2 of 23 Public Input No. 1-NFPA [ Section No. 1.1 ] 1.1 Scope. This document provides standards and recommendations for fire prevention and fire protection for electric generating plants and high voltage direct current converter stations, except as follows: Nuclear power plants are addressed in NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants; hydroelectric plants are addressed in NFPA 851, Recommended Practice for Fire Protection for Hydroelectric Generating Plants; and fuel cells are addressed in NFPA 853, Standard for the Installation of Stationary Fuel Cell Power Systems. TEST Submitter Full Name: Marisol Ballester Organization: NFPA Submittal Date: Thu May 10 11:50:45 EDT 2012 I, Marisol Ballester, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of By checking this box I affirm that I am Marisol Ballester, and I agree to be legally bound by the above and the terms and conditions contained therein. I understand and intend that, by

13 Page 3 of 23 Public Input No. 11-NFPA [ Section No. 2.2 ] 2.2 NFPA Publications. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA NFPA 1, Fire Code, 2009 edition. NFPA 10, Standard for Portable Fire Extinguishers, 2010 edition. NFPA 11, Standard for Low-, Medium-, and High-Expansion Foam, 2010 edition. NFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 2008 edition. NFPA 12A, Standard on Halon 1301 Fire Extinguishing Systems, 2009 edition. NFPA 13, Standard for the Installation of Sprinkler Systems, 2010 edition. NFPA 14, Standard for the Installation of Standpipe and Hose Systems, 2010 edition. NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection, 2007 edition. NFPA 16, Standard for the Installation of Foam-Water Sprinkler and Foam- Water Spray Systems, 2007 edition. NFPA 17, Standard for Dry Chemical Extinguishing Systems, 2009 edition. NFPA 20, Standard for the Installation of Stationary Pumps for Fire Protection, 2010 edition. NFPA 22, Standard for Water Tanks for Private Fire Protection, 2008 edition. NFPA 24, Standard for the Installation of Private Fire Service Mains and Their Appurtenances, 2010 edition. NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water- Based Fire Protection Systems, 2008 edition. NFPA 30, Flammable and Combustible Liquids Code, 2008 edition. NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages, 2008 edition. NFPA 31, Standard for the Installation of Oil-Burning Equipment, 2006 edition. NFPA 37, Standard for the Installation and Use of Stationary Combustion Engines and Gas Turbines, 2010 edition. NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, 2009 edition. NFPA 54, National Fuel Gas Code, 2009 edition. NFPA 55, Compressed Gases and Cryogenic Fluids Code, 2010 edition. NFPA 58, Liquefied Petroleum Gas Code, 2008 edition. NFPA 59, Utility LP-Gas Plant Code, 2008 edition. NFPA 59A, Standard for the Production, Storage, and Handling of Liquefied Natural Gas (LNG), 2009 edition.

14 Page 4 of 23 NFPA 61, Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities, 2008 edition. NFPA 68, Standard on Explosion Protection by Deflagration Venting, 2007 edition. NFPA 69, Standard on Explosion Prevention Systems, 2008 edition. NFPA 70, National Electrical Code, 2008 edition. NFPA 72, National Fire Alarm and Signaling Code, 2010 edition. NFPA 75, Standard for the Protection of Information Technology Equipment, 2009 edition. NFPA 77, Recommended Practice on Static Electricity, 2007 edition. NFPA 80, Standard for Fire Doors and Other Opening Protectives, 2010 edition. NFPA 80A, Recommended Practice for Protection of Buildings from Exterior Fire Exposures, 2007 edition. NFPA 85, Boiler and Combustion Systems Hazards Code, 2007 edition. NFPA 86, Standard for Ovens and Furnaces, 2007 edition. NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems, 2009 edition. NFPA 90B, Standard for the Installation of Warm Air Heating and Air- Conditioning Systems, 2009 edition. NFPA 91, Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Noncombustible Particulate Solids, 2010 edition. NFPA 92A, Standard for Smoke-Control Systems Utilizing Barriers and Pressure Differences, 2009 edition. NFPA 101, Life Safety Code, 2009 edition. NFPA 110, Standard for Emergency and Standby Power Systems, 2010 edition. NFPA 204, Standard for Smoke and Heat Venting, 2007 edition. NFPA 214, Standard on Water-Cooling Towers, 2005 edition. NFPA 220, Standard on Types of Building Construction, 2009 edition. NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations, 2009 edition. NFPA 251, Standard Methods of Tests of Fire Resistance of Building Construction and Materials, 2006 edition. NFPA 252, Standard Methods of Fire Tests of Door Assemblies, 2008 edition. NFPA 253, Standard Method of Test for Critical Radiant Flux of Floor Covering Systems Using a Radiant Heat Energy Source, 2006 edition. NFPA 257, Standard on Fire Test for Window and Glass Block Assemblies, 2007 edition. NFPA 259, Standard Test Method for Potential Heat of Building Materials, 2008 edition. NFPA 497, Recommended Practice for the Classification of Flammable Liquids, Gases, or Vapors and of Hazardous (Classified) Locations for Electrical Installations in Chemical Process Areas, 2008 edition. NFPA 551, Guide for the Evaluation of Fire Risk Assessments, 2010 edition.

15 Page 5 of 23 NFPA 600, Standard on Industrial Fire Brigades, 2010 edition. NFPA 601, Standard for Security Services in Fire Loss Prevention, 2010 edition. NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids, 2006 edition. NFPA 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, 2007 edition. NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, 2010 edition. NFPA 704, Standard System for the Identification of the Hazards of Materials for Emergency Response, 2007 edition. NFPA 750, Standard on Water Mist Fire Protection Systems, 2010 edition. NFPA 780, Standard for the Installation of Lightning Protection Systems, 2008 edition. NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2010 edition. NFPA 851, Recommended Practice for Fire Protection for Hydroelectric Generating Plants, 2010 edition. NFPA 853, Standard for the Installation of Stationary Fuel Cell Power Systems, 2010 edition. NFPA 1143, Standard for Wildland Fire Management, 2009 edition. NFPA 1144, Standard for Reducing Structure Ignition Hazards from Wildland Fire, 2008 edition. NFPA 1221, Standard for the Installation, Maintenance, and Use of Emergency Services Communications Systems, 2010 edition. NFPA 1962, Standard for the Inspection, Care, and Use of Fire Hose, Couplings, and Nozzles and the Service Testing of Fire Hose, 2008 edition. NFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting, 2007 edition. NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems, 2008 edition. NFPA 2010, Standard for Aerosol Fire Extinguishing Systems, 2010 edition. NFPA, Fire Protection Handbook, 2008, 20th edition. SFPE, Engineering Guide to Fire Risk Assessment, 2006 edition. SFPE, Handbook of Fire Protection Engineering, 2008, 4th edition. Aerosol Extinguishing systems are suitable for some suitable applications covered by this document, but there is no reference to allow use of the technology.

16 Page 6 of 23 Submitter Full Name: Daniel Dahl Organization: Morrison Hershfield Corporatio Submittal Date: Tue Dec 11 09:33:40 EST 2012 I, Daniel Dahl, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. Except to the extent that I may lack authority to make an assignment of content identified above, I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Daniel Dahl, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature Origin (from sources other than the submitter) The proposed text matches the format and content of the other references in the table.

17 Page 7 of 23 Public Input No. 18-NFPA [ Section No ] UL Publications. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL ANSI/UL 723, Test for Surface Burning Characteristics of Building Materials, 2008, revised ANSI/UL 900, Standard for Safety Test Performance of Air Filters, 2004, Revised ANSI/UL 1479, Standard for Fire Tests of Through-Penetration Firestops, 2003, Revised ANSI/ UL 790, Tests for Fire Resistance of Roof Covering Materials, 2004, revised ANSI/ UL 1709, Standard for Rapid Rise Fire Tests of Protection Materials for Structural Steel, Add ANSI approval designation to ANSI/UL 790 and ANSI/UL 1709, and update referenced standards to most recent edition as indicated. Submitter Full Name: John Bender Organization: UL LLC Submittal Date: Fri Dec 28 09:03:59 EST 2012 I, John Bender, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this By checking this box I affirm that I am John Bender, and I agree to be legally bound by the above and the terms and conditions contained therein. I understand and intend that, by

18 Page 8 of 23 Public Input No. 14-NFPA [ New Section after ] Gas Purging. The act of replacing air in a fuel gas pipeline with gas by direct replacement so rapidly that a minimum of mixing between the two gases occurs Gas Blowing. The act of cleaning a fuel gas pipeline using high pressure/velocity fuel gas. Note: This Proposal originates from Tentative Interim Amendment (TIA 1004) issued by the Standards Council on October 20, The 2010 edition of NFPA 850, Recommended Practice for Fire Protection for Electric Generating Plants and High Voltage Direct Current Converter Stations, contains a conflict with NFPA 54, National Fuel Gas Code, in that it is referenced in the Recommended Practice while NFPA 54 states that it excludes utilities. The proposed TIA intends to correct this conflict as well as offer guidance that would lessen the recognized hazards associated with the cleaning, inerting and purging of fuel gas piping systems associated with electric generating plants. The reference and applications to NFPA 54 has been clarified in the proposed TIA as it applies to low pressure fuel gas piping systems at power generating plants. New references are included for applicable documents that provide guidance for high pressure fuel gas piping systems. In addition, guidance is provided for the safe cleaning, inerting and purging of fuel gas piping systems in both new construction phase as well as repair and maintenance phase. Emergency Nature: In February 2010, there was a large natural gas explosion at the 620 MW gas and oil fired Kleen Energy Plant located in Middletown, Connecticut. The plant was 95% complete and was planned to go on line in June The explosion resulted in six fatalities. The facility was conducting a gas blow of the fuel gas piping using natural gas when the explosion occurred. The physical damage was in the millions and caused a delay in the project for two years. The proposed TIA intends to address potential hazards related to this incident. The proposed TIA meets Sections 5.3(b) and 5.3(d) of NFPA s Regulations Governing Committee Projects for justification of its emergency nature, which read as follows: 5.3(b) The document contains a conflict within the document or with another NFPA document. 5.3(d) The proposed TIA intends to offer to the public a benefit that would lessen a recognized (known) hazard or ameliorate a continuing dangerous condition or situation. Submitter Full Name: Rickey Johnson Organization: One Beacon Energy Group Submittal Date: Tue Dec 11 09:50:15 EST 2012 I, Rickey Johnson, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of

19 Page 9 of 23 By checking this box I affirm that I am Rickey Johnson, and I agree to be legally bound by the above and the terms and conditions contained therein. I understand and intend that, by

20 Page 10 of 23 Public Input No. 3-NFPA [ New Section after ] TEST ADD New TEST TEST Submitter Full Name: Marisol Ballester Organization: NFPA Submittal Date: Thu May 10 12:03:51 EDT 2012 I, Marisol Ballester, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of By checking this box I affirm that I am Marisol Ballester, and I agree to be legally bound by the above and the terms and conditions contained therein. I understand and intend that, by

21 Page 11 of 23 Public Input No. 12-NFPA [ Section No ] Fire suppression systems and equipment should be provided in all areas of the plant as identified in Chapters 7 through 14 or as determined by the Fire Protection Design Basis. Fixed suppression systems should be designed in accordance with the following codes and standards unless specifically noted otherwise: NFPA 11, Standard for Low-, Medium-, and High-Expansion Foam NFPA 12, Standard on Carbon Dioxide Extinguishing Systems NFPA 13, Standard for the Installation of Sprinkler Systems NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection NFPA 16, Standard for the Installation of Foam-Water Sprinkler and Foam-Water Spray Systems NFPA 17, Standard for Dry Chemical Extinguishing Systems NFPA 750, Standard on Water Mist Fire Protection Systems NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems NFPA 2010, Standard for Aerosol Fire Extinguishing Systems Aerosol Extinguishing systems are suitable for some suitable applications covered by this document, but there is no reference to allow use of the technology. Submitter Full Name: Daniel Dahl Organization: Morrison Hershfield Corporatio Submittal Date: Tue Dec 11 09:35:51 EST 2012 I, Daniel Dahl, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. Except to the extent that I may lack authority to make an assignment of content identified above, I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Daniel Dahl, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature Origin (from sources other than the submitter) The proposed text matches the format and content of the other references in the table.

22 Page 12 of 23 Public Input No. 15-NFPA [ Section No. 7.2 ] 7.2 Fuel Handling Gas * General. The storage and associated piping systems for gases in the gaseous or liquefied states should comply with ASME B31.1, Power Piping, NFPA 54, National Fuel Gas Code; NFPA 55, Compressed Gases and Cryogenic Fluids Code; and NFPA 58, Liquefied Petroleum Gas Code; and. For pressures exceeding the scope of the aforementioned documents, refer to ASME B31.1, Power Piping , Gas Transmission and Distribution Piping Systems Shutoff Valve. The plant's main and igniter natural gas shutoff valve should be located near an exterior wall. The valve should be provided with both manual and automatic closing capabilities locally, and remote closing capability from the control room. The valve should be arranged to fail closed on the loss of power or pneumatic control Electrical Equipment. Electrical equipment in areas with potentially hazardous atmospheres should be designed and installed in compliance with Articles 500 and 501 of NFPA 70, National Electrical Code, and ANSI C2, National Electrical Safety Code Cleaning. The following cleaning methods should be considered when designing, installing, and testing the fuel gas piping systems: (1)* Pigging (2)* Aerated water jets (3)* High-pressure water jets (4)* Nonflammable gaseous media

23 Page 13 of The hazards associated with each type of cleaning media should be considered Gas blowing for cleaning pipe is inherently dangerous and should be avoided If gas blowing for cleaning pipe cannot be avoided, a flare stack should be provided for the discharge If a flare stack is not provided, the precautions listed in through should be taken Personnel responsible for directing a gas blow operation should be knowledgeable in all aspects of the operation Site specific procedures should be developed that address all aspects of the gas blow operation Site specific procedures should take into account guidance and parameters regarding recommended flow rates provided by the equipment manufacturer S ite specific gas dispersion analyses should be conducted Potential ignition sources should be eliminated from the area Piping and associated equipment should be grounded Gas detection equipment should be placed in appropriate areas to ensure adequate gas dispersion occurs and to identify gas migration into areas where personnel or property may be at risk On-site personnel should be reduced to only those necessary to support the gas blow operation (e.g., off hours or weekend) All on-site personnel should be knowledgeable of the safety protocols associated with gas blow operation Communication protocol should be established for warning personnel on site in the event of an incident, including the appropriate actions to take Discharge vent(s) should be directed upward to safe outdoor area(s) above all equipment and away from all building air intakes Public officials should be notified where interruptions to normal flow of traffic or calls from the public can be anticipated The public in the vicinity of the gas discharge should be notified if it is anticipated the public will be affected by the noise or odor * Inerting. Prior to the introduction of fuel gas to the fuel gas piping, inerting should be performed.

24 Page 14 of Gas Purging. Gas purging, whether indoor or outdoor, should be attended, monitored with a combustible gas indicator, and stopped when fuel gas purity indicates completion (e.g. 95% fuel gas) Gas purging at pressures below 125 psig (861.8 kpa) should be performed in accordance with the applicable sections of NFPA Gas purging at pressures exceeding 125 psig (861.8 kpa) should be performed in accordance with or * Maintenance and Repair. The hazards associated with flammable gases and asphyxiants should be considered when performing maintenance and repairs Fuel gas piping should be inerted in accordance with prior to maintenance and repair When fuel gas piping is being inerted with asphyxiants, the area should be ventilated or considered a confined space as regulated by US Department of Labor OSHA 29 CFR , Permit Required Confined Space Standard. Note: This Proposal originates from Tentative Interim Amendment (TIA 1004) issued by the Standards Council on October 20, The 2010 edition of NFPA 850, Recommended Practice for Fire Protection for Electric Generating Plants and High Voltage Direct Current Converter Stations, contains a conflict with NFPA 54, National Fuel Gas Code, in that it is referenced in the Recommended Practice while NFPA 54 states that it excludes utilities. The proposed TIA intends to correct this conflict as well as offer guidance that would lessen the recognized hazards associated with the cleaning, inerting and purging of fuel gas piping systems associated with electric generating plants. The reference and applications to NFPA 54 has been clarified in the proposed TIA as it applies to low pressure fuel gas piping systems at power generating plants. New references are included for applicable documents that provide guidance for high pressure fuel gas piping systems. In addition, guidance is provided for the safe cleaning, inerting and purging of fuel gas piping systems in both new construction phase as well as repair and maintenance phase. Emergency Nature: In February 2010, there was a large natural gas explosion at the 620 MW gas and oil fired Kleen Energy Plant located in Middletown, Connecticut. The plant was 95% complete and was planned to go on line in June The explosion resulted in six fatalities. The facility was conducting a gas blow of the fuel gas piping using natural gas when the explosion occurred. The physical damage was in the millions and caused a delay in the project for two years. The proposed TIA intends to address potential hazards related to this incident. The proposed TIA meets Sections 5.3(b) and 5.3(d) of NFPA s Regulations Governing Committee Projects for justification of its emergency nature, which read as follows: 5.3(b) The document contains a conflict within the document or with another NFPA document. 5.3(d) The proposed TIA intends to offer to the public a benefit that would lessen a recognized (known) hazard or ameliorate a continuing dangerous condition or situation. Submitter Full Name: Rickey Johnson Organization: One Beacon Energy Group Submittal Date: Tue Dec 11 09:52:14 EST 2012

25 Page 15 of 23 I, Rickey Johnson, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of By checking this box I affirm that I am Rickey Johnson, and I agree to be legally bound by the above and the terms and conditions contained therein. I understand and intend that, by

26 Page 16 of 23 Public Input No. 13-NFPA [ Section No ] * ANSI/ASME B31.1, Power Piping, should be followed in the design of HTF piping systems. Piping and fittings should be properly designed to resist an exposure fire until protection can be achieved by water spray. To reduce possible sources of leaks, use of rotating-ball-joint-type connections instead of flexible hose connections Careful consideration should be given to the design, application, construction, and installation of connections (e.g., rotating ball joint, flexible hose, etc.) employed in areas such as the HTF loop connection connections of adjacent solar collector assemblies should be considered so as to prevent possible sources of HTF leaks. Gaskets and seals should be compatible with HTF. Flanges and piping connections on HTF systems should have guards. Note: This Proposal originates from Tentative Interim Amendment (TIA 982) issued by the Standards Council on August 5, The statement in the NFPA 850 documentation, To reduce possible sources of leaks, consider use of rotating-balljoint-type connections instead of flexible hose connections in areas such as the HTF loop connection of adjacent solar collector assemblies, limits the utilization of new technologies. Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised document has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process, or was without adequate technical (safety) justification for the action. Restricting usage of new technologies in parabolic trough is an emergency issue as the current version limits and discourages the utilization of new proven technologies. NTF connections are highly engineered devises. Fire accidents have occurred when careful consideration was not given to the design, application, construction and installation of the connections regardless of the connection type used. Submitter Full Name: GLENN PECHT Organization: SENIOR FLEXONICS Submittal Date: Tue Dec 11 09:43:45 EST 2012 I, GLENN PECHT, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of By checking this box I affirm that I am GLENN PECHT, and I agree to be legally bound by the above and the terms and conditions contained therein. I understand and intend that, by

27 Page 17 of 23 Public Input No. 16-NFPA [ New Section after A ] A NFPA 54, National Fuel Gas Code, provides guidance for the design, installation, and testing of applications operating at pressures less than 125 psig (861.8 kpa), such as hot water heaters, space heaters, cooking applications, auxiliary boilers and emergency generators, and should be considered a good reference for these type applications in power generating facilities. NFPA 54 specifically excludes piping in electric utility power plants that supplies gas utilized directly as the fuel in the generation of electricity. These systems typically operate at pressures greater than 125 psig (861.8 kpa) which is beyond the scope of NFPA 54. A.7.2.4(1) Pigging is discussed at length in CGA G-5.6 Section 6, which describes mechanical scraping or pigging. A.7.2.4(2) Aerated water jet flushing is a process where highly aerated water is forced as a slug down a pipe at speeds of 40 to 80 feet per second (12.2 to 24.4 meters per second) to dislodge debris, weld slag, corrosion deposits, and other foreign objects from the pipe. A.7.2.4(3) High-pressure water jet flushing is a process where high-pressure jets are used to scour debris, weld slag, corrosion deposits, and other foreign objects from the pipe. A.7.2.4(4) Nonflammable gaseous media methods for clearing debris from the fuel gas piping include the use of air, an inert gas (such as nitrogen), or steam. These methods employ the same principle as a gas blow, with the nonflammable medium substituted for the natural gas. The key to making any of these methods work is to achieve sufficient flow velocity within the piping system to blow any debris that can damage the equipment in operation out of the piping. Guidance regarding recommended flow rates should be provided by the equipment manufacturer. A It is often recommended that oxidants like air be diluted by a nonreactive ( inert ) gas, such as nitrogen, carbon dioxide, or argon, to levels such that when a flammable gas is introduced a flammable mixture is not generated. The reverse is also true; dilute the fuel before adding air. Flammability ranges for various fuels are noted as part of Table of NFPA 497. While this addresses fire hazards, the nonreactive gas is an asphyxiant and proper cautions are to be followed. This best practice is discussed in CGA G-5.6 Section A Maintenance and repair of fuel gas piping should be performed in accordance with Subsection of CGA G-5.6.

28 Page 18 of 23 Note: This Proposal originates from Tentative Interim Amendment (TIA 1004) issued by the Standards Council on October 20, The 2010 edition of NFPA 850, Recommended Practice for Fire Protection for Electric Generating Plants and High Voltage Direct Current Converter Stations, contains a conflict with NFPA 54, National Fuel Gas Code, in that it is referenced in the Recommended Practice while NFPA 54 states that it excludes utilities. The proposed TIA intends to correct this conflict as well as offer guidance that would lessen the recognized hazards associated with the cleaning, inerting and purging of fuel gas piping systems associated with electric generating plants. The reference and applications to NFPA 54 has been clarified in the proposed TIA as it applies to low pressure fuel gas piping systems at power generating plants. New references are included for applicable documents that provide guidance for high pressure fuel gas piping systems. In addition, guidance is provided for the safe cleaning, inerting and purging of fuel gas piping systems in both new construction phase as well as repair and maintenance phase. Emergency Nature: In February 2010, there was a large natural gas explosion at the 620 MW gas and oil fired Kleen Energy Plant located in Middletown, Connecticut. The plant was 95% complete and was planned to go on line in June The explosion resulted in six fatalities. The facility was conducting a gas blow of the fuel gas piping using natural gas when the explosion occurred. The physical damage was in the millions and caused a delay in the project for two years. The proposed TIA intends to address potential hazards related to this incident. The proposed TIA meets Sections 5.3(b) and 5.3(d) of NFPA s Regulations Governing Committee Projects for justification of its emergency nature, which read as follows: 5.3(b) The document contains a conflict within the document or with another NFPA document. 5.3(d) The proposed TIA intends to offer to the public a benefit that would lessen a recognized (known) hazard or ameliorate a continuing dangerous condition or situation. Submitter Full Name: Rickey Johnson Organization: One Beacon Energy Group Submittal Date: Tue Dec 11 10:05:39 EST 2012 I, Rickey Johnson, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of By checking this box I affirm that I am Rickey Johnson, and I agree to be legally bound by the above and the terms and conditions contained therein. I understand and intend that, by

29 Page 19 of 23 Public Input No. 2-NFPA [ Section No. C.1 ] C.1 Introduction. This annex summarizes the results of fire tests in which automatic sprinklers or water spray systems were used to extinguish or control fires in oil and grouped cables. Also included in this annex are results of tests conducted on fiberglass stack liners. TEST Submitter Full Name: Marisol Ballester Organization: NFPA Submittal Date: Thu May 10 11:57:15 EDT 2012 I, Marisol Ballester, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of By checking this box I affirm that I am Marisol Ballester, and I agree to be legally bound by the above and the terms and conditions contained therein. I understand and intend that, by

30 Page 20 of 23 Public Input No. 19-NFPA [ Section No. C ] C Tests were conducted by FM Global in [7] The test configuration included a turbine pedestal measuring 15 ft wide 20 ft long 18 ft high (4.6 m 6 m 5.5 m), with a 7.5 ft (2.3 m) grated walkway extending along one edge and an adjacent lube oil tank with a dike surrounding the tank. Twentythree full-scale tests were conducted in the FM Global large burn laboratory. Initially, they were intended as demonstration tests to show clients potential fire risks. However, early in the planning process, the scope of the effort was expanded to include a research component. Spray fire, three-dimensional fire, and pool fire testing was conducted using various fire protection systems. Mineral oil was used with a flash point of 261 F (127 C) and a 19,080 Btu/lb (44,345 kj/kg) heat of combustion. Ten spray fire tests were conducted. Lube oil was pumped through a nozzle under pressure at a rate of 20 gpm (75.7 L/min). The spray fire under free burn conditions generated a heat-release rate of 40 MW. The nozzle was located above the lube oil tank and directed toward the ceiling. Protection used included ceiling sprinkler protection only and local protection near the spray: 8 10 ( m) spacing with fusible link heads and 5 5 ft ( m) spacing with open head sprinklers. The open head sprinkler arrangement used sprinklers with four different K factors (2.6, 5.6, 8.0, 11.2 gpm/psi 1 2 ) located 6 ft (1.8 m) above the spray. Ceiling temperatures during spray fires reached 1500 F (816 C) without sprinkler protection and slightly less with ceiling sprinklers. Closed head sprinklers on 8 8 ft ( m) spacing did not operate during the spray fire portion of the test. Open head sprinklers on 5 5 ft ( m) spacing with a K factor of 8.0 and a discharge pressure of 50 psi (3.5 bar) or greater did not extinguish but seemed to be most effective in controlling temperatures from the spray fires. This protection arrangement reduced gas temperatures at the ceiling from a maximum of 1500 F (816 C) to below 400 F (204 C). Two three-dimensional fires were conducted. A flowing fire simulating a leak at a fitting on the turbine operating floor was ignited and allowed to flow off the platform into a pan on the ground floor. The flow rates varied from 6.0 to 10.5 gpm (22.7 to 39.7 L/min). Automatic sprinkler protection was provided below the operating floor and below the grated walkway around the turbine. Automatic sprinkler protection did not control the three-dimensional component but appeared to limit the size of the pool fire on the ground floor. Eleven pool fire tests were conducted and compared with the results of another pool fire test with sprinklers at a higher elevation. Tests were conducted with below the turbine pedestal with lube oil contained in a 81 ft 2 (7.5 m 2 ) pan. Sprinkler protection was about 15 ft (4.6 m) above the oil surface. Densities of 0.20 and 0.30 gpm/ft 2 (12 and 18 mm/min) were used. Closed head and open head sprinkler protection was used. Pool fires were most reliably extinguished by sprinklers with a density of 0.30 gpm/ft 2 (12 L/min m 2 ). Another pool fire test series was conducted at 30 ft (9.1 m). [8] It was found at an elevation of 30 ft (9.1 m) above the oil surface that a density of 0.40 gpm/ft 2 (16 mm/min) was needed to extinguish a pool fire. It was concluded that sprinkler density needed depends on height above the pool fire.

31 Page 21 of 23 The Section, inserted in the last code change cycle, refers to tests as noted in Reference 7. Reference 7 is not available in the NFPA records, and is unavailable in the public domain. This is counter to NFPA policy which requires that code change documentation and referenced reports in NFPA Standards be publically accessible and available. Submitter Full Name: JOSEPH SCHEFFEY Organization: HUGHES ASSOC INC Submittal Date: Wed Jan 02 08:48:56 EST 2013 I, JOSEPH SCHEFFEY, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of By checking this box I affirm that I am JOSEPH SCHEFFEY, and I agree to be legally bound by the above and the terms and conditions contained therein. I understand and intend that, by

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